STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE

COUNTY OF SURRY SUPERIOR COURT DIVISION

WILLIAM NEIL SHELTON } 15 CVS ________________

PLAINTIFF, }

vs } COMPLAINT

STEVENS AND BRINTLE LAWFIRM; } ( Jury Trial Requested)

SARAH STEVENS; ZACHERY SMITH }

BRINTLE; KIM HIATT SHELTON, }

DEFENDANTS }

Plaintiff, complaining of the defendants, alleges and says:

1. The plaintiff is a citizen and resident of Surry County, North Carolina. 2. Upon information and belief, the defendant Stevens and Brintle Lawfirm is a Lawfirm with it’s

principal place of business in Mount Airy, Surry County, North Carolina. 3. The defendant Sarah Stevens is a citizen and resident of Surry County, North Carolina. 4. The defendant Zachery Smith Brintle is a citizen and resident of Surry County, North Carolina. 5. The defendant Kimberly Hiatt Shelton is a citizen and resident of Surry County, North Carolina. 6. The defendant Kimberly Hiatt Shelton retained the Lawfirm Stevens and Brintle Lawfirm better

known as Sarah Stevens and Zack Brintle to represent her in the matter of Divorce in the year 2012.

7. The plaintiff William Neil Shelton and the defendant Kimberly Hiatt Shelton were in a relationship from 1995 and were then married in 1999 through the end of the divorce.

8. The defendant Kimberly Hiatt Shelton and the plaintiff William Neil Shelton had two children during the course of the marriage the two children being William Russell Shelton and Addison Louise Shelton.

9. During the course of dating a home was picked out by both parties and bought under the name of Kimberly Hiatt Shelton in 1998 but both parties William Neil Shelton and Kimberly Hiatt Shelton resided there until the beginning of the divorce in 2012. With the payments of the said house being made with marital monies from both parties.

10. The defendant Kimberly Hiatt Shelton maintained a personal checking account with funds from both parties being deposited.

11. The defendant Kimberly Hiatt Shelton had always maintained the financial ends of the marriage including the banking accounts with the reasoning that since the plaintiff William Neil Shelton was self employed in case of lawsuits the best thing to do was for the plaintiff not to have anything in his name.

12. The plaintiff William Neil Shelton never held a personal account from 1999 until the time of marriage was illegally dissolved.

13. The plaintiff William Neil Shelton was the owner of several businesses including MCS Commercial Cleaning, One Stop Utility Buildings and Truck Accessories, Mayberry Squad Cars

.com, Unique Auto Sales of Mount Airy, Mayberry Limousine Service, Moby’s Coffee and Otis’ Nightclub. The Plaintiff William Neil Shelton did hold business accounts for the said businesses with the defendant Kimberly Hiatt Shelton being on the signature card and allowed to write checks on said accounts and was a signer of Surety Bond for Unique Auto Sales of Mount Airy North Carolina.

14. In 2010 the plaintiff William Neil Shelton and the business Unique Auto Sales of Mount Airy were the victims of embezzlement from a employee Jody Clayton Inman also of Surry County, North Carolina.

15. The Plaintiff William Neil Shelton was the victim of several warrantless and illegal arrests due to the unscrupulous ways the bank and Mount Airy Police Department and Surry County District Attorney’s office.

16. The Plaintiff William Neil Shelton doing business as Unique Auto Sales of Mount Airy North Carolina entered into a Civil Lawsuit against Jody Clayton Inman; Surrey Bancorp; Surry Bank and Trust and Edward C. Ashby all of Surry County, North Carolina.

17. The lawsuit was settled by the then defendants Surrey Bank and Trust and all parties included which just the settlement amount of the said lawsuit being sealed.

18. The settlement money was awarded to the plaintiff William Neil Shelton but made payable to the defendant Kimberly Hiatt Shelton to handle all open accounts and balances in which she did not do.

19. The plaintiff William Neil Shelton has over One Hundred Thousand Dollars in monetary judgements against him while The defendant Kimberly Hiatt Shelton even though who is on the surety bond for Unique Auto Sales of Mount Airy North Carolina has no monetary judgments against her only because the plaintiff William Neil Shelton has never sent a copy of the said surety bond to the companies with said monetary judgments placed against the plaintiff William Neil Shelton.

20. The defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle at the request of the defendant Kimberly Hiatt Shelton put a protective order against the sealed bank settlement without me being allowed due process and not having it heard in court.

21. Upon information and belief, the defendant Kimberly Hiatt Shelton at the coaching of the Defendants Stevens and Brintle Lawfirm, Sarah Stevens and Zachery Smith Brintle had my sister Joan Shelton Phillips a Licensed Family Nurse Practioner in the State of North Carolina misrepresented my medical records saying that the plaintiff William Neil Shelton was bi-polar refusing medications to attempt two unsuccessful Involuntary Commitment Warrants in the same day to try and institutionalize the said plaintiff William Neil Shelton. Which upon review the hospital realized that the plaintiff William Neil Shelton had never been seen, diagnosed or treated for bi-polar disorder.

22. Upon information and belief, the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle and Kimberly Hiatt Shelton the same day with the help of the defendants Kimberly Hiatt Shelton’s sister in law Melissa Watts Hiatt who was at that time the director for Surry S.C.A.N. { Stop Child Abuse Now} then issued warrants for the plaintiff the same day as the two failed Involuntary Commitment attempts then had warrants issued and enforced for Domestic Criminal Trespassing to get a Restraining Order placed upon the plaintiff William Neil Shelton for the third arrest of the same day.

23. The plaintiff William Neil Shelton was found not guilty of Domestic Criminal Trespassing but yet due to the weight that the defendant Sarah Stevens carries with the Court due to her roll as State Representitive for the State of North Caroina the Restraining Order remained in place.

24. The defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle and Kimberly Hiatt Shelton then used the as proven now to be bogus Restraining Order to get a Custody Ex

Parte put in place by Judge William Flynn Southern whom Sarah Stevens was making financial contributions to his campaign for The North Carolina Court of Appeals to get Emergency Custody of the two minor children and the home as well as all assets.

25. Upon information and belief the defendant Kimberly Hiatt Shelton at the coaching of Stevens and Brintle Lawfirm, Sarah Stevens and Zarchery Smith Brintle had the plaintiff William Neil Shelton arrested numerous times with false accusations of violating the said restraining oder. Which resulted in numerous False Arrests and Emotional and Financial suffering of the plaintiff William Neil Shelton. All false allegations were either Not Guilty or Dismissed.

26. Upon information proof and belief, with the help of the defendants Sarah Stevens and Kimberly Hiatt Shelton the drafted a letter which has been proven Zachery Smith Brintle to be the Author threatening court officials, lawyers, family members and others to have the plaintiff William Neil Shelton arrested and held in custody to insure a complete win in the divorce case thus leaving the plaintiff William Neil Shelton receiving nothing in the Divorce Resolution.

27. Upon information and belief, The defendants Stevens and Brintle Lawfirm, Sarah Stevens and Zachery Smith Brintle then began bombarding the Court with Motions to Compell regarding to answering questions in the Divorce case knowing that the plaintiff William Neil Shelton did not posses them and had no access to the Interrogatory Questions from the Divorce Proceedings.

28. Upon information and belief, the defendants Sarah Stevens and Zachery Smith Brintle conspired with the local District Attorneys office to hold the Defendant in Jail on the False Allegations for the Threatening Letter that Zachery Smith Brintle wrote saying that the plaintiff Willaim Neil Shelton wrote. To hold the Plaintiff William Neil Shelton illegally for eleven months in the Surry County Jail in order to lose everything in the Divorce Proceedings.

29. Upon information and belief, The defendants Stevens and Brintle Lawfirm, Sarah Stevens and Zachery Smith Brintle made and published disparaging remarks about the plaintiff William Neil Shelton with the intent to harm the plaintiff’s reputation which were in fact harmful to the plaintiff William Neil Shelton’s businesses and reputation.

30. The defendants actions with the letter written by the defendant Zachery Smith Brintle of the Lawfirm Stevens and Brintle who was conspiring with the defendants Sarah Stevens and Kimberly Hiatt Shelton to manufacture evidence for the purpose of harming the plaintiff William Neil Shelton.

31. The defendant Kimberly Hiatt Shelton took and converted to his own, to the exclusion of the plaintiff William Neil Shelton, use monies and properties due to the plaintiff. The defendant Kimberly Hiatt Shelton who was conspiring with the defendants Stevens and Brintle Lawfirms, Sarah Stevens and Zachery Smith Brintle took and transferred to others all pre marital property including motor vehicles, marital monies, business monies that were the sole or joint property of the plaintiff.

32. The defendant Kimberly Hiatt Shelton while conspiring with the defendants Stevens and Brintle Lawfirm, Sarah Stevens and Zachery Smith Brintle took and converted to her own use, to the exclusion of the plaintiff, various personal property, data and private information, including all businesses and property of the plaintiff William Neil Shelton.

33. The defendant Kimberly Hiatt Shelton who was conspiring with the defendants Stevens and Brintle Lawfirm, Sarah Stevens and Zachery Smith Brintle instituted and prosecuted against the plaintiff William Neil Shelton, wrongfully and maliciously, criminal charges including the ones mentioned above but not limited to the six felonies from the letter written by Zachery Smith Brintle, among other charges.

34. Upon information and belief, the defendants Stevens and Brintle Lawfirm, Sarah Stevens and Zachery Smith Brintle conspired with the defendant Kimberly Hiatt Shelton to institute and prosecute wrongful and malicious criminal claims against the plaintiff William Neil Shelton.

35. Upon information and belief, the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle conspired with the defendant Kimberly Hiatt Shelton toaid and abet institute and prosecute wrongful and malicious criminal claims against the plaintiff William Neil Shelton, resulting in damage to the plaintiff’s reputation and incarceration.

36. Upon information and belief, the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle conspired with the defendant Kimberly Hiatt Shelton to obstruct justice and prevent the plaintiff from obtaining necessary information to starve off and defend both civil and criminal charges.

37. As a direct, proximate and consequential result of the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle and Kimberly Hiatt Shelton misconduct the plaintiff William Neil Shelton has suffered substantial damages including but not limited to loss of personal and marital property, loss of funds, lost profits, extensive expenses, loss of creditworthiness, damage to reputation, the loss of his livelihood, physical pain and mental suffering and parental alienation.

FIRST CLAIM FOR RELIEF

(CONVERSION Kimberly Hiatt Shelton)

1. Plaintiff incorporates herein by reference all of the allegations set forth in the preceeding paragraphs of this Complaint as set for herein.

2. The defendant Kimberly Hiatt Shelton took and converted to her own use substantial sums of money, cars and negotiable instruments that were and should have been the property of the plaintiff William Neil Shelton with the intent to deprive the plaintiff William Neil Shelton of his property through various fraudulent schemes, including selling vehicles that were both marital and pre marital property, monies and real properties and other ways that will be proven at trial.

3. The defendant Kimberly Hiatt Shelton took motor vehicles in the that were the plaintiffs William Neil Shelton pre marital property in exchange for money or other goods or services with the intent to deprive the plaintiff William Neil Shelton of the vehicles and value of the vehicles and the value of the funds received upon transfer of the said vehicles. The defendant Kimberly Hiatt Shelton took and converted other personal and real property of the plaintiff William Neil Shelton for her own use with the intent to deprive the plaintiff William Neil Shelton of the property.

4. As a direct, proximate and consequential cause of the defendant Kimberly Hiatt Shelton’s conversion, fraud and other misconduct, the plaintiffs William Neil Shelton businesses were damaged, lost and destroyed and the plaintiffs financial and credit worthiness is no longer in good standing.

5. The plaintiff William Neil Shelton is entitled to have and recover of the defendant Kimberly Hiatt Shelton in excess of $1,000,000.00 as a result of conversion, fraudulent misconduct, intentional misconduct and other misconduct as set forth herein.

SECOND CLAIM FOR RELIEF

(FRAUD Kimberly Hiatt Shelton)

6. Plaintiff William Neil Shelton incorporates herein by reference all of the allegations set forth in the preceeding paragraphs of this Complaint as is fully set forth herein.

7. The defendant Kimberly Hiatt Shelton’s willful, intentional and malicious conduct and her false allegations, representations were designed to mislead the plaintiff William Neil Shelton and others and did mislead the plaintiff William Neil Shelton and others resulting in substantial harm and damage to the plaintiff as set forth herein.

8. The Plaintiff is entitled to have and recover of the defendant Kimberly Hiatt Shelton in excess of $1,000,000.00 as a result of her actual and constructive Fraud.

THIRD CLAIM FOR RELIEF

(INTENTIONAL AND NEGLIGENT MISREPRESENTATION Kimberly Hiatt Shelton)

9. Plaintiff incorporates herein by reference all of the allegations set forth in the preceeding paragraphs of this Complaint as is fully set forth herein.

10. The defendant Kimberly Hiatt Shelton made intentional, knowing, reckless and negligent misrepresentations to the plaintiff William Neil Shelton, and to local law enforcement agencies, family, and third parties regarding ownership of property, including but not limited to motor vehicles, real property and criminal activities thus causing financial, emotional and mental damages, false arrests and incarceration.

11. As a direct, proximate and consequential result of the defendants Kimberly Hiatt Shelton’s misrepresentations, the plaintiff William Neil Shelton lost property, incurred obligations, breach of fiduciary responsibilities and paid money to lenders, third parties and others, wrongful imprisonment, parental alienation and the plaintiff William Neil Shelton was damaged in an amount in excess of $1,000,000.00.

FOURTH CLAIM FOR RELIEF

(FRAUD Zachery Smith Brintle)

1. Plaintiff William Neil Shelton incorporates herein by reference all of the allegations set forth in the preceeding paragraphs of this Complaint as is fully set forth herein.

2. The defendant Zachery Smith Brintle willful, intentional and malicious conduct and his false representation of the terroristic letter that has been proven he wrote while saying that the plaintiff William Neil Shelton wrote to silence the plaintiff William Neil Shelton and guarantee a complete win in all areas of the Divorce and Custody case. These actions resulted in the incarceration of the plaintiff William Neil Shelton for eleven months in the Surry County Jail. The defendant conspired with the other named defendants Sarah Stevens and Kimberly Hiatt Shelton to guarantee the above mentioned accusations and proof will be made available only at the time of trial.

3. The defendant Zachery Smith Brintle’s willful, intentional and malicious cinduct and his false allegations and representation were designed to mislead the plaintiff, law enforcement and other third parties and did mislead the plaintiff and others resulting in substantial harm to the plaintiff William Neil Shelton as set forth herein.

4. The plaintiff is entitled to have and recover of the defendant Zachery Smith Brintle in excess of $1,000,000.00 as a result of his actual and constructive fraud.

FIFTH CLAIM FOR RELIEF

(INTENTIONAL and NEGLIGENT MISREPRESENTATION Zachery Smith Brintle, SarahStevens, Stevens and Brintle Lawfirm)

5. Plaintiff incorporates herein by reference all of the allegations set forth in the preceeding paragraphs of this Complaint as it is fully set forth herein.

6. The defendants Zachery Smith Brintle and Sarah Stevens made intentional, knowing, reckless and negligent misrepresentations to the local law enforcement, Judicial members, District Attorney’s office, family members and third parties regarding ownership of properties and false allegations resulting in multiple arrests and incarceration of the plaintiff William Neil Shelton.

7. As a direct, proximate and consequential result of the defendants Zachery Smith Brintle’s and Sarah Stevens’s misrepresentations, the plaintiff lost property, freedom, incurred obligations, third parties and others, and the plaintiff was damaged in excess of $1,000,000.00

8. Treble damages are requested as a result of the afore mentioned allegations.

SIXTH CLAIM FOR RELIEF

(DEFAMATION STEVENS AND BRINTLE LAWFIRM, SARAH STEVENS, ZACHERY SMITH BRINTLE, KIMBERLY HIATT SHELTON)

9. Plaintiff William Neil Shelton incorporates herein by reference all of the allegations set forth in the preceeding paragraphs of this Complaint as fully set forth herein.

10. Upon information and belief, the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle and Kimberly Hiatt Shelton, all acting within the scope of the above referenced proceedings manufactured and relayed false, misleading, slanderous, libelous and defamatory accusations and statements for the purpose of damaging the plaintiff William Neil Shelton’s reputation, his businesses and his physical and mental well being and loss of freedom for several false arrests including the letter written by Zachery Smith Brintle in Conspiracy with Sarah Stevens and Kimberly Hiatt Shelton.

11. As a direct, proximate and consequential result of the conduct of the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zackery Smith Brintle and Kimberly Hiatt Shelton, the plaintiff William Neil Shelton was damaged in excess of $1,000,000.00.

SEVENTH CLAIM FOR RELIEF

(MALICIOUS PROSECUTION, ABUSE OF PROCESS AND FALSE IMPRISIONMENT STEVENS AND BRINTLE LAWFIRM, SARAH STEVENS, ZACHERY SMITH BRINTLE, KIMBERLY HIATT SHELTON)

12. Plaintiff William Neil Shelton incorporates herein by reference all of the allegations set forth in the preceeding paragraphs of this Complaint as fully set forth herein.

13. Upon information and belief, the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle and Kimberly Hiatt Shelton for a ulterior purpose conspired to institute and continue, without probable cause and with malice, criminal proceedings against the defendant William Neil Shelton causing him to lose his liberty, freedom, incur expences and suffer damage to his mind, body and reputation.

14. As a direct ,proximate and consequential result of the conduct of the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle and Kimberly Hiatt Sheltonthe plaintiff was damaged in excess of $1,000,000.00.

EIGHTH CLAIM FOR RELIEF

(FRAUDULENT MISREPRESENTATION STEVENS AND BRINTLE LAWFIRM, SARAH STEVENS, ZACHERY SMITH BRINTLE, KIMBERLY HIATT SHELTON)

1. Plaintiff William Neil Shelton incorporates herein by reference all of the allegations set forth in the preceeding paragraphs of this Complaint as fully set forth herein.

2. Upon information and belief, the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle and Kimberly Hiatt Shelton conpired to manufacture, prepare, procure and report false and misleading information to local Law Enforcement, District Attorney’s Office and third parties with malice and for the purpose of harming the plaintiff William Neil Shelton.

3. As a direct and proximate and consequential resultof the conduct of the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle and Kimberly Hiatt Shelton the plaintiff William Neil Shelton was damaged in an amount in excess of $1,000,000.00.

NINTH CLAIM FOR RELIEF

(INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS STEVENS AND BRINTLE LAWFIRM, SARAH STEVENS, ZACHERY SMITH BRINTLE, KIMBERLY HIATT SHELTON)

4. Plaintiff William Neil Shelton incorporates herein by reference all of the allegations set forth int the preceeding paragraphs of this Complaint as fully set forth herein.

5. The aforesaid conduct of the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle, Kimberly Hiatt Shelton was perpetrated to inflict and did inflict upon the plaintiff William Neil Shelton severe financial, mental and emotionational distress.

6. As a direct, proximate and consequential result of the conduct of the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle, Kimberly Hiatt Shelton, the plaintiff William Neil Shelton was damaged in an amount in excess of $1,000,000.00.

TENTH CLAIM FOR RELIEF

(UNFAIR AND DECEPTIVE TRADE PRACTICES STEVENS AND BRINTLE LAWFIRM, SARAH STEVENS, ZACHERY SMITH BRINTLE, KIMBERLY HIATT SHELTON)

7. Plaintiff William Neil Shelton incorporates herein by reference all of the allegations set forth in the preceeding paragraphs of this Complaint as fully set forth herein.

8. The aforesaid conduct of the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle, Kimberly Hiatt Shelton unfair and deceptive and willful conduct of the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle, Kimberly Hiatt Shelton was in commerce and caused injury and damage to the plaintiff William Neil Shelton and his businesses, physical and mental health.

9. The plaintiff William Neil Shelton is entitled to recover from the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle and Kimberly Hiatt Shelton treble damages and future attorneys’ fees pursuant to N.C.G.S. Chapter 75.

ELEVENTH CLAIM FOR RELIEF

(PUNITIVE DAMAGES STEVENS AND BRINTLE LAWFIRM, SARAH STEVENS, ZACHERY SMITH BRINTLE, KIMBERLY HIATT SHELTON)

10. Plaintiff incorporates herein by reference all of the allegations set forth in the preceeding paragraphs of this Complaint as fully set forth herein.

11. The aforesaid conduct of the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle and Kimberly Hiatt Shelton was done with malice, was willful, was grossly negligent and was done with reckless disregard to the rights of the plaintiff William Neil Shelton entitling the plaintiff William Neil Shelton to recover punitive damages, in excess of $1,000,000.00.

WHEREFORE the plaintiff William Neil Shelton prays the he have and recover of the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle and Kimberly Hiatt Shelton treble damages; that the plaintiff William Neil Shelton have and recover of the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle and Kimberly Hiatt Sheltons’ punitive damages in excess of $1,000,000.00; that the plaintiff William Neil Shelton have and recover of the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle and Kimberly Hiatt Shelton treble damages ; that the plaintiff William Neil Shelton have and recover reasonable attorneys’ fees; the the costs of this action be taxed against the defendants Stevens and Brintle Lawfirm, Sarah Stevens, Zachery Smith Brintle and Kimberly Hiatt Shelton; and that the Court grant the plaintiff such other and futher relief as to the Court may seem just and proper; plus Sarah Stevens and Zachery Smith Brintle forfeit their Law License as a result of all their unlawful misconduct.

This the ____ day of November, 2015

______________________________________

William Neil Shelton

Pro-Se

OF COUNSEL

William Neil Shelton

1497 North Franklin Road

Mount Airy NC 27030