STATE OF MAINE SUPERIOR COURT CUMBERLAND, SS. CIVIL ACTION DOCKET NO. DANIEL G. LILLEY LAW OFFICES, P.A.,) a professional association with a principal) Cp 87 place of business in Portland, County of) MATa Cumberland, State of Maine, ) "s Plaintiff fp » ) oa, y. ) COMPLAINTS. _ ) Ma ; oh Cumberland, State of Maine, ) Defendant) NOW COMES Plaintiff, by and through undersigned counsel, and hereby complains against Defendant as follows: 1. Plaintiff Daniel G. Lilley Law Offices, P.A., (“the Law Finn”) is a Maine law firm with a principal place of business in Portland, County of Cumberland, State of Maine. Daniel G. Lilley was the owner of the Law Firm at the time of his death on March 11, 2017. By Order of the Maine Supreme Judicial Court on March 15, 2017 the Law Firma was placed in receivership and John McArdle, Esq. and Amber Tucker, Esq. were appointed co-receivers of the ‘Law Firm, 2. Defendant aOR is a resident of CMIMIND County of Cumberland, State of Maine, and was the Law Fim’s employee and QI until @p was terminated on or about April 7, 2017 for stealing from the Law Firm. During the time that §iijwas employed by the Law Firm, G9 wrote checks tof for monies that @§jJ was not entitled to from the Law Firm. Qi forged the signature of Daniel G. Lilley in doing so. 4, Preliminary investigation has shown the total forged checks that QJ wrote to in 2013 totaled $76,670.65; in 2014, $223,862.04; in 2015, $288,350.00; in 2016, $239,795.80; and in 2017, $15,656.78 (including one check for $3,500.00 which Qi wrote to ind forged Daniel G. Lilley’s signature on February 23, 2017 while Daniel G. Lilley in iine Medical Center and was not able to communicate given his medical condition). The total for all these years is $844,335.27. }was not authorized to write checks to QigggBand keep the monies for @jgpwn personal benelit 5. @MBMBelso diverted client cash payments to the Law Firm to Qi On December 5, 2016 (ggpreceived $19,600.00 in cash from a Law Firm client and only deposited $14,600.00 of that cash in the Law Firm’s account. gil retained the $5,000 difference for BMD On December 17, 2016 QR received $5,000.00 in cash from a Lew Firm client,BP retained that entire $5,000.00 in cash for Gi On February 27, 2017 jeceived $14,000.00 in cash fiom a Law Firm client. deposited $12,000.00 of the $14,000.00 in cash in the Law Firm account and retained $2,000.00 for QQ The total amount of cash stolen by GBM just for this time period is $12,000.00. BP was not authorized to take cash payments to the Law Firm and keep them forf@jijown personal benefit. 6. The amounts mentioned here were discovered after Daniel G. Lilley’s death and a partial review of the Law Firm's accounts. As of this date additional investigation is being conducted to determine what additional monies QJiBstole from the Law Firm, COUNT Embezzlement 7. Plaintiff repeats and realleges the allegations contained in paragraphs 1 through 6 as if fully set out herein, 8. At current count {MMM embezzled at least $856,335.27 from the Law Firm. (GHW had no right or authority to receive these monies. QP embezzlement caused the Law Firm damages including but not limited to the right and benefit to the monies that guggpstole. RB conduct was intentional, malicious, and outrageous. Wherefore, for the foregoing reasons, Plaintiff respectfully requests this Court enter judgment against (Pin Plaintiff's favor and award Plaintiff damages, including punitive damages, costs and whatever other relief this Court deems just and equitable. COUNT Conversion 9, Plaintiff repeats and reslleges the allegations contained in paragraphs 1 through 8 as if fully set out herein, 10. ‘The Law Firm had the right to the monies that Qi took for QD @phad no tight to receive these monies from the Law Firm. jijnever informed the Law Firm that (BB was taking money from the Law Firm. (MMM conduct amounts to conversion of at least $856.335.27. Jconversion caused the Law Firm damages including but not limited to the right and benefit to the monies that QGgstole. QE conduct was intentional, malicious, and outrageous. WHEREFORE, for the foregoing reasons, Plaintiff respectfully requests this Court enter judgment against MQ in Plaintiff's favor and award Plaintiff damages, including punitive damages, costs and whatever other relief this Court deems just and equitable