MITUL R.

PATEL
Plaintiff
v.
MATHEW CHAN
Defendant

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IN THE
MARYLAND CIRCUIT COURT
FOR BALTMORE CITY
Case #: 24-C-16-003573

DEFENDANT'S RESPONSE TO INTERVENOR'S MOTION TO INTERVENE &

MOTION TO STRIKE JUDGMENT

Defendant Matthew Chan of Columbus, Georgia (herein referred as Mathew Chan in the above
caption), pro se, hereby responds to the MOTION TO INTERVENE, MOTION TO STRIKE
JUDGMENT and ANSWER TO DEFENDANT MATHEW CHAN'S MOTION TO VACATE
CONSENT JUDGMENT/ORDER (herein referred to as Intervenors Motion) filed on
September 21, 2016 by Intervenor Mitul R. Patel of Suwanee, Georgia. In the interest of moving
this matter towards conclusion as efficiently as possible, Defendant files this response while his
Motion for Time Extension (sent on October 3, 2016 and entered October 12, 2016) is being
considered.
Since the time Defendant was made aware of this case on September 10, 2016 by
Yelp.com (Def. Motion to Vacate, Exhibit C), there have been disturbingly more questions than
answers regarding the uncovering of the many fraudulent elements within the documents in this
case. Defendant previously referred to the unknown party claiming to be Mitul R. Patel, who
filed and signed fraudulent court documents in his name, as the "purported Plaintiff." Defendant
recognized the possibility that the true Mitul R. Patel, the Intervenor now coming forward, might

not be the same party who filed or signed the original Complaint and Consent Motion entered on
June 15, 2016.
In his initial pleading with this court, Defendant moved to vacate the fraudulentlyobtained consent judgment/order. He further moved for this Court to "report this matter to any
investigative agency or authority this Court deems appropriate for further investigation" and
provide "such other and further relief as the court deems just and proper under these unusual
circumstances." Defendant believed it was the only responsible and reasonable request to make
given the information he had at that time. New relevant information has been obtained since.
In response to Intervenors Motion to Intervene, Defendant asserts the following:
A. Defendant Supports Intervenor's Request to be Named Plaintiff
Intervenor requests designation as Plaintiff in this case so that he may be heard and offer
his statement of facts to "clear [his] name in this Court, to report a potential crime, and fraud that
has been perpetrated upon [him] and this Court, and to report an abuse this Court's legal
process."
Defendant does not object to this request. In fact, Defendant welcomes and supports
Intervenor's participation in this case in an effort to uncover the truth.
B. Intervenor Materially Supports Defendant's Motion to Vacate Consent Judgment/
Order
In Intervenor's Motion (which also serves as his response to Defendant's Motion to
Vacate Consent Judgment/Order), Intervenor materially supports Defendant's Motion and what
he seeks from this Court: 1.) Vacate the existing consent judgment/order, 2.) Report the matter to
an investigative agency or authority for investigation, and 3.) Other and further relief this court
deems just and property under these unusual circumstances.
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Intervenor presents no objections to these three remedies which Defendant requests. In

fact, in light of the Intervenors Motion, which alleges that the matter may have been a fraud on
both purported parties to the lawsuit, it is clear that the entire action should be dismissed and not
just the courts consent judgment/order.
C. Intervenor's Client Relationship with Profile Defenders Bears Further Investigation
In his Motion to Intervene and his affidavit, Intervenor makes one statement with little
explanation or elaboration. He "contracted with SEO Profile Defender Network, LLC to provide
online reputation management services" for his dental practice. Intervenor offers his Exhibit 3
which is essentially one letter written by Mr. Oberman, Intervenors counsel, postal-mailed and
emailed to Mr. Richart Ruddie of SEO Profile Defender Network, LLC (herein referred to as
Profile Defenders).
Through Mr. Oberman's letter, Intervenor points to and accuses Mr. Ruddie and Profile
Defenders of filing a "legal action" in this court against Defendant and forging both Intervenor's
and Defendant's signature on the Complaint and Consent Motion resulting "in the production of a
Court Order." One can infer from presenting Mr. Oberman's letter, Intervenor is attempting to
shift attention and investigations away from himself, towards Mr. Ruddie and Profile Defenders.
Mr. Oberman's letter refers to an unseen "Reputation Management Client Agreement
with SEO Profile Defense Network LLC" in which the firm purportedly "agreed to provide
online management services to Dr. Patel." It is unclear what Intervenor hired Profile Defenders
to specifically do on his behalf or what was disclosed to Intervenor by Mr. Ruddie. Absent
additional sworn statements or exhibits from Intervenor, one can infer that Intervenor hired
Profile Defenders to, in fact, remove Defendant's consumer reviews even if Intervenor did not
necessarily know or direct the specific actions and steps taken.
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In an independent article written by Mr. Paul Alan Levy (Def. Motion to Vacate, Exhibit
S), a notable lawyer with Public Citizen (a consumer-advocacy group based in Washington DC),
Mr. Levy published a letter to Mr. Oberman (Exhibit A) of his thoughts on the matter and his
investigative findings:
"I have qualms about your assertion that, before my blog post was published,
Patel had no knowledge of the lawsuit in Baltimore, for two reasons. First, in the course
of investigating..., I obtained from Yelp copies from Mitul Patel to Yelp, attaching
the Baltimore court order and asking that Chan's Yelp comments be deleted Yelp
has told me that Patel used the same email address that
Unless the
email addresses were spoofed, those emails suggest that your client knew about the
court order and was trying to take advantage of it." [EMPHASIS ADDED]
In email exchanges between a "Mitul R. Patel" (signed "Dr. Mitul Patel") and Yelp.com,
there are three (3)

It should be noted that August 10, 2016 was the day Defendant was made aware of the "consent
judgment/order" and he subsequently emailed his response to Yelp.com (Def. Motion to Vacate,
Exhibit F) alerting them of the fraudulent circumstances behind the obtaining of the "consent"
order. These communications establish that Intervenor knew of the fake court action and used
the fraudulently obtained consent judgment/order.
Because this Court is itself also a victim of fraud through the manipulation of forged
documents and the misuse of its authority through the illicit obtaining of the court order,
Defendant suggests that the Court exercise its authority to request from Intervenor a copy of this
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"reputation management client agreement" and all correspondence between Intervenor and
Profile Defenders to clear up questions relating to what Profile Defenders was actually
contracted to do and to determine the breadth and scope of Intervenors knowledge about the
matter.
Defendant has obtained a copy of Profile Defenders agreement with another client and
presents it to this court as a possible template of the agreement Intervenor signed with Mr.
Ruddie (Exhibit D).
In order for the Court to ascertain "such other and further relief this Court deems
appropriate" as Defendant has requested, Defendant believes the Court should inquire more
information from Intervenor in order to determine a proper outcome.
D. Defendant Believes that Mr. Richart Ruddie and Profile Defenders Are Appropriate
Parties for Further Investigation
Intervenor disclosed to this court the names of Mr. Richart Ruddie and SEO Profile
Defender Network, LLC (aka Profile Defenders). Intervenor also admits to hiring them for
reputation management services for the benefit of Intervenor and his dental business. Through
Mr. Oberman's letter, Intervenor identifies them as the perpetrators of the fraudulent and forged
filings in this case. Defendant supports the inference that Mr. Ruddie, Profile Defenders, and/or
its associates may be likely perpetrators of fraud and other crimes. They are worthy and
reasonable subjects for further investigation.
In his research, Defendant uncovered evidence which lends credence that Mr. Ruddie and
Profile Defenders are appropriate subjects for further investigation. In support of Mr. Oberman's
findings, Defendant has good faith belief that both Mr. Ruddie & Profile Defenders are based in
Florida (Exhibit D).

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On their own website (ProfileDefenders.com), Profile Defenders actively promote a

Complete Removal service and "Lawsuit Removal Service" (Exhibit E). Also on their website,
Profile Defenders promotes a do it yourself kit for those that might want to execute Lawsuit
Removal activities themselves (Exhibit F).
In several press releases and articles promoting Profile Defenders, the "Lawsuit Removal
Service" is described in vague, unspecific terms (Exhibit E). In one press release, Profile
Defenders states, "We cannot let the secret sauce out of the bottle, and never will. In the end, it's
results that matter" (Exhibit G-1). On their own website, Profile Defenders states, "We have to
be vague on the details until we speak with you" (Exhibit E-2).
While details are not provided to the public, various descriptions of Profile Defenders'
Lawsuit Removal scheme gives credence to Defendants belief that the simultaneously-filed
Complaint and Motion for Consent Judgment/Order in this case was part of an illegal scheme to
quietly remove Defendant's negative reviews about Intervenor and his dental business.
The articles and press releases of Profile Defenders' Lawsuit Removal scheme suggest
that it is an expensive "service" and has been in existence since 2012. In one client agreement,
the cost for the service is $6,000/month for 9 months (Exhibit C). There appears to have been
many clients who are willing to pay for, have paid for, and have utilized such a "service." Profile
Defenders claims as of November 14, 2015, there were "375 cases of which 1 [was]
unsuccessful." (Exhibit G-2). It also appears that some clients who wish to utilize the Lawsuit
Removal scheme are sometimes provided with "how-to" instructions. There is a purported doit-yourself kit for individuals who wish to learn how to execute the Lawsuit Removal scheme
themselves (Exhibit F). Most clients seem to be aware that court documents are required to
produce the desired court order although they might not know who actually files or signs such

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documents. It seems highly unlikely that any client, such as Intervenor, would agree to pay
$6,000 per month without being told what methods would be employed and what the anticipated
results would be.
To successfully remove negative reviews from consumer review websites such as
Yelp.com or search engines such as Google requires taking advantage of a policy loophole that
allow for the presentation of a court order proclaiming "defamation" against a party and the
specific removal of "defamatory" hyperlink entries. It is unclear who submits these suspiciouslyobtained court orders to any given website or search engine. But if this case involving Intervenor
and Defendant is any example, Mr. Levy's research suggests that Profile Defenders' Lawsuit
Removal clients are provided the signed court order, so that they can, in turn, submit it to host
websites or search engines containing the undesirable content (Exhibits A, B, & L).
On October 10, 2016, UCLA law professor Eugene Volokh and Mr. Levy jointly wrote,
researched, and published their findings of dozens of suspicious court cases leading to Mr.
Ruddie and Profile Defenders (Exhibit K). Also on October 10, 2016, Mr. Levy published an
additional investigative report regarding his findings on Mr. Ruddie and Profile Defenders as it
relates to this case involving Defendant and Intervenor.
Based on the foregoing information on Mr. Ruddie and Profile Defenders, Defendant
moves that the Court retains jurisdiction over the matter to consider whether pursuing sanctions
is appropriate for their fraud in this court.
E. Defendant Uncovers Similar Suspicious Cases in the Baltimore City Circuit Court
Defendant's research suggests that Profile Defenders' Lawsuit Removal Service scheme
extends much further than this one case. Defendant was able to identify Mr. Ruddie's own case
in the Baltimore City Circuit Court (R. Derek Ruddie vs. Jake Kirschner, Case #: 24-C-15-7-

005620) which uses a suspicious set of similar documents to obtain a "consent" order to remove
negative comments regarding "Daniel Warner Kelly" from RipOffReport.com (Exhibit H).
Defendant was also able to identify another "successful" case in the Baltimore City Circuit Court
(Brian Jones vs. William Conti, Case #: 24-C-15-006945) using a suspicious set of similar
documents to obtain a "consent" order to remove negative reviews and comments from three
different websites (Exhibit I). Both purportedly different plaintiffs in each of these cases
suspiciously have an Owings Mills mailing address.
Defendant was also able to identify a case of a failed attempt to obtain a "consent" order
in the Baltimore Circuit court (Ngodup Norbu vs. Matthew Campbell, Case #: 24-C-16-000250)
(Exhibit J). However, in a case with the same party names and contact addresses, a "consent"
order was successfully obtained in Harford County Circuit Court (Case #: 12-C-16-001959) on
August 8, 2016 (Exhibit J).
In the interest of brevity and keeping the Exhibits from being too unwieldy, Defendant
limited his submissions to these three cases. However, the Court should be aware that Defendant
and others have found and identified many more similarly suspicious cases using similar
documents in this and other courts connected to Mr. Ruddie and Profile Defenders (Exhibit K).
F. Defendant Requests Vacating the Consent Judgment/Order AND Dismissing the
Complaint WITH Prejudice
In his Motion to Vacate, Defendant inadvertently left out the specific request to vacate
the consent judgment/order and dismiss the Complaint with prejudice. Defendant's move to
dismiss the Complaint with prejudice differs from Intervenor's request to dismiss without
prejudice.

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Despite Intervenor's explanation, Defendant is still puzzled why he would want this case
dismissed without prejudice. To summarize Intervenor's points in Points #3 through 6 (Patel
Affidavit), Intervenor comes forward to clear his name and report a potential crime perpetrated
within this court under his name. He states he did not file, sign, or authorize anyone to file or
sign on his behalf either the Complaint or the Consent Motion in this case. Intervenor further
agrees there have been numerous frauds and forgery against both parties in this case.
This lawsuit was brought without any legitimate basis and was done in a fraudulent,
unlawful way. Further, it appears that, at the very least, Intervenor took questionable advantage
of the illicitly-obtained court order for his own gain because it was he who sent it to Yelp.com
for the specific purpose to remove Defendant's consumer reviews of Intervenor supposedly
without Intervenor's knowledge (Exhibit B). Based on these uncovered facts, Intervenor should
not be allowed another opportunity to bring this matter into this court.
The central assertion and reason for special appearances of both Defendant and
Intervenor in this court is that this entire case was born out of fraudulent filings of the Complaint
and Consent Motion in the names of both Intervenor and Defendant. Any assertions made within
the fraudulent Complaint (which Intervenor states in his Affidavit that he would never have
authorized) have no relevance or standing except it was a concocted basis for the fraudulent
obtaining of a consent judgment/order in this court.
Intervenor's request that this matter be dismissed without prejudice potentially allows him
a "second bite at the apple." It is also contrary to his stated interest of "clearing his name" as well
as his statement that he "would have never authorized the filing of this Complaint." Granting
Intervenor's request to dismiss this matter without prejudice allows for the possibility that
Intervenor could reopen, litigate, and otherwise take questionable advantage of this illicitly-

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brought case in this Maryland court. Defendant has no contact with the State of Maryland and
would not be subject to the jurisdiction of this court if a new action were commenced.
Should any residual matters pertaining to this case continue (beyond vacating the consent
judgment/order), it does not prohibit Intervenor from further addressing this court through
additional pleadings in this court. Vacating the consent judgment/order and dismissing the
Complaint with prejudice rightly disposes the matter once and for all.
Based on the foregoing, Defendant requests this Honorable Court for the following:
Vacate the "Order Granting Consent Motion for Injunction & Final Judgment;" dismiss the
Complaint with prejudice; and report/refer this matter to any investigative agency or authority
this Court deems appropriate for further investigation.
In the matter of Mr. Ruddie and Profile Defenders, Defendant moves for this Honorable
Court to retain jurisdiction to consider whether it should pursue sanctions against them because
of their fraud in this court and for such other and further relief as the court deems just and proper
under these unusual circumstances.
This 14th day of October, 2016.
Respectfully submitted,
Matthew Chan, PRO SE
P.O. BOX 6865
COLUMBUS, GA 31917
Phone: (762) 359-0425
Email: matt30060@gmail.com

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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 14th day of October, 2016 mailed a copy of the
foregoing DEFENDANT'S RESPONSE TO INTERVENOR'S MOTION TO INTERVENE
& MOTION TO STRIKE JUDGMENT and EXHIBITS (A-L) via First Class postage
prepaid to the following:
James G. Maggio & Steven D. Shemenski
802 Ingleside Ave.
Catonsville, MD 21228

Matthew Chan, PRO SE

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MITUL R. PATEL
Plaintiff
v.
MATHEW CHAN
Defendant

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IN THE
MARYLAND CIRCUIT COURT
FOR BALTMORE CITY
Case #: 24-C-16-003573

[PROPOSED]
ORDER ON MOTION TO VACATE CONSENT JUDGMENT/ORDER
This matter having come before this Honorable Court having heard: DEFENDANT'S
RESPONSE TO INTERVENOR'S MOTION TO INTERVENE, MOTION TO STRIKE
JUDGMENT, AND ANSWER; Intervenor MITUL R.PATEL's Motion to Intervene, Motion to
Vacate Consent Judgment/Order and Answer to Defendant's Motion to Vacate Judgment/Order;
and Defendant's Motion to Vacate Consent Judgment/Order, hereby
ORDERED that Intervenor MITUL R. PATEL's Motion to Intervene be and is
GRANTED; and it is further
ORDERED that Intervenor MITUL R. PATEL be designated as Intervenor Plaintiff; and
it is further
ORDERED that Intervenor/Plaintiff MITUL R. PATEL's Motion to Vacate the Consent
Judgment/Order be and hereby is GRANTED; and it is further
ORDERED that Defendant MATHEW CHAN's Motion to Vacate Judgment/Order be
and hereby is GRANTED; and it is further
ORDERED that the Consent Order Granting Consent Motion for Injunction and Final

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Judgment entered by this Honorable Court on June 15, 2016, be and hereby is VACATED; and it
is further
ORDERED that this matter be and hereby is DISMISSED WITH PREJUDICE.

So ORDERED this ________ day of ____________________, 2016.

______________________________
JUDGE
Circuit Court of Baltimore City
CLERK:
Please mail copies of this Order to:
Matthew Chan
P.O. Box 6865
Columbus, GA 31917
Pro Se Defendant
James G. Maggio, Esquire
802 Ingleside Ave.
Catonsville, MD 21228
Attorney for Mitul R. Patel

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