1. DEBORAH DICKSON DAVIS
910 AZALEA HILL DRIVE (912) 257-6253
GREENVILLE, SC 29607 DLDICKSON@SAVANNAHLAWSCHOOL.ORG
WRITING SAMPLE
The attached writing sample is a motion and a sample order I researched and prepared for an
attorney at a personal injury firm. The names and facts have been changed to protect the confidentiality
of all parties involved. This case dealt with a no-asset case in a Chapter 7 bankruptcy, and the Debtor
received a post-petition settlement award from the manufacturer of a defective hip implant. The hip
implant surgery occurred pre-petition. The Trustee was attempting to claim the Debtor’s settlement as a
pre-petition asset because the surgery occurred pre-petition; hence, the settlement award was sufficiently
rooted back to the Debtor’s prepetition assets. See Segal v. Rochelle, 382 U.S. 375, 375-377 (1966). The
legal issue pivoted on whether the Debtor’s asset was a pre-petition or post-petition asset.
The underlying issue was whether the sufficiently-rooted-back test applies to personal injury
causes of action (i.e., involuntary plaintiffs), as distinguished from contract causes of action (i.e.,
voluntary plaintiffs). Like a play within a play, the answer lies is the state’s substantive law underlying
the property interest in a cause of action as to when the cause of action accrues.
The property interest in a cause of action depends on how the state defines the accrual of the
necessary elements to a cause of action, like all the pieces of a stopwatch coming together to form a
stopwatch. The moment a cause of action accrues to define one’s property interest is distinguishable
from when a cause of action accrues under the statute of limitations—under the discovery rule. That is,
the statute of limitations is merely the second hand on the stopwatch.
The elements of a cause of action must be present before a debtor may file a claim for personal
injury. The element of injury was not present until post-petition. This temporal progression of when a
case accrues is fatal to the Trustee’s claim.

2. 1
IN THE UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF INDIANA
METROPOLIS DIVISION
IN RE:
BROKE D. OLDMAN, CASE NO. 99-99-99999-DLD-9
DEBTOR.
DEBTOR’S MOTION TO DISMISS CASE
COMES NOW, the Debtor, BROKE D. OLDMAN (Debtor), through the undersigned counsel,
pursuant to FED. R. BANKR. P. 7041, and respectfully moves the court to dismiss the claims against the
Debtor for fraud, misrepresentation, or other misconduct alleged by GREEDY B. ALDMAN,
TRUSTEE (Trustee). 11 U.S.C. §§ 523(a)(2)(A)-(B), 727(a)(4) (West 2015); FED. R. BANKR. P. 7001;
FED. R. CIV. P. 60(b); see In re Midkiff, 342 F.3d 1194, 1197-1202 (10th Cir. 2003); In re Fosco, 289
B.R. 78, 94 (Bankr. N.D. Ill. 2002); In re Baker, 205 B.R. 125, 130-34 (Bankr. N.D. Ill. 1997); In re
Gledhill, 76 F.3d 1070, 1078 (10th Cir. 1996). The Trustee failed to plead with particularity in the
Trustee’s claims for fraud, misrepresentation, or other misconduct. Such failure is fatal to the Trustee’s
allegations from both a procedural and substantive posture:
STATEMENT OF FACTS
1.
The Debtor filed a petition for relief under Chapter 7 of Title 11 under the U.S. Bankruptcy
Code on October 15, 2009. 11 U.S.C. §§ 701-784 (West 2015). The Debtor had no cause of action that
commenced against any other entity prior to discharge. The Debtor received a discharge on July 15,
2010. See Exhibit A.

3. 2
2.
All of the Debtor’s post-operative follow up appointments with the Debtor’s doctor showed
clearly that the Debtor showed no abnormal results or effects from the hip replacement on June 15, 2009
(Hip Implant). See Exhibit B.
3.
The Debtor did not suffer any damage from the Hip Implant until 2013. On June 15, 2013, the
Debtor received a second hip replacement surgery to correct the first surgery. Shortly thereafter, the
Debtor suffered a cardiac arrest on June 30, 2013. Since then, the Debtor was discharged, and the Debtor
now wears a life vest daily. On December 15, 2013, the Debtor filed a suit for a personal injury claim
against Sloppy Hip Manufacturer, Inc. (Sloppy). On September 15, 2014, the undersigned counsel
resolved the Debtor’s claim for $250,000.00 (Award). See Exhibit C.
4.
On October 15, 2014, the undersigned counsel sent correspondence to the Trustee to resolve any
possible issues concerning the Debtor’s former bankruptcy, but, to no avail. The Trustee willfully
proceeded with this claim, possessing the full knowledge that no injury manifested from the Hip Implant
until well after the Debtor’s discharge, which is further evidenced by the Trustee’s letter dated as of
January 15, 2014. See Exhibit D.
LAW
5.
The Trustee must plead fraud, misrepresentation, or other misconduct with particularity. See 11
U.S.C. § 1330 (West 2015); FED. R. BANKR. P. 7009; FED. R. CIV. P. 9(b); Ashcroft v. Iqbal, 556 U.S.
662, 678 (2009); Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007); In re Fosco, 289 B.R. at 85-86;
In re Coastal Plains, Inc., 179 F.3d 197, 210 (5th Cir. 1999). Additionally, the Trustee must allege

4. 3
specificity in the facts that track the elements in a cause of action to merit a claim for fraud,
misrepresentation, or other misconduct under the Federal Bankruptcy Code. 11 U.S.C. § 727(a)(4) (West
2015); In re Jairath, 259 B.R. 308, 313-17 (Bankr. N.D. Ill. 2001) (pre-petition fraud under 11 U.S.C. §
523(a)(2)); In re Baker, 205 B.R. at 130-34 (post-petition fraud under 11 U.S.C. § 727). The Trustee
fails to cite relevant case law in a Chapter 7 bankruptcy that involves the Debtor’s legal interest in a
post-petition personal injury cause of action, or include any references to any statutes in the motions set
forth. Tyler v. DH Capital Mgmt., Inc., 736 F.3d 455, 463 (6th Cir. 2013); but see In re Holstein, 321
B.R. 229, 233-38 (Bankr. N.D. Ill. 2005); Raines v. Chenoweth, No. 1:03CV1289-JDT-TAB, 2005 WL
1115804, at *3 (S.D. Ind. 2005) (extending holding for In re Holstein, 321 B.R. 229 (Bankr. N.D. Ill.
2005), to Indiana); see also Exhibit D.
6.
First, the Trustee has impermissibly raised a collateral attack by alleging pre-petition fraud or
misrepresentation to circumvent the statute of limitations, which bars the Trustee’s claims to the
Debtor’s pre-petition assets beyond a 1-year-period after the Debtor’s discharge. 11 U.S.C. § 727(e)
(West 2015) (revocation); FED. R. BANKR. P. 9024; FED. R. CIV. P. 60; In re Fosco, 289 B.R. at 85-89,
93-94. The Trustee’s right to recover the Debtor’s post-petition assets is a dispositive issue that turns
upon Indiana’s substantive law, and not federal law. 11 U.S.C. § 541(a)-(c); Segal v. Rochelle, 382 U.S.
375, 375-377 (1966) (excluding exempt property from the sufficiently-rooted-test). Thus, state law
defines the moment a property interest attaches to a cause of action in tort law. Tyler, 736 F.3d at 461.
Only then does federal bankruptcy law pinpoint that moment on a fixed spectrum of time from
discharge, vesting the claim as a pre-petition or post-petition asset. Id.

5. 4
7.
More importantly, the sufficiently-rooted-test does not apply to exempt property in bankruptcy
or to property that is not vested to the Trustee by operation of law. Segal, 382 U.S. at 375, 377; 11
U.S.C. § 541(a)(1) (West 2015) (defining bankruptcy estate property); Id. at § 552(a) (barring
bankruptcy estate from asserting claims to post-petition legal interests); Id. at § 522(c) (barring
bankruptcy estate from seizing compensation for personal injury plaintiff from actual pecuniary loss and
pain and suffering). The Debtor had no intent to defraud, misrepresent, or conceal assets from the
Trustee: No pre-petition asset existed. The Trustee may not assert a claim on a post-petition cause of
action. Cf. Raines, 2005 WL 1115804, at *3; 11 U.S.C. § 552(a) (West 2015).
8.
Second, the Trustee failed to identify the appropriate elements for the Debtor’s cause of action—
and, account for the logical progression in the timing of those elements. In re Holstein, 321 B.R.at 237-
38; In re Fosco, 289 B.R. at 85-86. The Debtor suffered no injury until June 15, 2013. The Debtor’s loss
occurred well after—approximately three years after the Debtor’s discharge. Cf. In re Holstein, 321
B.R.at 236-37. If no injury exists before discharge, then no cause of action exists. Id. at 233-38; see also
In re Kewanee Boiler Corp., 198 B.R. at 529-31. These issues are incurable fatal defects in the Trustee’s
claim to the Sloppy settlement. Id. More than just embarrassing, such behavior is strictly prohibited.
FED. R. CIV. P. 11(b); 11 U.S.C. § 362(k) (West 2015).
9.
State law defines when a property right to a cause of action attaches and accrues, whereas federal
law defines whether that property right vests to bankruptcy assets or the Debtor. Compare In re
Holstein, 321 B.R. at 233-38 (tort law) with Tyler, 736 F.3d at 461 (contract law); In re Ballard, 238
B.R. 610, 618 (Bankr. M.D. La. 1999). The Trustee’s reliance on the sufficiently-rooted-test in Tyler is

6. 5
inapposite because the court did not answer the question of “whether a cause of action, one or more of
whose elements have not been satisfied at time of the petition, may become pre-petition property.” 736
F.3d at 463; see In re Holstein, 321 B.R. at 233-38.
In the case In re Holstein, the court foreclosed this issue. 321 B.R. at 233-38. The court
determined that a Trustee may not stand in the shoes of the Debtor when a cause of action does not
satisfy the elements under state law at the time of petition. Id.; Katz v. Kucej, No. CV065004131S, 2010
WL 2574137, at *2 (Conn. Super. Ct. 2010) (quoting Hirsch v. Arthur Andersen & Co., 72 F.3d 1085,
1093 (2d Cir. 1995)). This distinction is important for Chapter 7 bankruptcy cases because “[t]he nature
and extent of property rights in bankruptcy are determined by the ‘underlying substantive law’ . . . .”
Tyler, 736 F.3d at 461 (citing Raleigh v. Ill. Dep't of Rev., 530 U.S. 15, 20 (2000)).
10.
Indiana law is clear that a plaintiff must have damages to have a cause of action for negligence,
and in particular, physical harm or injury caused by a product in a claim for strict product liability.
Pisciotta v. Old Nat. Bancorp, 499 F.3d 629, 635 (7th Cir. 2007). Under Indiana law, the personal injury
plaintiff must establish the elements of negligence: “‘(1) a duty owed to plaintiff by defendant, (2)
breach of duty by allowing conduct to fall below the applicable standard of care, and (3) a compensable
injury proximately caused by defendant's breach of duty.’” Id. (citing Bader v. Johnson, 732 N.E.2d
1212, 1217 (Ind. 2000)); see also Alli v. Eli Lilly & Co., 854 N.E.2d 372, 379 (Ind. Ct. App. 2006); IC §
34-20-1-1 (West 2015) (product liability); Id. at §§ 34-20-3-1, 34-51-2-1, 34-51-2-3.
11.
In Indiana, the discovery rule determines the moment a cause of action accrues: “when the
plaintiff knew or, in the exercise of ordinary diligence, could have discovered that an injury had been
sustained as a result of the tortious act of another.” Wehling v. Citizens Nat. Bank, 586 N.E.2d 840, 843

7. 6
(Ind. 1992). But, a cause of action depends upon “uniting of at least two elements-injury and damages.”
Burks v. Rushmore, 534 N.E.2d 1101, 1103 (Ind. 1989) (quoting Montgomery v. Crum, 199 Ind. 660,
161 N.E. 251, 258-59 (1928)). Because injury precedes damages, a cause of action for negligence
requires that “the wrongdoer thereby accomplishes an injury to the person of another, for which the law
allows indemnity in the form of damages.” Id.; IC § 34-20-1-1 (West 2015).
A tort-plaintiff must have suffered damages to have a valid cause of action in personal injury: “A
cause of action ‘accrues only when all elements are present: duty, breach[,] and resulting injury or
damage.’” In re Holstein, 321 B.R. at 234-37 (quoting W. Am. Ins. Co. v. Sal E. Lobianco & Son Co., 69
Ill. 2d 126, 129-30, 370 N.E.2d 804, 806 (1977)). For a tort-plaintiff in personal injury litigation, no
cause of action can exist until a tort-plaintiff suffers damages. Id. at 233-38; In re Gullone, 301 B.R.
683, 687 (Bankr. D.N.J. 2003); In re Kewanee Boiler Corp., 198 B.R. 519, 529-31 (Bankr. N.D. Ill.
1996); Burks, 534 N.E.2d at 1103-04.
12.
A tort-plaintiff, such as the Debtor, only has a cause of action when some damage or injury has
manifested. In re Holstein, 321 B.R. at 233-38; In re Gullone, 301 B.R. at 687; Morton v. Merrillville
Toyota, Inc., 562 N.E.2d 781, 785-86 (Ind. Ct. App. 1990). The Debtor’s claim or suit only vests to the
Trustee when a cognizable interest arises prior to discharge. In re Gullone, 301 B.R. at 687; see also In
re Kewanee Boiler Corp., 198 B.R. at 529-31. Here, the Debtor had no damage nor a cause of action
until June 15, 2013. The Debtor’s loss has been well over three years since the Debtor’s discharge. The
Debtor did not have a cause of action prior to discharge because the Debtor did not suffer an injury from
the Hip Implant before then; hence, the Trustee proceeds misguided in this effort. In re Holstein, 321
B.R. at 233-38; see Exhibit B-C.

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13.
Third, after establishing the right to recovery, then the issue of “whether a debtor's interest in
property is property of the [bankruptcy] estate is a question of federal law.” In re Ballard, 238 B.R. at
618. When the Debtor brings a pre-petition cause of action, the legal interest in that cause of action vests
to “the bankruptcy estate, [and] any recovery in the action will accrue to the benefit of the creditors, not
the debtor-plaintiff.” Holiday, 659 N.E.2d at 650-51. In this case, this issue is moot because the cause of
action arose post-petition. Id. In a Chapter 7 bankruptcy, the Debtor has a substantial property interest in
the right of recovery from a personal injury claim, and choses in action in “torts for personal injuries . . .
remain unassignable.” Picadilly, Inc. v. Raikos, 582 N.E.2d 338, 340-45 (Ind. 1991) abrogated by
Liggett v. Young, 877 N.E.2d 178 (Ind. 2007).
14.
Under Indiana law, a debtor-plaintiff must have standing to pursue a cause of action, be a real
party in interest, and file the suit within the two-year statute of limitations for personal injury related to
product liability claims. IND. R. TRIAL P. 17(a)-(b); Hammes v. Brumley, 659 N.E.2d 1021, 1029-30
(Ind. 1995); IC § 34-20-1-1 (West 2015). A real party in interest is a party “who is the true owner of the
right sought to be enforced . . . the person who is entitled to the fruits of the action.” Hammes, 659
N.E.2d at 1025, 1029-30. Standing refers to a plaintiff who “has a personal stake in the outcome of the
lawsuit . . . [and] sustained a direct injury as a result of the allegedly tortious conduct.” Holiday v.
Kinslow, 659 N.E.2d 647, 648-51 (Ind. Ct. App. 1995); Higgins v. Hale, 476 N.E.2d 95, 101 (Ind.
1985); see also In re Holstein, 321 B.R. at 233-38.
15.
Indiana law requires compliance with bankruptcy law that the debtor-plaintiff must: (1) schedule
the pre-petition cause of action as an asset; (2) seek an order from the Trustee to either abandon the

9. 8
claim or dismiss the bankruptcy petition altogether nunc pro tunc; and (3) “even if scheduled, the debtor
is divested of standing to pursue any cause of action and [the] suit must be brought by the trustee . . . .”
Hammes, 659 N.E.2d at 1025, 1026-28. Conversely, as in this case, the Court would not impose these
requirements for post-petition assets because the Sloppy settlement is solely vested to the Debtor as the
injury manifested well after discharge. In re Holstein, 321 B.R. at 233-38; cf. Dusenberry v. Dusenberry,
625 N.E.2d 458, 462 (Ind. Ct. App. 1993) (“[A] tort claim for personal injury which has not been
reduced to a judgment has no readily ascertainable value.”); In re Vote, 276 F.3d 1024, 1026-27 (8th Cir.
2002) (“The trustee has not shown how the bankruptcy estate acquired an interest in the payments.”).
16.
Here, the right to property from the Sloppy settlement was exclusively vested in the Debtor as a
post-petition asset. In re Holstein, 321 B.R. at 233-38. After discharge in a no-asset case, the Debtor
maintained possession of post-petition assets, and exempt assets in a Title 11, Chapter 7 bankruptcy
under the U.S. Bankruptcy Code. The Debtor’s personal injury cause of action against Sloppy arose
when the Debtor suffered injury on June 15, 2013. In this case, the Debtor never raised a negligence
claim until after the Debtor’s discharge on July 15, 2010. The Debtor had no injury from the Hip
Implant at that time, nor did any injury manifest for almost three years after discharge. Thus, the Hip
Implant, as a basis under the sufficiently-rooted-test, is simply too attenuated legally and temporally to
justify a premature, speculative claim during pre-petition based on a defective product unbeknownst to
the Debtor at that time. In re Holstein, 321 B.R. at 233-38.
17.
Fourth, the sufficiently-rooted-test is not a failsafe to justify the Trustee’s overreaching. Id.
Under tort law, the sufficiently-rooted-test cannot apply to a personal injury plaintiffs. Id. The test fails a
timing element in a personal injury cause of action because the cause of action may not precede or

10. 9
accrue before an injury manifests—without an injury or damages, a debtor-plaintiff has no cause of
action to recover damages from another’s negligence under state law. Id.; In re Gullone, 301 B.R. at
687. And, if the injury manifests post-petition, then any preceding claim for a personal injury cause of
action is an un-ripened cause of action that would not vest to the Trustee. 11 U.S.C. § 552(a); In re
Bauer, No. BAP.EC-09-1281-DMKH, 2010 WL 6452899, at *11 (B.A.P. 9th Cir. 2010).
18.
The Trustee simply cannot find a plaintiff to have some matter pre-discharge that alerts the
plaintiff of the mere possibility of harm, or the possible existence of some unforeseen claim. In re
Holstein, 321 B.R. at 238 (overruling Segal v. Rochelle, 382 U.S. 375, 376-81 (1966)) (refusing to
extend the sufficiently-rooted-test for debtor-plaintiffs who file a tort cause of action after discharge).
The Debtor’s “cause of action was unknown, not even rising to a hope; [and,] the most pessimistic
curmudgeon could not anticipate [the plaintiff’s loss] . . . .” In re Witko, 374 F.3d 1040, 1044 (11th Cir.
2004). In the case In re Holstein, the court denied the Trustee’s invitation to “expand estate property to
include legal or equitable interests a debtor acquires post-petition, as long as a clever trustee can tie
those interests to the ‘pre-bankruptcy past.’” 321 B.R. at 238.
19.
The law does not deal with unforeseen possibilities: “The ‘mere possibility’ of harm does not
give rise to a legal [negligence] claim . . . .” In re Holstein, 321 B.R. at 236. Whether a cause of action
arising after discharge is sufficiently rooted in pre-discharge assets is moot under tort law; the claim
only arises when all elements to the cause of action are present. Id. 236-38. Here, the Debtor suffered no
injury and had no cause of action before discharge. 11 U.S.C. § 502(b); In re Holstein, 321 B.R. at 233-
38. Not only does the Debtor’s defective Hip Implant fall under the exemption for health aids under
Indiana law, but the subsequent litigation for the Debtor’s defective Hip Implant falls squarely beyond

11. 10
the Trustee’s request for relief. In re Holstein, 321 B.R. at 233-38; see also IC § 34-55-10-2 (c)(4) (West
2015); In re Stanger, 385 B.R. 758, 763-64 (Bankr. D. Idaho 2008).
20.
The Trustee’s application of minimal, irrelevant case law to a personal injury claim in a mass
torts case is ludicrous, and properly rejected by legal authorities. In re Holstein, 321 B.R. at 233-38; In
re Kewanee Boiler Corp., 198 B.R. at 529. Other courts previously analyzed the failure of the
sufficiently-rooted-back test with personal injury plaintiffs’ negligence claims that are related to the
Debtor’s duty of reporting foreseeable claims during pre-petition in bankruptcy law. In re Kewanee
Boiler Corp., 198 B.R. at 529. The Trustee seeks to place the Debtor into the same place as Sloppy with
respect to one’s duty to foresee unreasonable risks of harm, and before any injury ever manifests, back
to the moment of the first Hip Implant surgery—which is of no moment for a right to recovery in a
personal injury claim. See In re Gullone, 301 B.R. at 687 (requiring the element of injury for damages).
21.
The Trustee is creating an unworkable bright-line rule for debtor-plaintiffs to speculate about a
plethora of possibilities along a wide spectrum regarding someone else’s unforeseeable conduct. In re
Holstein, 321 B.R. at 233-38; cf. In re Dow Corning Corp., 211 B.R. 545, 556-89 (Bankr. E.D. Mich.
1997). For personal injury debtor-plaintiffs, the cause of action in personal injury is unforeseeable until
the debtor-plaintiff experiences a manifested injury from another’s negligence. See In re Kewanee Boiler
Corp., 198 B.R. at 529-31. The law does not impose such an exacting standard of clairvoyance for
plaintiffs to predict future lawsuits. Compare In re Holstein, 321 B.R. at 233-38 (debtor-plaintiffs) with
Morton, 562 N.E.2d at 785-86 (tort-defendants).
The Trustee’s self-defeating position turns the principles of negligence upside down, and allows
the tortfeasor to escape liability to compensate the plaintiff directly by shifting the tortfeasor’s duty of

12. 11
care—one’s ability to foresee causing unreasonable risks of harm to others—improperly onto the tort-
plaintiff within the context of bankruptcy law. See Hammes, 659 N.E.2d at 1025, 1029-30; see also In re
Butcher, 189 B.R. 357, 364-67 (Bankr. D. Md. 1995). Under this impossible theory, a Debtor in a
Chapter 7 bankruptcy must speculate about unforeseeable causes for litigation, which is nothing short of
gazing into a crystal ball. See In re Witko, 374 F.3d at 1044. In sum, the Trustee’s baseless allegations of
fraud must not serve as a backdoor to willfully circumvent the Debtor’s discharge and assert a claim for
post-petition assets that belong to the Debtor. Thompson v. Vill. of Monee, No. 12 CV 5020, 2014 WL
4175915, at *4 (N.D. Ill. 2014); 11 U.S.C. § 524(a) (West 2015); Id. at § 552(a). See Exhibit D.
WHEREFORE, the Debtor requests for the reasons set forth herein and for such reasons as may
appear upon an oral hearing of this Motion:
(1) that the Court direct oral argument on this Motion pursuant to 11 U.S.C. § 105;
(2) that the Court find the Debtor suffered no damage until long after the Debtor’s discharge, and
lacked an essential element of injury for negligence under Indiana law prior to June 15, 2013,
pursuant to IC §§ 34-20-1-1;
(3) that the Court find the Debtor had no asset in the cause of action against Sloppy prior to
discharge pursuant to 11 U.S.C. § 502(b);
(4) that the Court enter an order finding for the Debtor’s cause of action against Sloppy is a post-
petition asset pursuant to 11 U.S.C. § 552(a);
(5) that the Court dismiss the case for failure to state a claim pursuant to FED. R. BANKR. P.
7012; FED. R. CIV. P. 8-9, 12(b)(6); Bell Atl. Corp., 550 U.S. at 570; Iqbal, 556 U.S. at 678;
(6) that the Court grant the Debtor a preliminary injunction against the Trustee from raising a
collateral attack by alleging fraud, misrepresentation, or other misconduct against the Debtor

13. 12
/s/ Attorney at Bar, Esq.
regarding the defective Hip Implant pursuant to FED. CIV. R. P. 60(b); FED. R. BANKR. P.
7001;
(7) that the Court grant the Debtor’s request for a separate hearing regarding whether the Trustee
should pay any and all reasonable expenses incurred from defending unconstitutional claims
pursuant to 11 U.S.C. § 523(d); Id. at § 362(k); U.S. CONST. amend. V; U.S. CONST. amend.
XIV; 42 U.S.C. 1983 (West 2015); FED. R. CIV. P. 11(b); and
(8) such other relief as the Court shall deem just and proper.
Respectfully submitted, this day of , 20 .
___________________________
Attorney at Bar, Esq.
Attorney for Defendant
State Bar No. 999999
Attorney at Bar, Esq.
Anywhere Law Firm, LLC
123 Law Central Blvd.
Savannah, Georgia 31401
(912) 257-6253 t
(912) 999-9999 f
dldickson@savannahlawschool.org
www.savannahlawschool.org