AFFIDAVIT OF JANET D.

MCDONALD

NOW COMES Janet D. McDonald and after first duly sworn, deposes and says
that:
My name is Janet D. McDonald, I am over 18 years of age and competent in all
respects to testify regarding matters set forth herein. I am a Legal, taxpaying citizen of
DeKalb County State of Georgia. I have firsthand knowledge of the circumstances
regarding the relationship of all parties mentioned in the Answer and Counterclaim
surrounding Civil Action File No.: 06A44151, Sandra D. Hicks, d/b/a The Hicks Law Firm
v. James Stegeman. I attest that everything in the Counterclaim is true.
Mr. Stegeman is in ill health, seeing Doctor Schwartz in Stone Mountain every
thirty days. He has no car, annual income of less than $7500.00, and owes me a great
deal of money.
Attached hereto is a partial record of billing and payments to The Hicks Law Firm
from my records as “Exhibit 1”.
Mr. Stegeman is representing himself against The Hicks Law Firm. Neither Mr.
Stegeman nor I have the funds for an attorney due to negligence of The Hicks Law Firm.
Ms. Hicks is in error filing suit against Mr. Stegeman. Ms. Hicks should be filing
suit against attorneys that work in her law firm. The Hicks Law Firm did not continue the
duration of the matter. Mr. Stegeman is a law abiding citizen and because of The Hicks
Law Firm failure to protect him, his rights, his person Mr. Stegeman has suffered and lost
a great deal. The Hicks Law Firm knew of should have known Mr. Stegeman’s physical,
financial and emotional status. I attended the meeting when Mr. Stegeman explained his
finances, physical and mental health issues.
The Hicks Law Firm did nothing to protect accounts owned by Mr. Stegeman and
myself, accounts that would be worth $400,000.00.
The Hicks Law Firm refused to protect Mr. Stegeman, allowing his Constitutional
and Civil Rights to be violated repeatedly. By not obtaining a Court order so that Ms.
Caffrey would be deposed, The Hicks Law Firm is partially responsible for her death. No
family member was allowed contact with her or see her until the time of her death.
Ms. Caffrey, sister of Jack and Albe (James and Douglas’s father) Stegeman;
Aunt of James, Douglas, Mike and Jeff Stegeman; The Great, Aunt of Douglas
Stegeman’s seven children; The Great, Great Aunt of Douglas Stegeman’s
grandchildren. It is a tragedy, Ms. Caffrey was cremated, buried in a place she had
requested not to be buried in before family knew of the death.
All of the documents surrounding the death had been falsified. The Hicks Law
Firm did nothing. The family Bible held by Ms. Caffrey, statues carved by Albe
Stegeman as a boy, gone. Family has no idea what happened to the personal items of
Ms. Caffrey and items of sentimental value that family members should receive in order
to cherish. These items and all of the $115,000 except for $24,000.00 disappeared while
handled by a Temporary Administrator. Before a hearing in front of a Probate Judge, a
Temporary Administrator does not have the authority to waste the estate and give
personal items away, throw personal items away. The Hicks Law Firm never questioned
what was done with the items or the money, never asked for an accounting.
I was present when The Hicks Law Firm made the promises to Mr. Stegeman
that were not kept. I was co-plaintiff in the suit that The Hicks Law Firm is negligent for
not filing.
When Mr. Stegeman tried to get The Hicks Law Firm call the DeKalb County DA’s
office to have criminal charges brought against the predators that committed the
heinous, crimes and felonious acts against Mr. Stegeman, I heard the answer of “no,
you go there on your own”. When Mr. Stegeman called the DA’s office they replied:
“Why didn’t your attorney call us, if there were crimes committed your attorney should
have called us”.
Mr. Stegeman, as well as myself has been personally and financially devastated
by The Hicks Law Firm. Mr. Stegeman’s credibility, reputation and self worth destroyed.
The result of his relationship with The Hicks Law Firm has irreparably destroyed his
person, reputation, credit, in essence his life. He is 100% Federally Disabled.

FURTHER AFFIANT SAYETH NOT,

________________________________
JANET D. MCDONALD

Sworn to and subscribed

Before me this 24th day
Of February, 2006.

_______________________
Notary Public
My commission expires: ________________
 VERIFICATION

Personally appeared before the undersigned officer, authorized by law to

administer oaths, the undersigned Affiant, who on oath deposes and says that the facts
and documents set forth in the foregoing Answer and Counter-Complaint are true and
correct.

___________________________
JAMES B. STEGEMAN

Sworn to and subscribed

to before me
this 24th day of February, 2006.

Seal

__________________________
NOTARY PUBLIC

My Commission expires: ______________

 CERTIFICATE OF SERVICE

I hereby certify that I have this 24th day of February, 2006 served a true and
complete copy of the within and foregoing ANSWER AND COUNTERCLAIM upon the
Plaintiff in this matter by causing to be deposited in the U. S. Mail, proper postage
prepaid, a true copy of same addressed to Plaintiff’s attorney on file as follows:

DAVID L. WHITMAN,
Attorney for the Plaintiff
Post Office Box 1183
Lawrenceville, Georgia 30046

____________________________
JAMES B. STEGEMAN, Pro Se

821 Sheppard Road

Stone Mountain, GA 30083
(770) 879-8737