You are on page 1of 10

flLEO A

,\; \m\NU DISCIPLINE BOMRO


State of Michigan
20\8 JUN - 5 AM": 3 ,
Attorney Discipline Board

Grievance Administrator,

Attorney Grievance Commission,

Petitioner, Case Number 18-49-GA

v.
Ralph Wendell Kimble II, P64054.

Respondent.
1
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _- J

Answer to Complaint

1. Deny,
2. Deny,
3. Deny,
4. Deny, further state respondent does not have a legal business.
5. Admit,

Count One

6. Neither admit or deny. Leave Plaintiff to his proofs. Statement lacks sufficient

information or knowledge to form a belief as to the truth of the allegation.

7. Deny,
8. Deny, further state I have not called my penis "Little Ralphie".
9. Deny,
10. Deny,
11. Deny,
12. Deny
13. Deny and further state respondent has not grabbed anyone without their consent.
14. Deny,
15. No reply necessary, Respondent lacks any personal information.
16. No reply necessary.
17. No reply necessary.
18. No reply necessary.
19. No reply necessary.
20. Deny Respondent committed any Illegal acts or engaged in any inappropriate conduct
that is sanctionable.

Count Two

21. Neither admit or deny as the name of witness is riot pled. Leave Plaintiff to proofs.
22. Neither admit or deny leave Plaintiff to proofs.
23. Deny,
24. Deny, leave plaintiff to proofs
25. Deny
26. Deny, leave plaintiff to proofs
27. Deny. Further state the only thing I asked Evon Staley was she ready to come back to
work after her husband's passing. Deny I touched her.
28. Deny
29. Deny, leave plaintiffto proofs
30. Deny

Count Three

31. Neither admit or deny as respondent lacks information based on Plaintiff's failure to
plead with specificity. Witness is not named.
32. Deny.
33. Admit a Karen Martin came to the prosecutor's office. Further state I asked her if she
was excited that I was having babies. Karen Martin is the one that blew up in my office
and started attacking myself and my clerk calling her dirty names and swearing. Witness
to this altercation was Lori Blair and Tangela Gautsche. Further Karen Martin was
surprised when I told her that her son had better stop texting my girlfriend at midnight
trying to "hook up" with her. He is married and a deputy. His name is Phil Martin.
Karen Martin then verbally harassed Tangela Gautsche outside in the main hallway
about Phillip Martin.
34. Deny

Count Four
35. Neither admit or deny as the witness' name is not plead and respondent lacks
knowledge to reply.
36. Deny, further state that this allegation lacks any specificity. Respondent has no Idea
who witness 4 daughter-in-law is.
37. Deny, further state allegation lacks any specificity.
38. Neither admit or deny. Leave Plaintiff to proofs. Allegation lacks specificity.
39. Deny
40. Deny as this never happened, further state leave plaintiff to proofs. Allegation lacks
specificity. Tangela Gautsche would be the witness.
41. Deny.

Count Five

42. Neither admit or deny as allegation in pleading lacks specificity to form opinion. leave
plaintiff to proofs.
43. Admit that a defendant made a claim that respondent was "hitting on my woman" and
that the woman referred to was a victim.
44. Deny respondent ever made sexual advances towards any victim and further state
respondent never made a sexual comment to this victim. Allegation does not state
what was allegedly stated and does not contain requisite specificity for pleadings.
45. Admit respondent stated in the privacy of his office, without victim present, that she
was not a victim. I did state she was not to be allowed back into the prosecutor's office
because she was a trouble maker and I did not want any more false accusations being
made. Again, this was in my office behind locked doors and absolutely no public
persons were present.
46. Deny
47. Admit that! have complimented Det"ise Mack but only after she has been moping
around saying how old she was and how ugly. Deny I ever said I would lido her".
48. Deny, leave plaintiff to proofs.
49. Deny, leave plaintiff to proofs
50. Deny

Count Six

51. Deny, further state she left because she could not pass the requisite tests.
52. Neither admit or deny leave plaintiff to proofs
53. Neither admit or deny leave plaintiff to proofs
54. Deny I asked anyone to sext with me. May have called her a fucking bitch however
allegation lacks specificity to whom the allegation was directed or when and where.
55. Deny.
56. Deny

Count Seven

See attached answer

57. Neither admit or deny as allegation lacks specificity.


58. Admit
59. Admit
60. Deny, further state this allegation has already been answered.
61. Deny
62. Deny, further state Lona Julien never denied making a complaint.
63. Already answered this grievance.
64. Again, I already answered this grievance, further state Lona Julien asked me to leave
because she was caught in a lie and didn't have the honesty to answer for it.
65. Again I never swore and never yelled. I was confident in my stature but not
inappropriate.
66. I temporarily stayed in the Friend of Court to address office issues. I did say that I had
legal business and could not be forcibly removed from the area. I did leave on my own
accord. Deny officers got me to leave. I left on my own accord.
67. Deny, further state i left on rny O"I/,\/n accoid.
68. Deny, further state This was done due to her mistreatment of numerous citizen's and
her own conduct.
69. Deny, further state This was done due to her mistreatment of numerous citizen's and
her own conduct.
70. Deny.

2018
RALPH W. KIMBLE II

PROSECUTING ATTORNEY

BRANCH COUNTY

Ralph W. Kimble II

Branch County Prosecuting Attorney

Answer Complaint #17-2645

, .
On 9-26-2017 I received a phone call from Dwayne and the State of Michigan Office of Child Support. I
think I called 517-241-7728. I called Dwayne and he stated that the Branch County FOC had called him
and complained that my office was not doing our job. I asked who exactly called and he stated it was
Lona Julien. I asked what the complaint was. He said she only said my office was not doing thejob on
file #913321673 and that my 4D contract clerk was not working and would not be back to work until
sometime in November. This was due to her being out on maternity.leave. This was a clear attempt to
try and get the 4D contract taken from my office and placed with her office and to get the clerk fired.

A background of Lona Julien's start of a hostile work environment against me started when my
ex-wife Alice Kimble and I separated. Ms. Julien became increasingly hostile towards me and took the
side of Alice and against myself. She then became hostile towards my clerk and significant other
Tangela Gautsche, the 4d clerk. Ms. Julien spread hateful untruths about myself and Ms. Gautsche,
gossiped like a teenager, focused enormous amounts of work time with gossiping and spreading of lies.
She even tried to get Alice Kimble to move in with her. This started around November of 2016. She
then started to reach out to others who were "taking sides" in the divorce in attempts to create trouble
for me and to make doing my job harder. Ms. Julien has been very deceitful and mean against myself
and Ms. Gautsche.

I pulled the file above mentioned fileMs. Julien complained about and it was up to date. Note
the Circuit Court Judge has made statements to me that I could transfer the contract my office has to
the FOe. Ms. Julien is his employee. I believe the FOC Lona Julien was calling and making false
allegations about my office in an attempt to have the contract removed from my office to her office. I
called FOC and left a message for Lona to discuss why she would call the office of Child Support and
make such blatant lies. I was not happy that she made false claims against my office and believed that
she would not call me back because she knew she made false accusations against me. I had to address
her hostile continued personal inappropriate actions against me. I then went to her office to see if she
would discuss this matter. She was meeting with Mr. Galinis. It should be noted Mr. Galinis would say
anything to try and get any prosecutor in any form of trouble. He has a long known history oftrying to
bait others and then complain about any responses. Deputy Mark Miller is witness to this. Mrs.
Holbrook asked if she could help me. I said no I needed Lona. I never made any grin or whatever
inappropriate body gestures perceiye'd by Mrs.'Holbrook. Clearly I was upset about the false
accusations combined with the horrible treatment from Ms. Julien I have experienced over the last year.
Lona asked if she could help me and I said yes. I then asked her why she called MiSCES, I meant

31 Division Street, Coldwater, MI 49036 • (517) 279-4319· Fax (517) 279-6437


Dwayne, and complained that my office wasn't doing its job. She immediately denied that she did such
a thing and said she was going to deal with Galinis. I said I would wait. She said she was busy and I said
that I would wait. She was the one that addressed me and was yelling at me. Lona did ask me to leave
and I said I would wait. She then started yelling for a Deputy. I said she did not have the right to have
me removed and I wanted to talk about why she is making false accusations against my office. She kept
yelling and screaming at me. She said I was not going to bully her like I do my staff and that I treat my
workers bad and wasn't going to do that to her. She then stated I sunk to a new low. I asked what new
low? Coming to talk with her? Clearly she was referring to my personal life of which she has taken a
weird interest in. Ms. Julien was the one yelling and making inappropriate personal attacks against me.
I never yelled at her. I never threatened her or anyone else in her office. I never swore or used
inappropriate language while I was addressing her and I did not have "clenched teeth".

This was just a simple disagreement that was never talked about again. Arguments and
disagreements happen at work. I thought that trying to work it out somehow would put an end to her
hostility and pettiness.

No idea why they think they needed the locked door. Simply put that was not on the FOC part
and they need to come to realization that simple disagreements happen and should be worked out by
actually communicating with each other. Not sure what retaliation against anyone in FOC office means.
I was only dealing with Lona Julien and Officer Hurley. Secondary was Mr. Singer. I believe some of the
workers are clearly biased due to Ms. Julien's constant vendetta against me or are just plain scared to
come out and speak against her inappropriate conduct on this date do to her retaliation against them.
Rhonda Harmon is an ex employee who can testify to how inappropriate Lona Julien is in her office and
how vindictive she is in creating hostile work environment. Her telephone number is 269-908-3558. She
is expecting your call.

Sure I thought about filing a grievance against Lona Julien for lying and making false statements
to get a contract and her hostile actions against me but I did not think it was in my best interest as I
feared further retaliation by her, her employer, and those who thought they should turn against me for
my personal life and break-up with Alice.

I never yelled, I did talk firm and stern. I never swore. I never threatened anyone. I did say that
Deputies were working for the wrong team. I meant that Mr. Hurley is such an honorable man of
Integrity that he shouldn't be working for such a devious liar.

As far as being grieved for having a relationship with my clerk and starting a family with her, It
should be known that I am divorced a nd we are raising our children together. I would not do it the same
way again looking back. However, life takes us in weird unseen directions. Plus, Ms. Julien does not and
did not know of my personal situation. with Alice Kimble. I will not air any of that. What I find
interesting is Ms. Julien finds my actions immoral. However, she herself had a child out of wedlock, is a
single parent without a father in the child's life. Ms. Julien has made numerous statements against men
and specifically that her home is not welcome to any men.

I did not have to be removed. I left on my own after realizing Lana Julien wasn't going to fess up to her
lie.

As for not changing my place of employment with the Bar Journat I have clearly put my place of
employment every year on the form. I have no idea why they have it as Kimble and Kimble. I never
looked in the Bar Journal to see what it says about me. After receiving the grievance, I contacted the
State Bar of Michigan to rectify the miss-publication. They were very nice and stated the employer was
wrong because the computer messed the name portion up. The address was correct. The phone
number was correct. They immediately fixed the place of employment. This was done 10-31-2017.

FILED nAon
\; \,.;:JiEl DISCIPLINE ~ ,,,l\U
State of Michigan
'l0\3 JUN -5 AM": 32
Attorney Discipline Board

Grievance Administrator,

Attorney Grievance Commission,

Petitioner, Case Number 18-49-GA

v.
Ralph Wendell Kimble II, P64054.

Respondent.

------------------------~/

Discovery Demand

As permitted by MCR 9.115, Respondent makes the following demand for discovery:

1. Copies of all exhibits petitioner intends to introduce at hearing.


2. Names and addresses of any persons petitioner may call as a witness at the hearing, in
accordance with MCR 9.115.

Failure to produce and comply with this discovery demand may subject you to sanctions under
MCER 9.115 and MCR 2.313.

Date Ralph W. Kimble II

31 Division St. Coldwater, MI 49036

517-279-4319
State of Michigan

Attorney Discipline Board

Grievance Administrator,

Attorney Grievance Commission,

Petitioner, Case Number 18-49-GA

V.

Ralph Wendell Kimble II, P64054.

Respondent.

------------------------~/

Witness list

Judge P. William O'Grady, 31 Division St. Coldwater, MI 49036

Judge Brent Weigle, 31 Division St. Coldwater, MI 49036

Lori Blair, Branch County Prosecuting Attorney Felony Clerk, 31 Division St. 49036

Assistant Prosecutor Scott Smith 31 Division St. Coldwater, MI 49036

Chief Assistant Prosecutor Valerie White, 31 Division 5t, Coldwater, MI 49036

Tangela Gautsche Prosecutors office, 31 Division St, Coldwater, MI 49036

Marcia Barry, Probate Court, 31 Division 5t. Coldwater, MI 49036

Rhonda Harmon, Ex FOC employee, 269-908-3558

Branch County Sheriff Deputy Carl Sevidal, 31 Division 5t. Coldwater, MI 49036

David Coyle 31 Division St. Coldwater, MI 49036

FILED

STATE OF MICHIGAN ,\.~ [[JEM] DISCIPLINE BUARD


ATTORNEY DISCIPLINE BOARD
2018 JUN -5 AM II: 32
GRIEVANCE ADMINISTRATOR
ATTORNEY GRIEVANCE COMMISSION,
Petitioner,
vs. CASE NO: 18-49-GA

RALPH WENDELL KIMBLE II (P64054)


Respondent.

PROOF OF SERVICE

STA TE OF MICHIGAN )
) ss
COUNTY OF WAYNE )

Lorene C. Blair, being duly sworn, deposes and says that on May 31, 2018, she served a copy of
Answer to Complaint, Witness List, and Discovery Demand and this Proof of Service, upon the
following:

Mr. Alan M. Gershel Mr. Harold G. Schuitmaker


535 Griswold St., Ste 1700 181 W. Michigan Ave., Ste 1
Detroit, MI 48226 Paw Paw, MI49079

Ms. N amita Sharma Mr. Gregory W. Russell


2555 S. 11 th St., Ste B 227 W. Michigan Avenue
Kalamazoo, MI 49009-2174 Kalamazoo, MI 49007-3734

by enclosing same in a sealed envelope properly addressed with sufficient postage affixed and
depositing in the United States mp.jl.

Lorene C. Blair

Subscribed and sworn to before me


this the 3 pt day of May, 2018.

~~G~~

Tangela Gautsche Notary Public


Branch County, Michigan
My Commission Expires: 8/14/2023