IN THE COURT OF SPECIAL APPEALS OF MARYLAND September Term, 2014 No, 719 STEPHEN D. CHAMBERLAIN Appellant vy. JUDITH C. CHAMBERLAIN Appellee APPEAL FROM THE CIRCUIT COURT FOR ANNE ARUNDEL COUNTY (The Honorable Paul F. Harris, Ir., Presiding) APPELLEE'S BRIEF M. Evelyn Spurgin HILLMAN, BROWN & DARROW, P.A. 221 Duke of Gloucester Street Annapolis, Maryland 21401-2500 410-263-3131, (Fax) 410-269-7912 Attorney for AppelleeTABLE OF CONTENTS STATEMENT OF THE CASE QUESTIONS PRESENTED 2,3 STATEMENT OF THE FACTS 3 ARGUMENTS, 5,7 1, THIS COURT SHOULD DISMISS THIS APPEAL 5 BECAUSE THERE IS NO EVIDENCE ON THE RECORD TO CONTRADICT THE CONCLUSION THAT BOTH PARTIES VOLUNTARILY AGREED TO. THE TERMS OF THE ORDER. 2 ASSUMING ARGUENDO THAT THE FATHER: 7 APPEALED THE TRIAL COURT’S ORDER DENYING THE MOTION REGARDING DECLARATION OF MISTRIAL AND REQUEST FOR SCHEDULING OF EXPEDITED MERITS HEARING, THE TRIAL COURT'S DENIAL OF THE MOTION IS SUPPORTED BY SUBSTANTIAL EVIDENCE. CONCLUSION CERTIFICATE OF SERVICETABLE OF CITATIONS Cases Cited Page Barnes v, Barnes 5 181 Md, App. 290, 956 A.2d 770 (2008) Dougherty v, Mercantile-Safe Deposit & Trust Co. . 5 282 Md. 617, 621, 387 A.2d 244, 247 (1978) Fuge v. Fuge. 5 146 Md. App., 806 A.2d 716, 738 (2002) Smith v. Luber ... 6 165 Md. App. 458, 885 A.2d 994 (2005) Suter v. Stuckey . 6 402 Ma. 211, 224-25, 935 A.2d 731 (2007) Statutes Cited ‘Ma, Rule 8-131(¢) 5 APPENDIX Letter from Stephen D, Chamberlain to Samuel J. Brown dated April 28, 2014 Apx. 1 Stephen D. Chamberlain’s Proposed Consent Order ... Apx. 4 Notice of Appeal ... Apx. 9 -ii-IN THE COURT OF SPECIAL APPEALS OF MARYLAND. September Term, 2014 No. 719 STEPHEN D. CHAMBERLAIN Appellant vy. JUDITH C, CHAMBERLAIN Appellee APPEAL FROM THE CIRCUIT COURT FOR ANNE ARUNDEL COUNTY, (The Honorable Paul F. Harris, Jr., Presiding) APPE ?S BRIEF STATEMENT OF THE CASE ‘The Appellee, Judith C. Chamberlain, (hereinafter “the Mother”) does not accept the Appellant’s Statement of the Case and, therefore, states as follows: ‘The Mother filed a Complaint to Enforce Marital Settlement Agreement and Consent Order of August 31, 2011, and for Declaratory Judgment on September 19, 2013. ‘The Mother was seeking to enforce a provision of the parties’ Marital Settlement ‘Agreement and a later Consent Order regarding payment for the parties’ child’s college education, (E 10, 22). The Appellant (the Father), through counsel, filed an Answer on October 18, 2013. (E 10, 27)The matter was set for a merits hearing for April 18, 2014, (E 17) On April 14, 2014, the Mother filed a Request for Voluntary Dismissal because an additional request to modify child support had been filed, the minor child had applied for college and a payment determination could be made when the actual tuition bills arrived, (B 112) ‘The Father filed a response to the request for voluntary dismissal, stating that he consented, conditioned upon payment of his attorneys? fees. (E 115) At the beginning of the merit’s heating on April 18, 2014, the Wife withdrew her request for dismissal. (E 182) The Father objected to the withdrawal of the request for dismissal, but the Trial Court decided to proceed with the merits hearing. (B 182-91) The Father also argued, prior to any testimony, that the parties’ child, whose college expenses were the subject of the Motion, was a third party beneficiary and should be joined as a party, (E 195) The Trial Court denied the request. (E211) Testimony began, but before the completion of the evidence, the ‘Trial Court asked to speak with counsel in chambers. (E 259) The parties reached an agreement that included all outstanding issues and was placed on the record. Both parties and their son, John, were questioned about their understanding of the agreement and their consent. (E259 - 77) Following the hearing, but before the Order was signed, the Father’s lawyer filed a Motion to strike his appearance. (E 17) The Father sent counsel for the Mother (and a copy to the Court) a letter dated April 28, 2014, with a proposed Order. (Apx. 1) He also filed a Motion to Extend Deadline for Submission of Consent Order by ten days. (E 18) ‘The Father then filed multiple Motions pro se. (E 19-20), including a Motion Requesting Declaration of Mistrial and Request for Scheduling of Expedited Merits Hearing. (E 129) ‘The Court denied the Motion Requesting Declaration of Mistrial (E175) and signed the Consent Order on June 5, 2014. (E 176) The Father filed a timely appeal (E 21), although the Notice of Appeal does not specify which Orders were being appealed. UESTIONS PRESEN’ 1. Should this Court dismiss this appeal because there is no evidence on the record to contradict the conclusion that both parties voluntarily agreed to the terms of the Order?2. Assuming arguendo the Father appealed the Trial Court’s Order denying the Motion Regarding Declaration of Mistrial and Request for Scheduling of Expedited Merits Heating, is the Court’s denial of the Motion supported by substantial evidence? STATEMENT OF FACTS The parties were divorced in May 2009 after executing a Marital Settlement ‘Agreement which had as one of its provisions that the Father “shall pay the costs of tuition, room and board, books, registration fees and reasonable application fees incident to providing each [of the parties’] children with an undergraduate college education for four consecutive years of college.” ‘The Agreement also stated that “The selection of which college or university each child shall attend shall be made by Husband, Wife and the child, prior to the application and prior to enrollment.” In addition, in August 2011, a Consent Order was entered that affirmed the Father’s obligation to pay for undergraduate college expenses, (E 22-23) ‘The Wife filed her Complaint to Enforce Marital Settlement Agreement and Consent Order following a dispute over where the parties” youngest child, John, could apply for college. The Mother also requested the Trial Court to “enforce the provisions of the parties’ Marital Settlement Agreement and August 31, 2011, Consent Order regarding college expenses.” (E 24) As stated above, following some procedural issues regarding John and whether the Mother's Complaint had been dismissed, the ‘Trial Court began taking testimony. Following some testimony and the attorneys’ conferences with the Court and the parties, the parties reached an agreement that was placed on the record by the Father’s lawyer. ‘The parties agreed that the Father will pay up to $14,000.00 per year toward John’s college expenses after scholarships and payment of $9,000.00 per year by the Mother. ‘The proceeding was dismissed with prejudice, as well as the pending child support case, and both parties waived any claims for attorneys’ fees. (E 259-266) Both parties and their son John were questioned regarding their understanding and consent to the agreement. Specifically, the Father was questioned as follows: MR, SCHAEFFER: Yes, sir. Could you please stand up, Mr, Chamberlain? Mr. Chamberlain, you've heard my recitation of the terms ofsettlement today, you're not under the influence of any alcohol or drugs or anything that might affect your anything that might affect your reasonable judgment, correct? MR. STEPHEN CHAMBERLAIN: No. MR. SCHAEFFER: Can you confirm to the Court that you have heard and understood the terms of the agreement? MR. STEPHEN CHAMBERLAIN: Yes. MR. SCHAEFFER: And can you confirm that you want the Court to incorporate the terms of the agreement into a consent order that will be enforceable by the Court in the event of a breach by either of you? MR. STEPHEN CHAMBERLAIN: Yes. MR. SCHAEFFER: Do you believe the terms under the circumstances, to be fair and reasonable? MR. STEPHEN CHAMBERLAIN: Yes. MR. SCHAEFFER: Do you have any questions for me regarding the terms and conditions at this time? MR. STEPHEN CHAMBERLAIN: No. MR. SCHAERFER: And have you been generally satisfied with my services as your counsel throughout these proceedings? MR. STEPHEN CHAMBERLAIN: Yes, sir. (E 267-68) ‘The Court proceeded to find that the Father entered “into the consent order freely and voluntarily and after being properly advised of his rights.” (E268) Furthermore, even though he was not a party, the Court questioned John Chamberlain, asking if he had any questions, if he understood and agreed with the agreement his parents had made, John agreed and stated he understood he was waiving his right to bring an independent action. (E 271-72) The Trial Court signed the Consent Order onJune 5, 2014, which reflected the agreement the parties and their son, John, consented to on the record. (E 176) NDARD OF REVIEW Maryland Rule 8-131 (¢) governs non-jury cases: “When an action has been tried without a jury, the appellate court will review the case on both the law and the evidence, It will not set aside the judgment of the trial court on the evidence unless clearly erroneous, and will give due regard to the opportunity of the trial court to judge the credibility of the witnesses.” The Appellate Courts have explained the standard of review further. For example, “fiJf there is substantial evidence to support the Trial Court’s factual conclusion, that finding must be reviewed in the light most favorable to the prevailing party below and the Appellate Court should accept that conclusion,” Dougherty v. Mercantile-Safe Deposit & Trust Co., 282 Md. 617, 621, 387 A.2d 244, 247 (1978). In addition, [i]f there is any competent evidence to support the factual findings below, those findings cannot be held to be clearly erroneous.” Fuge v. Fuge, 146 Md. App., 806 A.2d 716, 738 (2002). ARGUMENTS 1. THIS COURT SHOULD DISMISS THIS APPEAL BECAUSE THERE IS NO EVIDENCE ON THE RECORD TO CONTRADICT THE CONCLUSION THAT BOTH PARTIES VOLUNTARILY AGREED TO THE TERMS OF THE ORDER. Maryland law has long been settled that if there is evidence that both parties voluntarily agreed to the terms of a Consent Order and the language in the Order reflects the language of the agreement the parties put on the record in open Court, there is no right to appeal and any appeal should be dismissed. Barnes v. Barnes, 181 Md. App. 290, 956 A.2d 770 (2008). In Barnes, this Court explained in detail the rationale behind why consent orders are not appealable: ‘The rule that there is no right to appeal from a consent decree is a subset of the broader principles underlying the right to appeal. ‘The availability of appeal is limited to parties who are aggrieved by the final judgment. A party cannot be aggrieved by a judgment to which he or she acquiesced . , . The rational for this general rule “has been variously 5characterized as an ‘estoppel’, a ‘waiver’ of the right to appeal, an ‘acceptance of benefits? of the court determination creating ‘mootness?, and an ‘acquiescence’ in the judgment.” Id. at 781 (quoting Suter v. Stuckey, 402 Md. 211, 224-25, 935 A.2d 731 (2007) The parties placed a Consent Order on the record and were questioned by their lawyers about their understanding and consent to the Agreement. ‘The Court made a factual finding that the parties entered into the Agreement voluntarily and issued an Order that, to a large extent, mirrored the proposed Consent Order submitted by the Father, The appeal should, therefore, be dismissed, The Father’s various arguments regarding why the Consent Order should be set aside are specious. ‘The Court had jurisdiction to hear the case. ‘The issues before the Court were not moot. While John may have already applied to the college his father opposed, the Mother also requested that the Trial Court enforce the provisions of the ‘Marital Settlement Agreement and August 31, 2011, Consent Order regarding college expenses. (B 24) After the Mother chose to withdraw her Request for Voluntaty Dismissal because the Father would only consent with certain conditions imposed, the Court had the authority and right to proceed. Furthermore, the Father’s decision to enter into a Consent Agreement followed the Court’s decision to proceed. ‘The Father’s statement that the Court should not have proceeded because John was not joined as a necessary party to the hearing is also without merit. Even if the Court should have joined him as a party, once an Agreement was reached, John was specifically questioned about his understanding and consent to the Agreement. The Mother does not concur that the Court’s initial decision was erroneous, but assuming arguendo it was, it was also rendered completely harmless because of John’s consent to the Agreement and waiver of any right to pursue his own action. ‘The Mother acknowledges that if the written Order did not comport with the Agreement placed on the record, this Court could remand the case to correct the language. See Smith v. Luber, 165 Md. App. 458, 885 A.2d 994 (2005). The Consent Order the Court signed does not contain the precise language the parties acknowledged 6on the record, but, instead, contains additional language that had been proposed by the Father. Instead of stating that the Father’s obligation was up to $14,000.00 a year after Mother’s payment of $9,000.00 and application of any scholarships/grants that do not need to be paid back to lender or grantor, the Court broke the payments down by semester ($4,500.00 payment by Mother and up to $7,000.00 payment by Father per semester). (E 176-77) This language is very similar to the language proposed by the Father in his Consent Order and before he started barraging the Court with Motions. (Apx. 4) This Court should dismiss this Appeal because the Consent Order was entered into ‘voluntarily after consultation with able counsel. Contrary to the Father’s request, this Court cannot make a new factual finding that the Father entered into the Agreement under duress and after poor advice from his counsel. The Father has no right under Maryland law to appeal the Consent Order and it, therefore, should be dismissed. 2 ASSUMING ARGUENDO THAT THE FATHER APPEALED THE TRIAL COURT’S ORDER DENYING THE MOTION REGARDING DECLARATION OF MISTRIAL AND REQUEST FOR SCHEDULING OF EXPEDITED MERITS HEARING, THE TRIAL COURT’S DENIAL OF THE MOTION IS SUPPORTED BY SUBSTANTIAL EVIDENCE. ‘The Father's Notice of Appeal docs not specify what Order or Orders he was appealing, although, based on his Brief, it is evident he has had a change of heart regarding the Consent Agreement that he entered into that became the Consent Order. ‘The uncertaimy, however, about the actual Orders addressed in his appeal is irrelevant because the Court’s denial of the Motion Regarding Declaration of Mistrial was not clearly erroneous and was supported by the evidence. (Apx. 9) In his Motion Regarding Declaration of Mistrial, filed after he submitted a proposed Consent Order and requested an extension of time within which to submit the Order, the Father for the first time asserted that he entered into the Agreement under duress, He also raised the same arguments regarding jurisdiction and John’s participation that he did in his Brief before this Court. The Father’s assertions regarding duress, both in this Motion and in his Brief, are based upon bald allegations that are not part of the 7record and upon his contentions regarding what his attorney advised him. If the Father’s decision was based upon his lawyer’s advice, his remedy is not setting aside the Agreement. More importantly, the Trial Court made a factual finding that there was no basis (0 set aside the Agreement after hearing and observing the Father, who was represented by able counsel. ‘The Trial Court specifically found that the Father, as well as the Mother, entered into the Agreement freely and voluntarily after being properly advised of their rights. This Court cannot substitute its judgment for the Trial Court and make a new factual finding that the Father acted under duress when he consented to the Agreement. Further, as stated above, the Trial Court had authority to proceed with the hearing and the parties? son, John, consented fully to it. ‘The Trial Court’s decision was not clearly erroneous and should be affirmed. CONCLUSION ‘This Court should dismiss this Appeal or, in the altemative, affirm the Consent Order and Denial of the Motion for Declaration of Mistrial. STATEMENT OF FONT USE This Brief has been prepared using TIMES NEW ROMAN pt. 13 font and has not been altered from the computer generated spacing presets. untuk ARAL pr M, Evelyn Spurgin f sotilawakty HILLMAN, BROWN & DARROW, P.A. 221 Duke of Gloucester Street Annapolis, Maryland 21401-2500 410-263-3131, (Fax) 410-269-7912 Attomey for AppelleeCERTIFICATE OF SERVICE I hereby certify that on this AQ” day of January, 2015, a copy of the foregoing sil Brief was mailed, first class seis prepaid, to Stephen D. Chamberlain, M. Evelyn SpurgiSamuel J. Brown, Esquire « Hillman, Brown & Datrow, B.A, 221 Duke of Gloucester Street \ Annapolis, MD 21404 April 28, 2014 Mr. Brown, ‘Your letter dated April 23, 2014 to my former attomey, Mr. Kevin Schaeffer, was predictable. As has been the case for the last 4 years of litigation, you accuse with no facts, and intentionally misrepresent the truth of the matter You stated “We had agreed before Judge Harris that we would prepare the initial draft of the Conserit Order and yet, for some reason, your client has insisted on having you prepare your own Order, once again increasing fees and eteating unnecessary issues in what should be a very simple matter." Mr, Schaeffer sent an initial draft of the Consent Order to you on the same day of the trial, without my knowledge, review or consent, while I was en route from Maryland to Colorado. You arc vory much mistaken if you believe you can make false accusations, willfully misrepresent facts, slander the character and integrity of your opponent in a calculated effort to create a faise impression for the Coutt, or to fnterfore with the attomey-client relationship of your opponent with impunity, Quite frankly, your conduct has been, and continues fo be, unprofessional, unethical, dishonorable, and provides absolute justification for the general public's increasing mistrust in, and disdain for, the legal profession. 0/200'd Oe — LEBEL bLozs/ezro0 Ap p x, ! GAL PSB¢C091 :wolyZloseoo'd oze# Thave attached a draft of the Consent Order which eliminates the superfluous verbiage you included in your draft, places into words the oral agreements reached during the hearing of April 18, 2014, and provides specificity to the application of the annual financial obligations which were clearly delineated on the same date, While I am sure it helps your client achieve her goals to have the entire financial obligation for the 2014-2015 academic year paid “up front”, I ‘would never have agreed to the settlement offer if it was clear that my financial obligation for “the academic year” was needed in August and not payable on a somester by semester basis. If the annual cost of college were to be $35,000, the university would have no expectation that all $35,000 would be paid “up front”, ut rather it would be divided into two payments, $o it is with the proposed agreement for mo to pay up to $14,000.00 per academic year, In addition, having closely reviewed my financial records, level of debt and income prior to April 18, and having knowledge that I have just spent over $32,000.00 in legal fees to defend against this vexatious litigation leaves no doubt that by claiming we had an agreement whereby I would pay all $14,000.00 in August, your intent is to create further divisiveness rather than worlc in good faith. to achieve our common goal of ending this contentious dispute and mitigating the need for future litigation over the matter of my son’s college education, All paragraphs of the Consent Ofder attached are based on the verbal agreements reached in front of Judge Hartis on April 18, 2014, and provide clarity to the issues raised by both patties in order to ensure there are no misunderstandings on the final resolution of the issue of John’s college expenses. oa th ploz/aZ/+o Rex. 661 pSege091:wOlyTwill be filing-a Motion to Bxtend the Deadline for Submission of Consent Order today and will forward you a copy, as well as provide Judge Elatris a copy so he is aware that there is a disagreement as to the language that needs resolution. Ifyou feel the need to edit or modify any of the language of the Consent Order Drafi, please make your changes apparent. Sea . Stephen D, Chamberlain Pro Se Litigant ZL0/vO0'd SZE# SLL Phozrez/Po Mp x. 3 66Lpsese091 : HossIN THE CIRCUIT COURT OF MARYLAND FOR ANNE ARUNDEL COUNTY JUDITH C. CHAMBERLAIN ‘ Plaintiff * v. STEPHEN D. CHAMBERLAIN * Defendant 7 , Case No, 02-C-09-13690 Pesaro cea ee wee we EE ee Consent Order ‘The parties appeared for a merits hearing on Plaintiff's Complaint to Bnforce Marital Settlement Agreement and Consent Order of August 31, 2011, and for Declaratory Judgement before the Honorable Paul F. Hanis, Jr, on April 18, 2014, During this hearing, the parties reached an agreement resolving all issues pertaining to this action, which is memorialized below. WHEREFORE, it is this__ day of Aptil, 2014, by the Circuit Couet for Anne Arundel County, ORDERED, that the Defendant, Stephen D. Chamberlain shall pay up to a maximum of $14,000.00 per academic school year as his total obligation towards John Chamberlain’s college expenses, defined as college tuition, room and board, books and registration fee for four consecutive years. The caloulation of the Defendant's obligation will be made cach Fall and Spring semester as follows: The 014 Z10/500'd sze# SLL pLozreer¥o Apy 4 eelyseseog!:210/900"d 92e# SLL bLoz/ez/¢0 sum of tuition, room and board, books, and registration’fee minus $4,500.00 (which is oné half of the Plaintifi’s $9,000 annual redirection of contractual support paid by the Defendant for John Chamberlain towards the college expenses defined above as set forth in the parties’ Coisont Order of August 31, 2011), minus any and all scholarships awarded to John Chamberlain or grants to him which do not require repayment, will equal the balance due, of which the Defendant is obligated to pay up to $7,000.00 each Fall semester, and if the balance due in the Spring semester is more than $7,000,00, the Deféndant will pay at least $7,000.00, but no more than a total of $14,000.00 each academic yeat. By way of examplo, if John Chamberlain’s tuition, room and board, books, and registration fee for the 2014 Fall Semester at Virginia Tech equals $18,000.00, the Plaintiff shall be responsible for $4,500.00 leaving a balance due of $13,500.00, of which the Defendant shall be responsible for $7,000.00. However, if John Chamberlain receives a scholarship for $8,000 that semester, the balance due would be $5,500.00, which the Defendant would pay. If the balance due in the Spring semester of that academic year was $9,000.00, the Defendant would be obligated to pay $8,500.00 (for a total of $14,000 that academic yoar). Student loans, including Federal student aid, gifts ftom third parties, or any other form of financial assistance which requires repayment, taken by or given to John Chamberlain, must not be deducted from the parties obligations and the repayment Ap x 7 661 pS6se091 :wo14zhO/Lo0'd 9ze# — 9k #L pLozsazry0 AY x b 661 pS6SE091:m04 4 of such loans, gifts, or any other form of financial aid will be the sole responsibility of John Chamberlain; and it is further ORDERED, that’ Paragraph 8 of the Marital Settlement Agreement is declared null and void, and is replaced with obligations as sct forth within this Consent Order; and it is further ORDERED, that any obligation placed on John Chamberlain or on the Defendant with regard to loans taken by John Chamberlain as set forth in the parties’ Consent Order of August 31, 2011 is roplaced by the terms and conditions of this Consent Oitder; and it is further ORDERED, that John Chamberlain must gather all invoices clearly showing each semester’s tuition, room and boatd, books, xégistration feo, and scholarships or grants which do not have to be repaid, and provide these invoices to the Defendant at one. time each semester. This may be accomplished via the mail, of by scanning copies of the invoices and providing them via email. All invoices must be in the form of a university document or valid receipt or lease. No invoice can be self-generated. The Defendant will provide a check within 10 days of receipt of these invoices cach somester, paid directly to John Chamberlain, who will apply those funds dircetly to the college expenses stipulated within this Order. All three parties to the agreement shall immediately notify each of the other patties of any change of mailing address or email address immediately upon such a change; and it is fartherORDERED, that each party shall be resporisible for their own attornoy’s fees and costs, that each party waives any and all claims for attomey’s fees or reimbursement for attomney’s fees or suit costs, including any claim pursuant to Maryland Rule 1-341, incurred in this matter; and it is further ORDERED, that John Chamberlain has confirmed his understanding of the terms of this Consent Order and has affirmed his willingness to be bound. hereunder; and it is further ORDERED, that all remaining provisions in the parties’ Marital Settlement Agreement and Consent Order of August 31, 2011 shall remain in full force and effect, except as specifically modified herein; and it is further ORDERED, that the Plaintiff hereby dismisses her Motion for Modification of Child Support with prejudice and that the hearing currently set for May 29, 2014, is hereby cancelled; and itis further ORDERED, that the heavings set before the court on all existing pleadings or motions in this action are hereby CANCELLED; and it is further ORDERED, that seeing there are no outstanding outstanding court costs none are herchy assessed, Judge 0) Z10/900"d 9zee 91:41 $ozrazr+o APY.7 seLys0sc09}:u0s4CONSENTED TO: Judith C, Chamberlain, on behalf of John Chamberlain as next friend Samuel J. Brown, ‘Atiomey for Plaintift Stephen D; Chamberlain Pro Se Litigant ~P> 4.9 210/600'd 9ze# 9b HL thozrezsyo ' 66LbS6SE091 "05IN THE CIRCUIT COURT FOR FOR ANNE ARUNDEL COUNTY, MARYLAND JUDITH C. CHAMBERLAIN: Plaintiff, y. Case No. 02-C-09-139690 STEPHEN D. CHAMBERLAIN Defendant. NOTICE OF APPEAL Stephen D. Chamberlain, Pro Se Litigant, notes an appeal to the Court of Special Appeals in the above-captioned action. Stephen D, Chamberlain Pro Se Litigant CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that on this 20th day of June, 2014, a copy of the foregoing Notice of Appeal was served, by certified mail, on: Samuel J. Brown and Marietta B. ‘Warren, 221 Duke of Gloucester Street, Annapolis MD, 21401, Attorneys for Plaintiff. SBeenna Stephen D. Chamberlain A px. 4