IN

THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

THE LUO GROUP, LLC D/B/A )
TAGO INTERNATIONAL
CENTER,
) CIVIL ACTION NO.
1:21-cv-02588 MHC-RDC
GODFREY TAGO,
)
Plaintiffs,
v. )

ANDREW PERKEL, )

SC APARTMENTS, LLC )
D/B/A BOLTON VILLAGE

AND )

LANDLOCKED, LLC )
D/B/A BOLTON
VILLAGE )

Defendants, )

DECLARATION OF CHRISTOPHER KING, J.D.1

I THE UNDERSIGNED come now before the Court on Oath and
subject to the Pains and Penalties of Perjury to solemnly aver:
First of all the anomalies that I have personally witnessed give me great
concern, to wit:

1
Plaintiff noted last week that he was issuing a preliminary statement to be followed by a more detailed
statement. Plaintiff concurs in this filing and will be present -- along with me – at the upcoming “Emergency”
Status Conference. To be absolutely clear I am not Counsel for Mr. Tago; I am a friend of Mr. Tago and his
friend Devon Sawyer as noted within.

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 a. Plaintiff was unaware of pending Admission Requests (100+ requests)
until another Attorney happened to check the file.

b. Plaintiff was unaware of this pending Motion until I found it on Pacer;
Attorney Carlton verbally communicated he was going to withdraw but
never served him the Motion nor did he give him a copy of the Court’s
outstanding Order on the matter; again I found it on Pacer the same way
I found documents for Attorney Carlton when he claims to have joined
this case as he said he could not locate them on Pacer.

c. Neither Attorney Matthew Carlton has explained to me why Plaintiff
does not have a copy of the Exhibits from the first half of his continued
Deposition despite at least half a dozen demands for same on behalf of
Plaintiff.


My Background

1. I am an investigative journalist former Assistant State AAG and Civil
Rights Attorney and manager of a Title Company. Prior to that I
edited a Statewide Black-owned newspaper (Ohio Call & Post) and
wrote as a daily beat reporter for the Indianapolis Star. As a Trial
Attorney I have sued and settled on State and Federal housing
discrimination cases for individuals and classes of people (frail
elderly handicapped) as briefly seen below in Hamm v. City of
Gahanna.

2

2. I was the first citizen I have also been awarded a Public
Commendation (essentially a Key to the City) by the Nashua, NH
Aldermanic Chamber and then-Mayor Bernard Streeter. I have also
investigated and run video of the Revere Dan Talbot police murder
trial. I have also run courtroom video on no less than three
multimillion dollar Jury verdict cases involving Joanna Marinova v.
Boston Herald, Scott Hyman v. Hemlock Association and Gianismidis
v. Palangas.

Double Homicide in NH + Screenplay “Circle of Stones” working title.
https://kingcast955.wixsite.com/circle-of-stones

Marinova
https://www.youtube.com/watch?v=ZlaHj9QN9yc&t
Hyman
https://www.youtube.com/watch?v=AsccNhDcsUQ

Gianismidis
https://www.youtube.com/watch?v=vy9cDADQLfw

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 3. I also investigate mortgage fraud and have run courtroom video in
six (6) states, one investigation ultimately resulting the suicide of a
lawyer engaging in misuse of client funds and failing to zealously
represent.

https://www.youtube.com/watch?v=CvFj9TRTghg
George Babcock Returns $2000 retainer to Martha Brunzos on
Bogus Nationstar Foreclosure


https://www.youtube.com/watch?v=W5Jyb6bH4Bg&t=0s
Pro Se Plaintiff Nails Nationstar in Federal Dual Tracking
Summary Judgment Motion.

The Intercept
https://theintercept.com/2015/09/18/leaked-seattle-audit-
concludes-many-mortgage-documents-void/
*********

4. I have known of Plaintiff (A/K/A “Tago”) for a few years indirectly
because of our mutual friend Devon Sawyer, J.D. Mr. Sawyer and I
have worked together on entertainment questions, legal issues and
more; in fact we shared a condo while we both worked on a wireless
project with AT&T in Atlanta. He worked with me at American Tower
Corp in 2001-2002 when I drafted a complaint on behalf of my
trainees that resulted in a $290,000.00 finding in their favor by the
United States Department of Labor:

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 5. Mr. Sawyer told me that Tago was having some problems with a
lawyer and some folks now known to me as Defendants in the case at
bar. He indicated to me that he has no reason to believe that Tago
would ever knowingly (or unknowingly) violate the law in any
measure.

Matthew Carlton, Esq.

6. I joined the case to help Tago investigate and to understand the
(in)actions of a former Attorney and to help him find a new Attorney,
one Matthew Carlton.

7. As such I interviewed him with his permission, live on the phone
with Tago. He stated, inter alia, that he would take this case to trial
on the $5,000.00 retainer excepting expenses of course for
Depositions.

8. He spoke of being aggressive and keeping ahead of the game and
issuing Discovery Demands and interviewing multiple key eyeball
and other witnesses; ultimately he never lifted a finger to do any of
those things even though Tago and I had specifically told him about
the abject failure of his prior Counsel on the very same issues.

9. Attorney Carlton knew that prior Counsel had failed to represent him
(Appendix A)

10. After a Suspended Deposition Plaintiff and I repeatedly asked for
these documents from both Counsel because Plaintiff claims he was
shown a false Exhibit where he made Anti-Semitic statements
(Appendix B).

11. I grew up in a largely Jewish environment and I have read the actual
comment from Tago that was on his Facebook page and do not find it
to be Anti-Semitic or anything that a lawyer should use in order to
distance himself from a Client.

5

12. Tago represents that his Jewish friends and clients do not find him to
be Anti-Semitic at all; he hosts Bar and Bat Mitzvahs and we have
both told Attorney Carlton to pull statements from these people,
instead citing to one comment on a Facebook page where Tago stated
that Jews have stereotyped Blacks in Hollywood, A KNOWN, WELL-
DOCUMENTED FACT OF WHICH ALL OF MY JEWISH FRIENDS
ACKNOWLEDGE.

13. However, the statement attributed to Plaintiff is not what was
written in the original Facebook post that I reviewed.

14. This is why I demanded half a dozen times from both Counsel to
provide a copy of *ALL* Depo Exhibits used to date, a typical demand
and one incumbent of any Attorney attempting to claim Zealous
representation.

15. To date neither Counsel has provided these documents yet both of
them conspired to make Plaintiff appear to finish his Deposition right
before a scheduled State Court Hearing.

16. Also during the first half of the Continued Deposition Plaintiff
witnessed Attorney Carlton speaking in hushed tones with Opposing
Counsel *AND THEIR CLIENT* outside of his presence.

17. Moreover, Attorney Carlton knew of a purported Insurance red
herring and that Tago did not fabricate anything but he ignored it
repeatedly (Appendix C).

18. Told Tago after Habit Evidence (Appendix C).

19. On information and belief the Insurance carrier lied about refusing
futher service to Tago because of his alleged fraud: Tago is still a
customer with that company for his home and vehicle so they did not
drop him.

20. While I was not present for these exchanges I believe Tago when
he states that Defendants instructed Plaintiff to start work on the
Premises without Permits as I have seen emails indicative of this.

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21. While I was not present for these exchanges I believe Tago when
he states that other Tenants have been affected “build out first” and
that he instructed his Attorneys to get statements but they failed to
do so.

22. I am one of the friends who discovered relevant recent law that
could be influential if not dispositive of this case should Tago
ever actually get the Discovery and zealous representation that
this case demands.

U.S. v. Crimson 1:20-cv-02050-MHC (NH GA 2022)(Consent Decree)

https://www.justice.gov/crt/case-document/file/1509886/download
U.S. v. Price 5:20-cv-00062-EKD (WD VA Harrisburg 2020) (Consent Decree)
https://www.justice.gov/opa/press-release/file/1320511/download

23. At this point I am preparing to come down there and start
interviewing witnesses because frankly, I smell a rat. And the rat is
not Tago.

Lucas Bradley, Esq.

24. Lucas Bradley is Counsel for Defendants. Curiously he emailed me
this month to inquire as to my intentions but did not initially follow
up with me when I asked him how he got my email address.

25. He eventually told me that he obtained it by running a Google search
of my phone number but I think he obtained it from Attorney
Carlton.

26. In any event he also telephoned me and when I answered the call he
stated – falsely – that he “[H]ad just received a call from this
number.”

27. I had not telephoned him, ever.

28. He never called back.2
2 Today I saw evidence of another of the Perkel/Landlocked Legal Representatives falsely accuse another

Attorney of ghostwriting for Tago, another in their abusive tactic I have witnessed.

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 FACT/OPINION

I have not witnessed such a Dereliction of Duty by an Attorney in my
lifetime, excepting on lawyer in New England (Rode Island) who was taking
client funds on Foreclosure cases; I did a video about him and shortly
thereafter he committed suicide. I have also helped another friend Shelley
Erickson in Washington obtain $10,000.00 from the Bar Association against
Jill Smith see below.
I take matters of zealous representation quite seriously and the conduct
of Attorney Carlton in this case falls well short of any recognizable standard;
as such I will be going quite public with this Declaration. I have a Fourth
Estate Free Press duty to publish these facts and I am aware of these duties as
a lifelong journalist: I was a daily reporter with the Indianapolis Star, a weekly
editor with the Ohio Call & Post and scores of freelance and Courtroom video
publications over the past thirty (30) years.
*************

STATE OF WASHINGTON

COUNTY OF KING

FURTHER AFFIANT SAYETH NAUGHT

__________________________________________
Christopher King, J.D.
[email protected]
617.543.8085m

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On this 13th day of December came before me Christopher King, on having
shown me a copy of his U.S. Passport, and did solemnly swear to the Truth of
the foregoing.

___________________________________________
NOTARY PUBLIC

MY COMMISSION EXPIRES:______________________