CITY OF DALLAS

ETHICS ADVISORY GOMMISSION

COMPLAINT FORM
CITY OF DALLAS

Please type or print legibly in blue or black ink.

NOTE: FILING A COMPLAINT THAT FALSELY ACCUSES SOMEONE OF A VTOLATION

OF THE ETHICS CODE MAY RESULT IN GRIMINAL PROSECUTION OR SANCTIONS OF
ANYONE WHO KNOWINGLY MAKES A FALSE ACCUSATION.
PART

A.

COMPLAINANT INFORMATION

1. Your full name (identifies you as the Complainant):

Thomas Carse on behalf of my client Matisha Ward

2. Your

residence address (Street, City, State, and Zip Code):

7039 Mossvine Road, Dallas, Texas 75254

3. Your

business address (Street, City, State, and Zip Code):

6220 Campbell Road, Suite 401, Dallas, Texas 75248

4.

Preferred telephone number:

Gil-\ nome

Business (circle one)

5. Alternate telephone number:

g72-503-6338

cetr

Home

dsth(circre

one)

6. Emailaddress:
tom@carselaw.com

City of Dallas
City Secretary's Office

1of 5

Complaint Form
Ethics Advisory Commission
REV'10/15

I CERTIFY THAT I HAVE READ THIS GOMPLAINT, I FULLY UNDERSTAND ITS

CONTENTS, AND I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF
THE STATE OF TEXAS THAT THE COMPLAINT STATES A VIOLATION OF CHAPTER 12A
OF THE DALLAS CITY CODE, THAT THIS COMPLAINT IS NOT BEING PRESENTED FOR
ANY IMPROPER PURPOSE, AND THE FOREGOING STATEMENTS AND EVIDENCE ARE
TRUE AND CORRECT OR, TO THE BEST OF MY KNOWLEDGE, ARE SUPPORTED BY
CREDIBLE EVIDENCE FORMED AFTER AN INQUIRY REASONABLE UNDER THE
CIRCUMSTANCES. I UNDERSTAND THAT A COPY OF THIS COMPLAINT WILL BE SENT
TO THE CHAIR OF THE ETHICS ADVISORY COMMISSION AND TO THE INDIVIDUAL
CHARGED IN THIS COMPLAINT. ALL PAPERS AND COMMUNICATIONS RELATING TO A
COMPLAINT MUST BE TREATED AS CONFIDENTIAL LAW UNLESS REQUIRED TO BE
MADE PUBLIC BY THE PUBLIC INFORMATION ACT (CHAPTER 552, TEXAS
GOVERNMENT CODE) OR OTHER AppLtCABLE LAW.
Signature

Before me the undersigned authority, on the 26th day of Auqust , 2016, personally
om L/arse.
Carse
appeared, .lTom
, known to me to be the person whose name is
subscribed hereto, and being duly sworn stated that such facts are true and correct, or, to the
best of his/her knowledge, formed after an inquiry reasonable under the circumstances, the

factual contentions are supported by credible evidence su

in and with the complaint.

Notary Public

Dallas

County, Texas

[,IY COMMISSION EXPIRES

Novembor20,2017

My Commission expires:

November 20,2017

iglltote:, Section 3.2 of the Ethics Advisory Commission Rules of procedure states that
"supplements to a complaint may only be filed within seven days after the
city secretary's
acceptance of the original completed complaint.,,

S.n9-u]{.voy_f,9y9 any questions concerning this form, please contact the City Secretary,s
Office,
at (2141670-3738 during regular business hours (g:1Sam 5:1Spm).
-

Upon completing ALL sections of this form, please hand deliver or send by certified mail with
any attachments to:

Office of the City Secretary

CIry HALL
1500 Marilla Avenue - Suite SDS
Dallas, TX 75201
City of Dallas
City Secretary's Office

5of5

Complaint Form
Ethics Advisory Commission
REV 10/15

I CERTIFY THAT I HAVE READ THIS COMPLAINT, I FULLY UNDERSTAND ITS

CONTENTS, AND I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF
THE STATE OF TEXAS THAT THE COMPLAINT STATES A VIOLATION OF CHAPTER 12A
OF THE DALLAS CIry CODE, THAT THIS GOMPLAINT IS NOT BEING PRESENTED FOR
ANY IMPROPER PURPOSE, AND THE FOREGOING STATEMENTS AND EVTDENCE ARE
TRUE AND CORRECT OR, TO THE BEST OF MY KNOWLEDGE, ARE SUPPORTED BY
CREDIBLE EVIDENCE FORMED AFTER AN INQUIRY REASONABLE UNDER THE
CIRCUMSTANCES. I UNDERSTAND THAT A COPY OF THIS COMPLAINT WILL BE SENT
TO THE CHAIR OF THE ETHICS ADVISORY COMMISSION AND TO THE INDTVIDUAL
CHARGED IN THIS COMPLAINT. ALL PAPERS AND COMMUNICATIONS RELATING TO A
COMPLAINT MUST BE TREATED AS CONFIDENTIAL LAW UNLESS REQUIRED TO BE
MADE PUBLIC BY THE PUBLIC INFORMATION ACT (CHAPTER 552, TEXAS
GOVERNMENT CODE) OR OTHER APPLICABLE LAW.
Signature

Before me the undersigned authority, on the 26th day of Auqust , 2016, personally
orn, uarse.
Carse
appeared, .lTom
, known to me to be the person whose name is
subscribed hereto, and being duly sworn stated that such facts are true and correct, or, to the
best of his/her knowledge, formed after an inquiry reasonable under the circumstances, the

factual contentions are supported by credible evidence su

in and with the complaint.

Notary Public

Dallas

County, Texas

fuIY COMMISSION EXPIRES

November20,20l7

My Commission expires:

November 20,2017

Srcigllgte:,

Section 3.2 of the Ethics Advisory Commission Rutes of procedure states that
"supplements to a complaint may only be filed within seven days after the city
secretary,s
acceptance of the original completed complaint.,,

S.h-o]]9.Voy f,9y9 any questions concerning this form, please contact the City Secretary,s
Office,
at (2141670-3738 during regular business hours (g:15am 5:1Spm).
-

Upon completing ALL sections of this form, please hand deliver or send by certified mail with
any attachments to:

Office of the City Secretary

CITY HALL
1500 Marilla Avenue - Suite 5DS
Dallas, TX 75201
City of Dallas
City Secretary's Office

5of5

Complaint Form
Ethics Advisory Commission
REV 10/15

August 26, 2016

VIA CMRRR: 7002 0510 0003 9881 7760 & 9590 9402 1645 6053 2357 67
Chief David Brown
Dallas Police Department
1400 S. Lamar
Dallas, Texas 75215
RE: Barratry complaint re: Tiffinni Arena Young and Christopher Moore Chestnut
Dear Chief Brown:
On behalf of my client, Matisha Ward, I am submitting the enclosed documents as a
complaint for review and handling by your agency. The allegations suggest, at a
minimum, the existence of a criminal conspiracy between a Dallas city councilwoman,
Tiffinni Young and Christopher Chestnut, an attorney not licensed in Texas, actively
soliciting my client for professional employment.
My client believes she was exploited by both individuals and in so doing they may likely
have violated Texas Penal Code 38.12.
Sincerely,

Tom Carse

August 26, 2016

VIA CMRRR: 7002 0510 0003 9881 7777 & 9590 9402 1645 6053 2357 50
Susan Hawk District Attorney
Frank Crowley Courts Building
133 N. Riverfront Boulevard, LB 19
Dallas, Texas 75207
RE: Barratry complaint re: Tiffinni Arena Young and Christopher Moore Chestnut
Dear Ms. Hawk:
On behalf of my client, Matisha Ward, I am submitting the enclosed documents for
review and handling by your agency. The allegations suggest, at a minimum, the
existence of a criminal conspiracy between a Dallas city councilwoman, Tiffinni Young
and Christopher Chestnut, an attorney not licensed in Texas, actively soliciting my client
for professional employment and in doing so may likely have violated Texas Penal Code
38.12.
Sincerely,

Tom Carse