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PLEASE NOTE
In acc'ord~nce with Section 177A of the Mississippi Constitution of 1890, all procee~ingsbefore the Mississippi
Commission on Judicial Performance are confidential unless and until the Commission files a recommendation"
for discipline or retirement with the Mississippi Supreme Court Confidentiality shall attach upon the filing of
the complaint and shall include all' records, flies, and reports of the Commission.
I.
PERSO~ISING COMPLAINT:.--,--.
Name:
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Address:
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If additional space is required, continue on additional pages as needed and attach them to this co
laint.
IV. I certify that the allegations and statements of fact set forth above are true and correct to the best of -my
knowledge, information and belief and are made of my'
~. /?U't;y
( Date)
se will.
NANINE MCCOOL
.Jlttomey at Law
June
13~
2012
MISSISSIPPI COMMISION
ON JUDICAL PERFORMANCE
P.O. Box 22527
Jackson, Mississippi 39225-2527
RE:
Dear SirIMadam:
I am an attorney in good standing, licensed to practice and practicing in Louisiana. I am
not licensed to practice law, nor have I ever been licensed to practice, in Mississippi. I have
never made an appearance as a party or otherwise, in a Mississippi proceeding.
On or about September 19,2011, I received a letter at my office in Mandeville,
Louisiana, by regular mail, (attached) which contained a court pleading captioned as "In The
Chancery Court Of Marion County, Mississippi, Michael T. Boyd PlaintiffVs. Raven S. Boyd
(Maurer) Defendant, Cause No. 06-0136-0n-0." The pleading was titled as a "Show Cause
Order" and it was directed to me.
I am not a party to this case. I have made no appearance in this case. I am not enrolled
as an attorney in this case (nor could I be because I am not licensed). I have never been
subpoenaed or formally called in any manner to appear in any capacity in this case. I do not live
in Mississippi. I own no property in Mississippi. Despite its close geographic proximity, I
hadn't even set foot in Mississippi for more than a year prior. At best, I flew over Mississippi
last year on my way to North Carolina.
Under no credible theory of law could Judge Oambrell reasonably believe that she had
personal jurisdiction over me such that she had the power or authority to order me into her court,
or subject matter jurisdiction over any matter pending in a Louisiana court. Having failed to
even properly serve me with the order, I further had no obligation to respond to it and I did not.
On or about October 3,2011, I received a notice from the Louisiana Disciplinary Counsel
that Judge Oambrell had filed a formal complaint against me (attached). I responded to the
complaint with my disciplinary counsel, as required by the Louisiana Supreme Court rules and
the Louisiana Rules of Professional Conduct. That complaint is pending.
On October 13,2011, I received another letter at my office via regular mail that
contained an order issued by Judge Gambrell that authorized my arrest and incarceration for an
indefinite period of time (attached).
Judge Gambrell has clearly embarked upon a personal vendetta against me, and through
me, my client, Raven Maurer, who I suspect is her real target. I represent Raven and her
husband in proceedings in Louisiana. Raven also currently has a case pending before Judge
Gambrell in Mississippi. Judge Gambrell is apparently of the mind that the Louisiana
proceedings related to an adoption by Raven's current husband are infringing on her jurisdiction
of a custody matter between Raven and her former husband in Mississippi. Judge Gambrell has
apparently issued an order to that effect in Mississippi. She is, apparently, however, displeased
that Raven's current husband has not abandoned the adoption proceeding in Louisiana.
Whatever her objections, Judge Gambrell nevertheless has no jurisdiction over the
Louisiana adoption proceedings or Raven's current husband. She also has no jurisdiction over
me or direct influence over my conduct as an attorney.
In her complaint against me to my disciplinary board, Judge Gambrell admits to engaging
in ex parte communications with the Louisiana judge handling the adoption. She references
these ex parte communications during the proceeding in Raven's case that took place last
August, and appears to rely upon them in sanctioning Raven, and Raven's mother, who was
neither a party to the case, nor served with any notice that she could be sanctioned. Judge
Gambrell's treatment of Raven's mother during those proceedings is particularly deplorable
because Raven's mother was appearing as a witness and was instead put on trial by Gambrell and
then verbally sanctioned by Gambrell in her ruling. Gambrell's ruling in that matter, as
evidenced by the transcript, again demonstrates her disregard for the limits of her jurisdictionshe is apparently unaware of any - and basic due process, such as reasonable notice and personal
service, not to mention her obligation to act as an impartial fact finder..
Judge Gambrell should be sanctioned for her conduct toward me; for failing to know or
respect basic legal principles of jurisdiction and state sovereignty; for attempting to use her
position and authority for an improper purpose; for attempting to use her position and authority
to interfere with a judicial proceeding in another jurisdiction; for attempting to use her position
and authority to intimidate and bully citizens seeking justice through appropriate legal methods;
for abusing her position and authority and violating my constitutional rights by issuing a warrant
for my arrest without due process or personal or subject matter jurisdiction, for abusing her
position and authority to intimidate, bully and humiliate or attempt to humiliate a citizen
appearing as a witness in her courtro ; for taking the role of an advocate in the proceedings,
rather than as an impartial, object" e
iased fact der.
JNMJdm
Enclosures
Cc:
MICHAEL T. BOYD
PLAINTIFF
VS.
DEFENDANT
TO:
'SEP 152011
CASS BARNES, CHANCERY CLERK
BY
You are commanded to appear before the Chancery Court of Marion County,
Mississippi on the 5th day of October, 2011 at 9:00 a.m. to show cause as to why you
should not be held in contempt of this Court's prior Orders by disclosing information
from a "~ed" Chancery Comt file or in the alternative, to disclose how audio
transcriptions came into your possession after they were placed under seal by the
Chancery Court of Marion County, Mississippi on May 22, 2008 by Court Order as well
as an Agreed Order executed on the ~ day of September, 2008 wherein the parties
agreed to withhold any video tapes or other records, made by the parties, or at their
behest, of the minor children, which are the subject of this litigation; This Order
prohibited the making of any audio or video recordings in an attempt to document
allegations set forth in the pleadings.
D.C.
That it bas come to this Court's attention that the protected audio recordings are
being disseminated via social medial networks under the following accounts:
www.twitter.comlnaninemccool
www.change.orglpetitionsljustice-for-barley-and-zoey
~
This the J!Lday of September, A.D., 2011.
CHANCELLOR
RESPONDENT:
Joyce Nanine McCool
COMPLAINANT: Deborah J. Gambrell
FILE NO.:
0028469
LtJ~s.
Damons.~
DSMljdh
Enclosure
(t)
Tenth Chancery Court District of Mississippi
(Forrest. Lamar. Marion, Pearl River & Perry Counties)
Website: www.chancery10.com
Deborah J. Gambrell
Barbara O. Parham
Certified Court Administrator
Chancellor-Place One
Post Office Box 807
Hattiesburg. MS 39403-0807
(601) 545-6028
(601) 582-2582
Fax: (601) 545-6080
patsyains@yahoo.com
bparham@co.forrest.ms.us
Sepb9nberlS,2011
~~nwq]
Re:
Complaint
Louisiana Attorney Joyce Nanine McCool
Bar Number 27026.
DfSCIPUNARV COtJNS@.
SEP 1 9 2011
OFRCEOF
COMPLAINT
This file was "sealed" by the court, and Attorney McCool appears to be disclosing
information from a sealed file in violation of the Court's Order. Also she may not be
aware, that the signatories to the Petition she is circulating are participating in a
conspiracy to intimidate a judicial officer, which is a felony in this state. (Miss. Code
Ann. 97-9-55)
I direct your attention to the following websites:
www.change.orglpetitionsljustice-for-harley-and-zoey
www.twitter.comlnaninemccool
The article on change.org contains a link to the twitter account, which contains the
alleged audio recordings of the minors. This is Attomey McCool's twitter account
Please accept this as a formal complaint against Joyce Nanine McCool.
DLGJ: s
Enclosures
Cc: Honorable Dawn Amacker
..-
FILED
AUG 13 2007
RAVENW. BOYD
DEFENDANT
ORDER GRANTING
MOTION FOR TEMPORARY EMERGENCY RELIEF
THIS'DAY, this cause came on for hearing on Motion for Temporary Emergency Relief
filed by the Petitioner, John D. Smallwood, Guardian A~ Litem, and. all parties having been
, noticed and after having been informed that the Defendant does not oppose the petition, the
Court finds that the Motion is well taken and should be and is hereby granted.
THEREFORE
IT IS HEREBY ORDERED AND ADJUDGED. that Raven Boyd, Wanda Phillips and
any persons acting on their behalf or at their direction are hereby enjoin'ed from making
the
same or simBar allegations of sexual abuse as to the minor chDdren of the parties herein.
IT IF FURTHER ORDERED AND ADJUDGED that Raven Boyd, Wanda Phillips and
any persons acting on their behalf or at their direction are enjoined from subjecting the minor
children to any more medical examinations for the same or similar allegations of sexual
abuse..
,J.11
PRESENTED BY:
JOHN D. SMALLWOOD, ESQ.
89:48
6~98ee~
JUN 27 2008
IN THE CHANCERY COURT OF MARION COUNTY
THE STATE OF MISSISSIPPI
MICHAEl T. BOYD
CLERK
D.C.
PLAINTIFF
vs.
RAVENW. BOYD
DEFENDANT
'..
.
and the-COurt having heard
all counsel; the Court flnda that based upon the nature
fRm
of allegations made In pleadings flied 1ft thll matter and to protect the mln~; children In
this mauer. the entJrefile .hall aBlllld by the cleric and not made available to any
petaOn until further order
"
0'
being gtven 10 both:parlfel and the court appointed Guardian All LItem herein.
THEREFORE, !_
IT IS HEREBY ORDERED AND ADJUDGeD. that the entfr8
shall be eearect by the erelt unit1 fUJ1her order of thl8 Court.
'''II
_in
thI& matter
FI~~Et
..
OCT 112011
CASS BARNES CHAN
IN THE CHANCERY COURT OF MARION COUNTY, MISS~IPPI
:t
(fRY CLau
D.c.
PLAINTIFF
MICHAEL T. BOYD
vs.
DEFENDANT
ORDER OF CONTEMPT
THIS CAUSE THIS DAY, October 5, 2011, having come to Court to be heard
upon the Show Cause order wherein the said Joyce Nanine McCool was ordered to
appear and show cause as to why she should not be held in contempt of this Court's prior
Orders by disclosing infonnation from a "sealed" Chancery Court file or in the
alternative, to disclose how audio transcriptions came into her possession after they were
placed under seal by the Chancery Court of Marion County, Mississippi on May 22, 2008
by Court Order as well as an Agreed Order executed on the 2nd day of September, 2008
wherein the parties agreed to withhold any video tapes or other records, made by the
parties, or at their behest, of the minor children, which are the subject of this litigation;
This Order prohibited the making of any audio or video recordings in an attempt to
document allegations set forth in the pleadings.
The Court has learned that the protected audio recordings are being disseminated
After being called thrice in open Court the said Joyce Nanine McCool failed to
appear.
..
IT IS THEREFORE ORDERED that the said Joyce Nanine McCool is in
contempt of this court for having failed to appear or respond and is hereby placed into the
custody of the Sheriff of Marion County, Mississippi for a period of ten (to) days where
she shall remain until further Order of this Court.
This the 6th day of October, A.D., 2011.