KENNETH WWPEM LAWEE GINGER DUNN [Ty TO: KENNETH RAY MOSS, JR., ESQ. DATE: APRIL 15, 2023 1180 Highway 17 Dunn v. Dunn Little River, SC 29566 2021-DR-26-2426 (843) 491-4315 Dunn v. Chaposky & Dunn 4:22-00387-JD MR. MOSS: VIA EMAIL ONLY In your August 26, 2022 email, you indicated you would mail a USB containing my complete file to my home address, but I did not receive the information, I did receive your closure letter dated January 13, 2023. but there was no mention of the USB. Can you please advise? Also, there is conflicting information in your emails dated August 30, 2022 and October 31, 2022, and the latter does not correspond with my recollections, the emails that followed, or the public docket entries on the pacermonitor.com web site, Can you please clarify your positio (EXHIBIT A - “EMAIL/CLOSURE LETTER/TRACKING: G. DUNN TO WWPEM LAW 2022.08.18") ( (EXHIBIT B - "Dunn v. Chaposky & Dunn Re: pacermonitor.com"); (EXHIBIT C - "QUOTES & EMAILS: KENNETH MOSS & GINGER DUNN") ‘On August 30th you wrote: " Ecould not possibly be more candid with you about when and why I filed an Amended Complaint on your behalf and the motion to reopen the case.” (emphasis added) On October 31st you wrote: " The motion that I was about to file when you instructed me not to was to reopen the case... As you will recall, I did not file that motion to reopen because you instructed me not to do so." (emphasis added) Indeed, T do not recall instructing you "not to do so” because; as you will recall, T contacted you to learn why you had filed your Amended Complaint and Motion to Reopen Case without my knowledge or consent.EE GINGER DUNN [Ty I do recall the subsequent lengthy correspondence in which you argued as to why your actions were justified, I do recall instructing you to take no further action on my behalf ABTER you filed your Amended Complaint and then again, AFTER you ignored my instruction and filed your Motion to Reopen Case. Can you please explain why you countered your own argument from one email to the next and why you did not acknowledge your previous stance whatsoever? Can you please explain why it appears you have endeavored to create this fraudulent indicia? (EXHIBIT D - "POST-MOTION QUOTES & EMAILS: KENNETH MOSS & GINGER DUNN") If my file has been closed and no preparation time is needed on your end, I can pick it up Monday, April 17, 2023. look forward to your reply, Ly CB GINGER H. DUNN Phone. Email Address. 043-446-5726 ghdeonsult@gmail.com 1835 Sarvis Drive, Loris, 329569EXHIBIT Aia | Gmail G. D. Update Ginger Dunn <1 Thu, Aug 18, 2022 at 9:55 PM To: "Richard L. Snyder" Richard, | have mailed a cashier's check to your office, . [Aunniet 10th\ % which should arrive tomorrow (August 19th). 1uu sai were Were no invoices prior to January 25!" | had our first meeting calendared in mid-December. Can you double check? | am trying to keep a detailed record of attorney fees. | received those late bills from Vorys in Columbus, and | don't want to leave an invoice outstanding or be surprised later. | had hoped to hear from you or Mr. Moss regarding Judge Dawson's ruling. Can you please let me know what | need ta do on my end? Thank you, GingerTravel bisteny =o | Sere v a So a es aes eet) eater tae St | spectator nati rear rs | cae — ml ae ss ey ‘Saturday, /20/2022 40080} Atlocal FedEx Fecity FLORENCE,SC wom || oie — mt Sees ames a. wm Got nangiemie 1 Back to topGINGER H. DUNN legaleinger@.gmail.com (843) 446-5726 August 15, 2022 WW.PEM. VIAUS ONLY 626-A Sea Mountain Highway North Myrtle Beach, SC 29582 Re: Invoice #17577 File No, SC-9785-001 To Whom it May Coneem: Enclosed is payment for the invoice listed above. Please forward your final bill and Jet me know when I may come by to pick up my file and tie up loose ends. Feel fice to contact me with questions or concerns. Regards, Ginger H. DunnMme Engich> United states South arcing FedEx Office Print & Ship Center 49 whee 23B reviews Closed-Opens at 3:00AM — Monday 258 Hwy 17N 5 North Myrtie Beach, South

Ietoing col’ an—. — —— STANDARD RATE Package Infornatior: Your Packaging waz iOwxwlFed Shipping ~ Tracking ~ Design & Print ~ Locatior Trave | h i sto ry SORT BY DATE/TIME Ascending Thursday, 8/18/2022 5:05PM @ InFedEx possession Tendered at FedEx location 5:08PM } Shipment information sent to Fed 6&13PM $ Pickedup 9:16PM 9» Arrived at FedEx location 9:32PM $ Shipment arriving On-Time Saturday, 8/20/2022 4:00AM » Atlocal FedEx facility 450AM 4 Delay Package delayed 6:22AM $ Deliveryexception Future delivery requested Monday, 8/22/2022 1:28AM 9 = Atlocal FedEx facilityALY AUGUST 19, 2022 ory PMAes 19, pce pacermonitor.co nq St MOSS SECRETLY FILES AN AMENDED COMPLAINTaNd AUGUST 19, 2022 Peete ee)When Kenneth Moss files an entry such as the AMENDED COMPLAINT (DE. 26) the docket reads: (Moss, Kenneth) Friday, August 19, 2022 Friday, August 19, 2022 26 ZC E Ad JENDED € 8 ON APLAINT agal Witte? (Moss, Kenneth} (Moss, Kenneth)When Ginger Dunn files an entry such as MOTION FOR RELIEF (DE. 32) the docket reads: (prou,) Tuesday, September 06, 2022 32 SG 4 pgs | motion | MOTION for Relief from25 Judgment by Ginger H Dunn. Re: Fed. R. Crim. P. 45.No proposed order.(prou, ) eer Wed 09/07 11:39 / ) junemnent by Ginger H Dunn. Re: posed order(prou,Regardless of the person filing, every "Plaintiff" entry is listed "by Ginger Dunn" Every "Defendant" entry is listed "by George Chaposky" or "by Vernon Keith Dunn." The "filer" is always listed in parentheses at the end of the entry. a $6 WE eS MOTION to Reopen Case by Ginger H Dunn. Respon Crim. P. 45. No proposed order,(Moss, Kenneth) Tuesday, September 06, 2022 2 2 CS Cee roe MOTION for Relief from25 Judgment by Ginger H Dunn. Re Fed. R. Crim. P. 45.No proposed order (prou, ) Wednesday, August 24, 2022 a 20h Soak RESPONSE in Opposition re27 MOTION to aan Case Response filed by Vernon Keith Dunn.Re mail or otherwise allowed under Fed. R. Civ. P. 6. (Josey, Jon) Thursday, August 25, 2022 cal 26 WS Red ee RESPONSE in Opposition re27 MOTION to Reopen Case Response fled by George J Chaposky.R mall or otherwise allowed under Fed. R, Civ. P. 6. (Wrenn, Catherine)‘Thoreday, August 25,2022 pacermonitor.com SED CoMPCaNT pars rash Gg Whom, en i by {eat Tose, August 09,2072 = SC mma << e UDGUENTis reece Coke cape cnn nib eid: 08) «26mm oo The Cerigarts Otero Netbes 9 Dams Plt fcol mw cae print 9A 10 ard 12); Fad RP, Card) Shee Cae ks aac. redcion over Plt encanto aera rotons provers, he Cour eins Pane Corpo OE +) wha pe. Sgn by Pe naa oph Danser Men 22022 (96 | Wednesday, August 24, 2022 e. $06 ooo RESPONSE in Cipposition re27 MOTION to Reopen Case Resp mail or othenvise allowed under Fad. R. Civ. P.6. (Josey, Jon) 7 $6E CO Ce MOTION to Reopen Case by . Response to Mat Crm P46 No proposes noes, Kenn > Friday, August 19, 2022 o SCRE Der AMENDED COMPLAINT against All Detendants, Service due by Teo a Kenneth) >You have been sent a case filing. e PacerMonitor 2 8/26/2022 9:39 PM To: legalginger@gmail.com Dunn_v_Chaposky_et_al_scdce-.. Gc. Ginger Dunn has sent you the following court filing: Case: Dunn v. Chaposky et al Docket Number: 27.0 Docket Text: MOTION to Reopen Case by Ginger H Dunn. Response to Motion due by 9/7/2022. Add an additional 3 days only if served by mail or otherwise allowed under Fed. ®. Civ. P, 6 or Fed. R. Crim. P. 45. No proposed order.({Moss, Kenneth) Publisher permalink: www. pacermonitor.com/view/63FH3BY/Dunn_v Chaposky_et_al__scdce-22- er: 27.0 MOTION to Reopen Case by Ginger H Dunn by 9/7/2022. Add an additional 3 days only otherwise allowed under Fed. R. Civ. P. 6 o1 proposed order.(Moss, Kenneth)EXHIBIT B™ Gmail GD. —— D> Payment etc. Ginger Dunn Wed, Aug 24, 2022 at 12:46 PM To: "Richard iardsnyaer@wwpemlaw.com> Richard, | am writing to follow up on whether you received payment and the letter I sent overnight to. your office. The tracking shows it was received, but | have not heard from you or your office regarding what steps need to be taken to tie up the loose ends of our engagement as | indicated in my letter. Also, were you able to locate in your notes the work performed before January 25!'? As | mentioned, | have our interaction beginning more than a month prior, and Ms. Ward's office has interactions with you and/or Mr. Moss as far back as December. As | stated previously, | am disappointed | have not heard from you or Mr. Moss regarding the Judge's dismissal of the case on August 9, 2022. | am also disappointed; and indeed, disturbed that you and Mr. Moss represented Judge Buckhannon and her husband without mentioning a conflict to me. Whenever | asked questions about how the federal case related to the Family Court case, they were never addressed. You said you knew nothing about Family Court and could not advise. Mr. Moss said there was no discussion with Ms. Ward regarding how the third-party jurisdictional issues interacted between suits. If you could not advise and Mr. Moss would not advise, why would you take this case? | made you aware the affidavit of Daniel Joshua Jones submitted by Mr. Dunn's Counsel in the federal response had been misrepresented as a Family Court document. | made you aware this was the same affidavit Ward Law worked to omit front the Family Court hearing on Apri 4th, and indeed the same affidavit pulled from my court packet by Ms. Ward in the courtroom at the last possible second. To date, Ward Law has never acknowledged or responded to my questions about this omission. Did you address this with Opposing Counsel? | find it difficult tobelieve there would be no remedy or obligation to bring this misrepresentation of a court document to the federal court's attention. I find it difficult to believe there would be no obligation to report this to the appropriate authority regarding Ms. Ward's actions in Family Court. By design, | am left in the position of reporting people who can and most likely will continue to do me and my family grievous harm. | made you aware Regina Ward had edited out references to Mr. Chaposky and his connections to South Carolina specifically in documents submitted to the Family Court. | made you aware she and her paralegal Ashley Roberts were recording notes in invoices accusing me, their own client, of crimes committed by Mr. Chaposky. On June 1%, | told you and Mr. Moss what had occurred with Judge Buckhannon, Regina Ward, Heather Moore, and Craig Snook leading up to, and surrounding the Rule to Show Cause. | told you specifically my Family Court attomey had lied in court, that Mr. Dunn had lied in court, and that both Ward and Heather Moore knew I had done a single thing they had listed in this Rule to Show Cause, that | did not have the computer referenced, that my son had tried to Having read the Judge Dawson's ruling, | am aware that all points mentioned that were not addressed in the previous motions and responses can be easily addressed by facts and existing evidence. | gave you the paperwork regarding the Rodizio PPP loan during our first meeting. You tapped Mr. Chaposky’s signature on the page and showed Mr. Moss adding, “There's your PPP fraud right there.” More to the point, feel the true issue is the Easion MP 2° draw PPP loan. This is the main issue that fits the rule of law. Why was this omitted entirely? Why was the RBS Columbus, LLC original documentation omitted entirely? | sent over the financials regarding the massive inequity in profit share. We discussed that the company had been put in Chaposky’s name alone on Craig Snook’s instruction in order to shelter funds from ‘potential spousal claims." Why were all these things omitted? After what Ms. Ward did to me regarding the window of appeal after the Rule to Show Cause Hearing, | am concerned there may be some window for necessary action after the Judge Dawson's decision in order to move forward with this suit. As a professional courtesy during this transition of representation, can you please advise me whether there are time sensitive matters | should be aware of moving farward? Please consider me Pro Se at this juncture, so | may receive my file and instructions on whatever I can do to facilitate this transition in whatever manner is most convenient to you. | look forward to hearing from you, Ginger DunnTravel history Thursday, 8/18/2022 Friday, 8/19/2022 Saturday, 8/20/2022 Monday, 8/22/2022 5:05PM 5:08 PM @13PM 9:16PM 9:32PM 13M 9:37PM 4.00 AM 4:50 AM B22AM 1:28AM 1:51AM 3:27 PM SORT BY DATE/TIME Ascending In FedEx possession Tendered at Fed&x location Shipment information sent to FedEx Picked up Arrived at FedEx location Shipment arriving On-Time Atlocal Fedex facility Delivery exception Delivery delayed, scheduled for next At local FedEx facility Delay Package delayed Delivery exception Future delivery requested At local FedEx facility ‘On FedEx vehicle for delivery ‘DeliveredAUGUST 24, 2022 WEDNESDAY (12:46PM) EMAIL: G. DUNN TO RICHARD SNYDER, ESQ. 66 lam writing to follow up on whether you received payment and the letter | sent overnight to your office. The tracking shows it was received, but | have not heard an from you or your office regarding what steps need to be taken to tie up the loose ends of our engagement as | indicated in my letter. GINGER DUNN Me4 Gmail G. D. Payment etc. Kenneth R. Moss Ms. Dunn, | appreciate that you took a great deal of time to compose an impassioned email. Itis clear from my reading that you are not fully aware of some very relevant information, and that you have failed to recall or recognize strategic decisions that you and we made in your case. What has happened to you by the conspiracy and acts of your husband and Mr. Chaposky are truly offensive. You are entitled to feel frustrated, as you evidently do. Outrage would be an appropriate emotion as well. However, | encourage you to direct your frustration and outrage at persons other than your attorneys who have worked diligently to advocate your case. | would be willing to meet with you to discuss all your concems if you would like. However, | did want to respond to what | believe are the most significant of your assertions. | confirm that we did undertake work in investigating your matters and communicating with Attomey Ward prior to January 25, 2022. Attorney Snyder indicated that were looking for time and billing entries for our time devoted prior to January 25. It is evident from our time and billing program that we simply did not bill you for our efforts and investigation prior to January 25. That is not unusual for my firm and my office, as we sometimes do not charge for initial consultations and investigations. Attorney Snyder was left with the impression that you were looking for time and billing entries that predate January 25. There simply are not any. do confirm that | did not discuss with you that my firm and | undertook representation of Judge Melissa Buckhannon and her husband. You should also take comfort in knowing that we never discussed with Judge Buckhannon that we undertook representation of you. Please understand that the matters for which my firm and | agreed to represent you are legally distinct from your Family Court case. And as a practical matter, | did not even know that Judge Buckhannon was a judge involved in your Family Court case. Having naw been made aware that Judge Buckhannon was a judge in your Family Court case, | am not aware of any facts or circumstances that constitute a conffct of interests in our representation of you in the US District Court in the claims that we asserted on your behalf. Judge Buckhannon is simply notinvolved in the US District Court case. | do not know to what you are referring when you asserted “third-party jurisdictional issues interacted between suits”. | simply do not understand what you are trying to communicate The only jurisdictional issues that | am aware of in our US District Court action are Mr. Chaposky's assertion that he does not have minimum contacts with SC (which is false) and the motion and the Court's Order that we did not include sufficiently specific acts that would violate the RICO claim. As to the latter, we feel that we did plead sufficiently the bad acts. The Judge disagreed with us. Recall that we intentionally omitted the claims concerning the Easton MP PPP loans so as to not draw attention to the company that you ultimately wanted to gain control of. Also recall that part of the strategy in your case was to attain a membership interest swap with Mr. Chaposky , in order that Mr. Dunn and you could sort our ownership of the Easton MP in your Family Court action. | would like for us to meet very soon and we do need to discuss whether you intend to relieve us from further representation of you. You are of course entitled to relieve my firm and me from your representation. However, you do need to understand specific deadlines. | have already filed an Amended Complaint behalf to more specifically assert the RICO claims. if you wish to relieve us, we will need for you to sign onto a motion for my firm and | to be relieved as your attomeys. And while your certainly have a right to proceed pro se, | do not encourage self representation in the US District Court. We can have your file materials ready for you to pick up by the first of next week. I would propose that we meet on Monday aftemoon of next week, if that date is canvenient for you. If itis not, | can look to other dates. Ido know that Tuesday and Wednesday of next week are booked for me. KENNETH R. MOSS ATTORNEY AT LAW WRIGHT, WORLEY, POPE, EKSTER & Moss, PLLCEXHIBIT CWEDNESDAY AUGUST 24, 2022 EMAIL: K. MOSS TO G. DUNN nT) MUR Me Malt re OMA my firm and me from’ your representation. However, you do need to _ understand _ specific deadlines. | have already filed an rVeroale( Me dnel ole el eM specifically assert the RICO claims. Gales) 4:18PMWEDNESDAY AUGUST 24, 2022 EMAIL: K. MOSS TO GINGER DUNN Tt Xero M ale M el mi materials ready for you to pick up by the first of next week. KENNETH MOSS 4:18PM14 minutes later... ee PMWEDNESDAY AUGUST rar Oe ee eu eet) KENNETH MOSS ite ai ans) MOTION TO REOPEN CASEWEDNESDAY AUGUST 24, 2022 Pee ee)WEDNESDAY AUGUST oi Oe pacermonitor.co CEA yy? 2-WEEK DEADLINE IS POSTED FOR RESPONSES BY OPPOSING COUNSEL 4:32PMWP minutes later... OE PMWEDNESDAY AUGUST oi Oe pacermonitor.co "OPPOSING COUNSEL" JON JOSEY FILES HIS RESPONSE IN OPPOSITION RE MOTION TO REOPEN CASERee ee). . RACKETEERING Mr. Moss's filings (without Ginger Dunn's knowledge or consent) created an opportunity for Keith Dunn's counsel to respond in opposition, which Jon Josey, Esq. did with speed. George Chaposky's counsel followed suit one day later. Vernon Keith Dunn added verbiage to documents in the South Carolina Family Court case Dunn v. Dunn 2021-DR- 26-2429 in which he requested Ginger Dunn pay all LLC members' legal fees in the Federal suit Dunn v. Chaposky & Dunn 4:22-cv-00387-jd. Kenneth Moss's filing of an Original Complaint intended to fail, an Amended Complaint, and Motion to Reopen the Case (also intended to fail) without his client's knowledge or consent provided further opportunities to charge legal fees which all felt confident the Horry County Family Court would subtract from Ginger Dunn's column in the ultimate division of marital assets. These acts have been made possible through top-down corruption as facilitated by Moss's personal client, Horry County Family Court Chief Administrative Judge Melissa J. Buckhannon.EXHIBIT DAUGUST 25, 2022 THURSDAY (12:52PM) EMAIL: G. DUNN TO KENNETH MOSS, ESQ. ee We did not discuss, nor did | consent to you filing an amended complaint on my behalf. I communicated my wish to end our engagement in my phone call with Mr. Snyder August 9, 2022. When | received no follow up regarding the initial missing billing entries, | emailed Mr. Snyder on August 18th and my confirmed in my email | would send your office payment and a letter from me via overnight delivery set to arrive August 19th. l asked you in this letter what | needed to do to tie up loose ends. as GINGER DUNNUST 30, 2022 INGER DUNN (4:45PM) « ——s al J i ' I could not possibly be more candid Rl Re fled iia when and why I filed an Amended Complaint on your behalf and the motion to reopen the case. eS MOSSFrom: Kenneth R. Moss Sent: Tuesday, August 30, 2022 4:45 PM To: Ginger Dunn Subject: RE: Payment etc. Ms. Dunn, I could not possibly be more candid with you about when and why | filed an Amended Complaint on your behalf and the motion to reopen the case. And I do not intend to delay further in resolving our issues with finality. You indicated last week that you would have direction for me by Monday (yesterday) about whether you wished to have me withdraw the motion and Amended Complaint or to file a motion seeking for my firm and | to be relieved from your representation, | have not received your direction. J will be out of the office tomorrow (Wednesday) in Court hearings. | will not delay past Thursday in either receiving your direction or unilaterally acting to withdraw the filings. KENNETH R. MOSS ATTORNEY AT LAW WRIGHT, WORLEY, Pore, EKSTER & Moss, PLLC‘From: ennoth Moss ‘Sent: Monday, October 31, 2022 3:05 FM ‘Ine Ginger Dunn, (Cet RICMAND L. Srycer subject: Case a:22-cv OSE? 21) Dhani. Chapothy et af Ginger, FYI, the attached Order & Opinion was entered by the foderal judge today. In the ‘Order, Judge Dawyon has denied your motions. Please forward this email and the attachment to whomever ir advising you know, What the Juekge hes conficmed ini this Order @ Opisian bs that yout cane was over when the motion to dtemtss wag granted. — wad of courte dlumtased without which means timply that can rettie the case if you choose to do <0, and in dairi se include mace specific about the RICO claim. You should recall that Ric Snyder, you and | discunsed the requinemoents for pleading with specifics and that we ‘imtonthonally chose not to include all of the information onder to The entities that yeu intended to es Chanel Cilered are At this point, and ns dudes Dawevon's Order 8 Opinion confirms, the case that my Arm and | filed on your behalf 1 over, Aty time and belling software chould have sent to you today a final tnvolee for the fee and coore dewoted to your cate. Yeu will mote ‘that | have crcdited $943.70, which was the remaining amount owing. after crediting the funds that you previously paid to your firm. Abs, you may notice that we have not included any time and billing entries for the time devoted to responding to Pa im As you cave is ower, Lintiend to close my firm's file in these matters. We-will maintaic: either electronic copies or hard copies of your fiic materials associated with your case for a period of six 46) years. Afterwards, we will destroy the records in accordance with my firm's then existing policy conceméng records retention. Mease accept my approciation for considering sy firm and me for your representation. It fs regrettable that our relationship ended as #t did. | da wish you the best of buck fr your caved) goalie forward.OCTOBER 31, 2022 EMAIL TO GINGER DUNN 3a tS The motion that! eke] erel [a voy (][-) ae ee M etic ood (1° menotto —— F reopen the case i as | had filed an Amended Complaint, eM ORM are l Wal: Ree i a whole new case. hes MOSSOCTOBER 31, 2022 EMAIL TO GINGER DUNN 2 PRIORY ete) P ' ie Kel (e Bale) 9i](-aaeiene motion to r eopen because you instructed me not todoso. hess MOSSOCTOBER 31, 2022 EMAIL TO GINGER DUNN (3:36PM) ot hi ei C1 011i) 1s rs 1) SOF] Aa seeking to reopen the case with the Amended forJpere) (elise In ‘oct, you instructed me not to file onyihing else in your case. hea MOSSAPRIL 12, 2023 (WEDNESDAY) LETTER: G. DUNN TO KENNETH MOSS ee Can you please explain why you countered your own argument from one email to the next and why you did not acknowledge your previous stance whatsoever? Can you please explain why it appears you have endeavored to create this fraudulent indicia? GINGER DUNN