You are on page 1of 15


Plaintiff *
v. *
* Case #: 24-C-16-003573
Defendant *


COMES NOW, Defendant Matthew Chan (referred as Mathew Chan in the above

caption) who hereby submits to the Court supplemental exhibits in support of "Defendant's

Motion to Vacate Consent Judgment/Order" filed on September 6, 2016 and "Defendant's

Response to Intervenor's Motion to Intervene & Motion to Strike Judgment" filed on October 24,


1. Defendant submits articles published by the Providence Journal (Exhibit A), Public

Citizen's Consumer Law & Policy Blog (Exhibits B & C) and Washington Post's Volokh

Conspiracy (Exhibit D). In summary, the articles support and reveal the following:

A. Through the Rhode Island case, Bradley Smith v. Deborah Garcia, it has been

reported that Richart Ruddie, through his companies, filed forged documents on behalf

of his clients to obtain fraudulent consent orders, similar to the one filed against the

Defendant in this case. A copy of a check by one of Ruddie's companies was found to

be used to pay to file the lawsuit. (Exhibit B)
B. Chief Judge William Smith in the Smith v. Garcia case reportedly asked the U.S.

District Attorney for the District of Rhode Island to open an investigation. In fact,

there is now a federal investigation into Richart Ruddie. (Following the release of the

most recent Public Citizen article [Exhibit C], Defendant placed a call to the US

Attorney's Office in Rhode Island to speak with a prosecutor. Defendant was informed

that there exists a case named U.S. vs. Richart Ruddie.)

C. It is reported that Ruddie settled the Rhode Island case for $71,000 in a non-

confidential agreement so that he would not have to be subpoenaed and be forced to

produce documents that might reveal the knowledge and involvement his clients had

about the fraudulent lawsuit / fraudulent consent order scheme. Ruddie allegedly

settled the matter in that case to shield his clients from further discovery and scrutiny

in a civil claim. It is reported that Ruddie insisted on protecting his clients for

undisclosed reasons. (Exhibit C)

D. Part of Ruddie's settlement is that he will fully cooperate to have fraudulently-

obtained consent orders lifted. One such case is in the Baltimore City Circuit Court,

Smith v. Levin, 24-C-15-0047889. (Defendant expects there will be new filings in the

docket for that case in the near future.)

E. It has been reported there are approximately two dozen other cases throughout the

U.S. with fraudulently-obtained consent orders that Ruddie was involved with.

Reportedly, part of Ruddie's obligations is to help resolve and lift the fraudulent

consent orders for each of those cases. (Exhibit C) [Defendant anticipates that Ruddie

may intervene in this case in the near future to support dismissing this case and

vacating the consent order.]

2. Although Defendant's new exhibits do not materially alter Defendant's earlier requests

from this court, Defendant hopes that the Court will take into account the breadth of new

information uncovered and appropriately exercise its full powers and authority to remedy

the situation to dissuade others who might consider such illegal and fraudulent actions in

the future.

3. Intervenor Mitul Patel stepped forward on September 21, 2016 in his "Motion to

Intervene, Motion to Strike Judgment / Answer to Defendant's Motion to Vacate Consent

Judgment/Order" to support Defendant's requests. However, Defendant stringently

emphasizes that Patel only did so after he was caught by Defendant (with the assistance

of Yelp) presenting a fraudulently-obtained consent order from this court to Yelp. In fact,

Patel's emails to Yelp shows when he emailed the fraudulently-obtained consent order to

Yelp and specifically requested Yelp to remove Defendant's consumer review of Patel.

(Previously submitted as an exhibit on October 24, 2016 but resubmitted here as Exhibit

E). The fraudulently-obtained consent order was presented in an attempt to remove

Defendant's negative consumer review of his experience about Patel's business practices

and prior disciplinary record with the Georgia Board of Dentistry.

4. Subsequently, the revelation of Patel's scheme against Defendant directly caused a chain

of events which ultimately led to the public reporting of this fraudulent consent order

scheme and compelled Defendant to unilaterally come forward and attempt to clean up

the matter in this court.

5. In light of recent developments and reporting revealed in the supplemental exhibits

(Exhibits A, B, C, D), Defendant makes the additional request from the Court that

Intervenor Mitul Patel be instructed to preserve all communications, letters, emails, faxes,

other communication records, contracts, agreements, and any other business records in

connection with Richart Ruddie, Ruddie's companies, agents, employees' or contractors.

Defendant feels this request is both necessary and reasonable as this court, another court,

and/or investigative agency may soon require them.

6. In conclusion, Defendant requests the following from this court:

A. Vacate the consent iudgment order and dismiss the case with prejudice with costs

payable to the Defendant by Plaintiff;

B. Refer the matter to an investigative agency or authority this Court deems appropriate;

C. Instruct Intervenor Mitul Patel to preserve all letters, emails, faxes, other

communication records, in addition to contracts, agreements, and any other business

records in connection with Richart Ruddie, Ruddie's companies, agents, employees, or

contractors or any other person or entity that was involved in the filing of this

fraudulent consent order;

D. Such other and further relief the Court deems just and proper under the


This 16th day ofMarch.2017.

Matthew Chan, PRO SE
P.O. Box 6865
Phone: (762) 359-0425


I HEREBY CERTIFY that I have this 16th day of March,2017 mailed a copy of the
via First class
postage prepaid to the following:

James G. Maggio & Steven D. Shemenski
802 Ingleside Ave.
Catonsville, l\tlD 21228