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1. We are living on the bottom unit at Village at Eagle Creek HOA. In 2009 there was a toilet overflow in the 2nd bathroom from the unit above ours. In 2010, we discovered that there were large patches of yellow on the ceiling of my master bathroom. In August 2011, water with mixture of excrement started leaking into our master bathroom. The three leaks are unique and not related to one another. In 2009 under Case 49K05-0904-SC-2680, Perry SCC entered judgment of $1042.86 for toilet over flow in favor of Kay Kim, Pro Se-Plaintiff. In 2010 under Case 49K04-1009-SC-3527, State Farm Insurance Attorney Robert F. Ahlgrim Jr. represented Defendants Kyle and Shannon Love. In his reply he lied by stating that the 2010 Case is the same one as the 2009 Case. The Defenders knowing the distinction of two Bathrooms by their descriptions mislead the Court also. In our reply to their Motions, we explained that the 2010 Case (master bathroom) is not the same as the toilet in the 2009 Case (2nd bathroom). In 2010 under Case 49K04-1009-SC-3527, Attorneys Lori A Coates, Richard A Rocap, Michael Brown represented the Defendant, VECHOA and State Farm Insurance Attorney Robert F. Ahlgrim Jr. represented the other Defendant in the Case. The Case was continued numerous times in the Perry Township Small Claims Court, Honrable Judge Robert S. Spears with own motions. The Defendant and the Defendants attorneys did not show few times on the Courts hearing date but Judge Spear would not grant default judgment to Kay Kim, Pro Se-Plaintiff. So Kay Kim, Pro Se-Plaintiff decided to ask the Perry Township Small Claims Court to dismiss all defendants without prejudice so that she can file/attach her Complaint in the ongoing Civil Superior Court Case 49D14-1011-CT-048790. Attorney Robert F. Ahlgrim unprofessionally shared the false and misleading information and conspired with the other Attoneys, Lori A. Coates, Michael E. Brown, and Richard A. Rocap even though he is not representing their client. Kay Kim filed claims in the Civil Superior Court #1 under Cause No: 49D04-1011CT-048790. The Defendant-VECHOAs attorneys-Michael E. Brown, Casey R. Stafford, and Lori Coates for the Defendant, lied to the Court and asked for Summary Judgment because the case is already ruled by the Perry Township Small Claim Court. This is a complete lie because their client is not a party of the 2009 Case. Never the less, the Judge Sherry K. Reid dismissed the case under the false pretence.







On August 5, 2011 there was a new leak in my Master Bathroom and Kay Kim filed a Complaint on August 8, 2011 in the Perry Township Small Claim Court under Case 49K04-1108-SC-2739. For the Defendants-Shannon & Kyle Loves attorney Robert F. Ahlgrim again conspired, lied, and claimed that the leak is the same as the one filed in 2009. Attorneys Michael Brown, Casey R. Stafford, Lori A. Coates for the Defendant-VECHOA presented the dismissal from the Civil Courts case 49D141011CT-048790 and again Attorneys Michael Brown and Lori A. Coates for the DefendantVECHOA conspired to lie to the Perry Township Small Claims Court and told the Judge Robert S. Spear that the new Case is the same as the one dismissed in the Civil Superior Court.


I am attached affidavit filed with the Small Claims Courts for your reference. Attorney Robert F. Ahlgrim intentionally lied to the Court and shared his lie and conspired with the other Attoneys who use the same lie to get a Summary Judgment from the Civil Superior Court. Attorney Michael Brown for the Defendant-VECHOA then used a Court Judgment issued under false pretence to mislead the Perry Small Claims Court Judge in Case 49K04-1108-SC-2739. This case was dismissed with prejudice. All cases for in favor of the Defendant are on a appeal. We have to appeal in the higher Courts because of their lies and conspiracy and there is no other recourse for us. Attorneys intentionally continue to conspires and lies in Court to further their cause.



I affirm under the penalties of perjury that the foregoing statements are true and accurate to the best of my knowledge and belief.

Dated: September 08, 2011

_______________________ Kay Kim, Pro Se-Plaintiff/Appellant