Defendant Steve Combs (aka Public Pretender), Attorney for Ronald Reale (June 23, 2010 thru November 30, 2010 *released by his client for lack of representation*)
Defendant Steve Combs, Private Attorney being hereby named personally, is an individual and a resident of this jurisdictional district, was initially a court appointed attorney appointed by the Wake County District Court Judge, later hired privately by Plaintiff Ronald Reale in case number 10JA xxx-xxx and 10CVD7386 in Wake County, North Carolina and was at all times material, pertinent and relevant hereto. Current mailing address is; 1003 High House Road, Suite 106, Cary, NC 27513. The Defendant was in fact, acting under the authority or color of state law at the time these claims occurred in that as a private attorney he did act personally and individually under the authority or color of state law when he acted in concert with local officials, including but not limited to, WCHS social workers, their supervisors, county attorneys and others causing harm to the Plaintiffs in effecting the deprivation of rights, Dennis v. Sparks (1980). Attorney immunity for intentional harm to one’s client (Ronald Reale) was never so protected at common law, Tower v. Glover (1984).
|Name||Steve Lawrence Combs|
|Address||140 Preston Executive Dr.|
VIOLATION OF THE SIXTH AMENDMENT – Assistance of Counsel, and THE FOURTEENTH AMENDMENT – Both the Due Process Clause and the Equal Protection Clause
Steve Combs was court appointed by Judge Monica Bousman and dismissed on the same day as I was declared “not indigent” by the court. I later agreed to a consultation and ultimately hired Steve Combs as my private attorney. In total Mr. Combs was paid $3,150 in cash. I asked for a copy of an updated billing record on multiple occasions and have not received one to this day. Mr. Combs never had the need to ask for payments as I always made periodic payments according to my estimates of our time spent in court and our other meetings. When I terminated the services of Mr. Combs on November 28, 2010 I requested that he provide me a copy of the entire court file. We exchanged documents and signatures on November 30, 2010.
Steve Combs’ services could easily be referred to as less than incompetent. At the start of this process, while reviewing the file, Mr. Combs immediately had questions about the validity of the DVPO as he noted that there was no service of process in the file. In fact, he also noted that there was no request for a DVPO (50B) in the file either. As he pursued this conversation he introduced the possibility to me that the protective order may have some serious flaws and that fact could have an impact on this case. I agreed, and the conversation in general was that of moving in the direction of attacking the protective order itself. Mr. Combs did expressed concern as to possibly upsetting the Judge who issued the protective order. Why should that type of concern be factored into a demand for Justice? The most egregious act with regard to the DVPO is that he ultimately did nothing.
Mr. Combs did seem a bit ambivalent and somewhat concerned as to how to proceed at times. He often seemed to lack in confidence, even his understanding of the law was questionable at best, most of the time with Mr. Combs. At one point on October 29, 2010 after Mr. Combs received a copy of my psychological evaluation that was conducted on October 6, 2010, he declined to give me a copy. He stated that WCHS would not allow him to provide me with a copy but they would allow me to read the evaluation at Mr. Comb’s office. Preposterous! Anyhow, I played along for now and read the document at Mr. Comb’s office on November 1, 2010. Mr. Combs went back and forth about whether or not to provide a copy to me. In the meantime I was the one (doing Mr. Combs job) jumping through hoops and sending strongly worded emails to WCHS while demanding a copy of my own psychological evaluation. I even withdrew my “consent to release all information” as a condition of being provided with a copy of my own evaluation.
At some point along the way (after adjudication) it was clear that Mr. Combs was a pawn in this completely fractured family court system and that he was complicit, in that he honestly could not care less about anything but continuing to recommend that I comply with everything “even though it might not represent the truth.” He was simply a hand-holder and that’s just what the court wanted. He was buried in work (appointed from the court) and was even late for court on several occasions. He seemed known for that at the courthouse.
I continued to research on my own how to properly attack the DVPO. I interview 4-5 attorneys and continued to gather information. Ultimately in early November I began to suggest to Mr. Combs that I may need to find a different attorney, especially to go after the unlawful DVPO which Mr. Combs had since declined to involve himself with. On November 22, 2010 Steve Combs sent me an email stating the following; “As discussed previously, litigation is not my specialty. If you are interested in someone who has more of a litigation background, I have two recommendations of attorneys that practice in courtroom 4C. If you do decide to switch, I will help transition the case.” Not a litigator? What are you then? Oh yeah, a hand-holder just as I suspected. This is information I could have used maybe “PRIOR TO ADJUDICATION!”
By November 28, 2010 I informed Mr. Combs that he and decided to release him as my attorney of record. When the two exchanged signatures and documents on November 30, 2010 I was surprised that not all the papers were in order. The entire CPS file was missing. As it turns out, Mr. Combs did not even obtain a copy of the CPS file. This was arguably the single most important document in this case and he never obtained a copy. This proof positive that he never intended to put forth his “best” effort on behalf of his client and that he was simply a part of the conspiracy seemingly along for the ride and in this for the “EASY MONEY.” The most interesting thing is that there was a copy of the Psychological Evaluation in the file. Finally! Although, more proof that he was involved in a conspiracy against his own client with the likes of WCHS, its agents, GAL, and the other attorneys and court officials. There was no need to keep the document from me now that he was being released. Attorney immunity for intentional harm to one’s client (Ronald Reale) was never so protected at common law, Tower v. Glover (1984).
Section 1983 imposes liability on anyone who, under color of state law, deprives a person of any rights, privileges, or immunities secured by the Constitution and laws. K & A Radiologic Tech. Servs., Inc. v. Commissioner of the Dep’t of Health, 189 F.3d 273, 280 (2nd Cir 1999) (quoting Blessing v. Freestone, 520 U.S. 329, 340 !997). “[T]he core purpose of § 1983 is ‘to provide compensatory relief to those deprived of their federal rights by state actors’.” Hardy v. New York City Health & Hosps. Corp., 164 F.3d 789, 795 (2nd Cir. 1999) (quoting Felder v. Casey, 487 U.S. 131, 141 (1988)). “The traditional definition of acting under color of state law requires that the defendant in a § 1983 action have exercised power possessed by virtue of state law and made possible only because the wrongdoer is clothed with the authority of state law.” Id. (quoting, inter alia, West v. Atkins, 487 U.S. 42, 49 (1988)) (other citations and internal quotation marks omitted)