Defendants JoEllen Shannon and Rosemary Foster are the agents for each other (Verified complaint and exhibits) for the breach of contract therefore plaintiffs are entitled to compensatory damages and consequential, foreseeable and incidental damages.

As of this date, defendants has used plaintiffs’ client list and have converted 6 clients and continue to mine the client list with confidential client information to convert additional clients.       Each Social Security client is worth $6,000. (Exhibit 1, Social Security regulation.)   Defendants have stolen plaintiffs’ client files and therefore the original attorney fee contract cannot be produced for the court. (Exhibit 2)  As defendants stole 10 clients at a rate of $6,000 each, therefore, defendants to this date have damaged plaintiffs at $60,000.

  Defendant Foster was employed to become the “holding attorney” for retiring attorney, Plaintiff Daniel A. Bernath pursuant to an agreement between the Social Security Administration and Bernath (Exhibit 3).  Plaintiff Martha   is set to take the SSA test to become an advocate before SSA and the clientele would then be put into  ’s name as per the agreement with SSA.  Based on the representations with Foster an agreement was entered into and all clients were placed into the name of Rosemary Foster (Exhibit 4).  Additional staff was hired, postage purchased, envelopes and stationary purchased, staff used to mail to clients for their signatures, open the mail, process the mail and file with the Social Security offices.  This cost was $10,745 Exhibit 5).

Thereafter, Foster renounced her agreement with plaintiffs, began to call all clients and state, without spending the 7 years and $750,000 to build the law practice, that each of plaintiffs’ 3600 clients were actually HER clients now.  An additional $10,750 was spent to put the claimants into another holding attorney’s name.

  A complaint was made to the Oregon Bar for Foster’s soliciting of clients right in the office of Social Security Court, using a “runner” and “capper” to contact plaintiffs’ clients directly to sign up with the “new outfit.” 

When a request for a response from Foster was requested, Foster RESIGNED from the Oregon Bar! (Exhibit 6 and Exhibit 7) As such, it is an admission by conduct that all of the allegations within the complaint are true and as she knows she will be disbarred or suffer a great lose ethically (as Judge Letourneau warned her at the TRO hearing on June 10, 2011[1]) she merely took away the Oregon Bar’s power to protect the citizens of Oregon from her lawyer soliciting, capping and running.  Incidentally, after taking plaintiffs’ client list, Foster and Shannon contacted clients and lied and terrified plaintiffs’ clients by stating:
“if you go with Foster and Shannon then you’ll get a hearing sooner on your disability case. 
If you stick with Bernath and  , your case will start all over again at the ‘back of the line.’ adding another two years to your wait for a hearing.”(exhibit 8)[2]