“Plaintiffs, Terance Healy and Todd M. Krautheim,
on behalf of Mark McBride, Helene Finno, Darren Moyer, Karen Baxter Randall, Michael LaBate
and the People of the United States of America hereby present for the consideration and review to this Honorable Court their Complaint – Constitutional Challenge of Rule 1.6 of the Code of Professional Conduct.”

Mark McBride is an essential party in the Challenge. He is presently unavailable to sign or authorize his consent or add his case to the Constitutional Challenge.

Helene Finno is a friend whose support has always been there and never failed.

Darren Moyer is a friend whose support has always been there and never failed.

Michael LaBate is a friend whose support (mostly by phone) arrived when needed most and has never failed.

Why Karen Baxter Randall?

Karen Baxter Randall believed in me, and she believed in the system… even when forced to carry out the judges improper instructions. Karen is an employee in the Court Administration office at Montgomery County Courthouse.

While Karen watched the system abuse me since 2007, she gave me the strength to make it through the procedural paperwork required.

And then there was that one day…
Homeless. Destitute. Exhausted. Alone. Beaten up. When I turned to face Karen just to file some paperwork, my eyes filled with tears and I wanted to turn and run. Karen stood firm demonstrating her belief in justice. Karen was resolute. Karen was lawful. Karen did her job professionally and with all the empathy permitted under the circumstances. I was surrounded by deputies who had been improperly ordered to remove me from the courthouse because they had been told I had no business there. Karen held my hand and looked me directly in the eye. Karen indicated that I WOULD GET MY DAY IN COURT.

Karen Baxter Randall has my sincere respect. Karen Baxter Randall demonstrated her unwavering belief in justice. As Todd & I were writing the closing paragraph, it was clear that her name belonged among the others on behalf of whom we have filed the Constitutional Challenge. Karen Baxter Randall, you have our admiration, our respect and our gratitude.

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