AFFIDAVIT OF JANET D.

MCDONALD

NOW COMES Janet D. McDonald and after being first duly sworn , deposes and
says that:
My name is Janet D. McDonald, I am over 18 years of age and competent in all
respects to testify regarding matters set forth herein. I am a legal, law abiding, taxpaying
citizen and a third party to all matters concerning the Estate of Jean S. Caffrey, beloved
aunt of James B. Stegeman.
I have firsthand knowledge of the following facts below. These statements are
back up by Certified Bank Records, Certified Copies of Depositions, Transcripts, etc.

 In 1997 Mr. Stegeman and Ms. Caffrey sold jointly owned property.
 A new account was opened Jean S. Caffrey AND James B. Stegeman Joint
Tenants With Rights of Survivorship at First Union Bank and First Union
Securities now known as Wachovia Bank and Wachovia Securities.
 Ms. Caffrey bought a home four houses down from the one that Mr. Stegeman
and I own.
 November 1998, Ms. Caffrey fell and broke her hip. At Ms. Caffrey’s request, I
began taking care of her all of her needs.
 January 1998 Ms. Caffrey signed a Durable Power of Attorney naming Mr.
Stegeman, signed and Notarized by Hilda Lesley, head Social Worker Northlake
Regional Hospital. Ms. Lesley questioned Ms. Caffrey in depth about the Power
of Attorney to make sure that Ms. Caffrey understood what it said. Ms. Caffrey
on numerous occasions confided to James and me that she had a fear of losing her
mind. She feared that Mavis Turner would take advantage of her or that
everything she had would end up being controlled by DeKalb County. Sadly
enough, her fears had warrant as that is exactly what happened.
 April 1999 Ms. Caffrey assigned me to replace her name on the Wachovia
Securities accounts at the time of my choosing; by signing a Notarized Directive
per Wachovia’s guidelines for such transactions.
 January 2001 my mother informed family that she had been diagnosed with lung
and bone cancer, given five years to live.
 March 2001, Ms. Caffrey suffered a stroke upon our return from grocery
shopping.
 I requested the transfer of Wachovia per my Directive from Ms. Caffrey.
 Wachovia had the account set up incorrectly, Mr. Busch was informed and it could
be completed at a later date..
 Within a couple of months of Ms. Caffrey’s stroke, Mavis Turner makes a false
complaint to DeKalb County DFCS that Ms. Caffrey had fallen and was being
held against her will. Ms. Al-Kadhja appeared one morning with Stone Mountain
Police Dept. as I was fixing to take Ms. Caffrey to physical therapy. According to
Doug Stegeman in Wisconsin, DFCS had called, the investigation showed no
wrong doing.
 February 2002, my mother passed away after only one year.
 FROM THIS POINT ON, MR. STEGEMAN’S AND MS. MCDONALD’S RIGHTS
WERE VIOLATED:
Mr. Stegeman is 100% Federally disabled, he receives Supplemental Security Income,
which is not very much to live on. Mr. Stegeman has Civil Rights granted under the
ADA, he has Disabled and Elder Rights, Constitutional Rights and Human Rights. All of
these rights have been violated the fullest extent! The following will show the extent
Rights Violations suffered over the years that have passed since June 2002:

 June 2002, I received a call from Al Thompson who told me that Ms. Caffrey, was
calling for help it was around 7:30 a.m. I arrived within 3 minutes at Ms.
Caffrey’s home.
 Ms. Caffrey was on blood thinner medicine, bruised very easily and had extreme
osteoporosis. Rather than chance hurting or bruising her, I called an ambulance to
help pick her up. After the past accusation to DFCS, I was not going to be
accused of abusing Ms. Caffrey by a bruise on her.
 Ms. Caffrey’s Primary Physician had diagnosed her as mid to mild cognitive, had
symbolic disorder and mild senility after her stroke in 2001.
 June 12, 2002 I informed Mr. Stegeman that I would like to finish the Wachovia
transfer.
 Neither James nor myself had been allowed to see Ms. Caffrey since the
ambulance took her to the hospital June 2002. We were told that we would be
arrested if we tried to see her or interfered. With James’ Durable Power of
Attorney, and Healthcare Directive, it was illegal to even treat Ms. Caffrey.
 June 13, 2002 Hearing at Emory Northlake Hospital. The accusations against Mr.
Stegeman were fraud and elder abuse. The accusations were totally untrue and no
evidence was presented at the hearing to show any wrongdoing by Mr. Stegeman.
 Law mandates that concrete proof be provided at these hearings. According to
The Secretary of State, the rules governing proper procedure for DFCS is to have
Mr. Stegeman arrested after their investigation if such is true. There cannot be
concrete proof of illegal activities without an arrest. Mr. Stegeman was found
guilty at the hearing which is a violation of his Rights of Due Process of Law.
 Our accounts were seized violating both of our rights. Therefore the agency that
is set up to protect disabled and elderly rights and The Probate Court of DeKalb
County violated Mr. Stegeman’s rights.
 Ms. Caffrey was appointed an Emergency Guardian of Property for a Gravely
Incapacitated Adult, John C. Joyner appointed by DeKalb County Probate Court.
Mark Stephen had the Court records sealed to hide her mental incapacity from
public view. What labeled Ms. Caffrey as “Gravely Incapacitated” was never
known by family.
 Mr. Stegeman and I found that the legal transfer of accounts at Wachovia had
been reversed. Mr. Busch said he didn’t know why. James Stegeman and I owned
several items in Ms. Caffrey’s home: full set of kitchen cabinets that had been
taken from the property that Caffrey/Stegeman sold in 1997, two freezers one of
which containing deer meat worth $2500.00 and other items these all disappeared
even though the items were documented. The fact that we tried on numerous
occasions to collect the items is documented.
 Dennis McCarthy owned an aquarium stored at the Caffrey home valued at $850
we had to reimburse him for.
 Ms. Caffrey was taken, hidden from all family members. Even though I had
called every “home” within a 75-100 mile radius, since where she was hidden was
told that there were no living relatives and no next of kin, I was told she was not
in the home. Doug Stegeman in Wisconsin and his wife also tried to find where
Ms. Caffrey was. Mavis Turner told them that she would get back with them,
never did. Mr. Robert Turner told them that he did not know where she was. Mr.
Turner admitted this when he responded to the GA Bar complaint filed against
him.
 Mr. Stegeman and I had attorney Mr. Sam Appel freeze accounts at Wachovia
which was confirmed by Cindy Wall, regional manager.
 Mr. Joyner and his attorneys Mr. Burnett and Mr. Turner had all been approached
by Mr. Appel to “let’s sit down and prove who the money belongs to”. Mr. Appel
was refused his offer.
 According to Certified Bank Records, Mr. Joyner had already changed the
address, and names on the account, removed funds and had Mutual Funds
reissued and sold. The account before transfer was Jean S. Caffrey AND James
B. Stegeman Joint Tenants With Rights of Survivorship. After legal transfer of
ownership it was Janet D. McDonald AND James B. Stegeman Joint Tenants With
Rights of Survivorship. Mr. Joyner illegally changed the name, changed the
address and committed grand larceny, he should be arrested.
 Mr. Appel had submitted to Mr. Turner, Mr. Burnett and Mr. Joyner my Notarized
Directive. They chose to ignore the Legal Notarized Directive.
 Mr. Appel also assured me that he had discussed the RV and the payments with
Mr. Joyner’s attorney Mark Burnett and then his attorney Mr. Turner. That was
also ignored.
 I was making the RV payment and paying all attorney fees for Mr. Stegeman.
Since Mr. Stegeman and I owned the Wachovia accounts and they were frozen,
we thought, and Mr. Stegeman was co-signer of the RV. Mr. Stegeman was
executor and sole beneficiary of the Caffrey Estate and the house Ms. Caffrey
owned backed up the debt.
 I paid Pattie Williams to file suit to prove ownership of the accounts. By the time
she got the paperwork together, Mr. Joyner filed suit against Mr. Stegeman alone.
The knowledge of my claim to account continued to be ignored by Joyner and
Turner, I guess they knew that they could not disprove the claim and Mr. Joyner
had already been taking from accounts according to Certified Bank Records.
 Mr. Joyner petitioned to sale the Caffrey home, Ms. Williams agreed to put a lien
on the property to insure the RV would be paid for. Ms. Williams failed to do so.
 Mr. Turner admits that Ms. Williams had asked on more than occasion to depose
Ms. Caffrey while Ms. Caffrey was alive, this was not permitted just as family
and friends were never permitted to see her again while she was alive. There had
been eight to nine months to dispute my ownership of the accounts. Yet there was
never a deposition nor Affidavit by Ms. Caffrey on the matter.
 Ms. Caffrey died April 17, 2003 after being in a coma for five days without any
knowledge given to family or the friends that we knew about the coma or the
death. Later it was mentioned aloud that Mr. Stegeman, his brother nor myself
had attended the funeral. You cannot go if you do not know she is dead.
 Mr. Stegeman and I found out Ms. Caffrey passed away four days later at a
Motion to Compel hearing on April 21, 2003. Judge Hunter gave Mr. Turner ten
days to legally substitute Ms. Caffrey.
 It is looked upon quite unfavorably to all that have heard this story that family
was not contacted, given a chance to see Ms. Caffrey while in a coma dying, bury
“one of our own”, and persecuted for keeping a promise to a beloved Aunt. Mr.
Lillig even had Ms. Caffrey buried using the wrong name.
 Ms. Caffrey had been promised that she would be cremated and taken to the Wolf
River in Wisconsin to be with her Father, Mother and Brothers. A horrible
injustice has been done! Ms. Caffrey despised her late husband, this was common
knowledge. Therefore, if it was in her Will, either she had totally lost her mind or
without her glasses, she had no idea what she was signing, if she even signed it.
 Mr. Lillig lied about the residence at time of death listing the property that had
been jointly owned and sold in 1997. He knew her proper address.
 The Medical Examiner in Cobb County told me that “considering the amount of
damage to her face and head”. I am outraged that The Probate Court of DeKalb
County put this woman in a position to die from such. I am outraged that because
of the Probate Court of DeKalb county, Mr. Lillig the Pastor, Mr. Joyner,
Guardian and Mr. Turner Attorney have manipulated the system to this point.
 We found out later that Mr. Tuner wrote to Judge Hunter and complained that the
law gives now less than 30 days and asked for the extra time. Judge Hunter
permitted the extra time.
 Mr. Turner writes to Judge Hunter again and complains that since there was a
Caveat filed, that it would take the usual 180 days to have Mr. Lillig names as
Personal Representative and would asked for more time. Judge Hunter went
ahead and granted the substitution even though there were two Wills and I was the
only one that could have legally replaced Ms. Caffrey.
 While Mr. Stegeman and I were at the hearing with Ms. Williams on April 21,
2003, Mr. Lillig went to Austell branch of Wachovia and told them that he was
Administrator of Ms. Caffrey’s Estate and Mr. Stegeman was under investigation
for Felony Fraud and Elder abuse, not to release the accounts to him. We found
this out later in Certified Bank Records.
 April 22, 2003, I brought Mr. Stegeman to DeKalb County Probate to file his
Will, it had been on file at DeKalb County since the date it was made. We were
told by the Clerk that Ms. Caffrey had died in Cobb County and that’s where the
Will needed to be Probated. Mr. Stegeman called Ms. Williams and she assured
him that she would find out and take care of it.
 I called Mr. Turner when we returned home and inquired about where the death
had occurred so that we could file the Will. He informed me that he would not
tell me and that he had a New Will. Therefore Mr. Turner and Mr. Lillig both
knew that Mr. Stegeman had a Will and was going to file it.
 April 25, 2003, meeting with Ms. Williams, she shook Mr. Stegeman’s hand and
informed him that the Civil suit would be ended since the only person that could
substitute for Ms. Caffrey was me, Janet McDonald.
 Ms. Williams filed Caveat in DeKalb Probate Court.
 With no notice to Mr. Stegeman, Mr. Lillig files for Temporary Administration of
the Caffrey Estate, perjuring himself. Mr. Lillig’s deposition he claimed he had
been good friends with Ms. Caffrey for 20 years and her Pastor for ten or eleven
years. If so, why in the same deposition does he claim that when Ms. Caffrey
died, “we notified her brother in Michigan”? Then Mr. Lillig on the Petition for
the Will claims that both of Ms. Caffrey’s brothers are dead? Then he also claims
that Ms. Caffrey’s brother Jack aka John had no living heirs. If Mr. Lillig Pastor
and very good friend of Ms. Caffrey had been truthful, he would have never said
that they contacted her brother in Michigan, both her brothers are dead, Jack had 4
children 3 of which are still alive, one in Washington state and two in Virginia.
Mr. Lillig perjured himself both in the deposition and the Petition for the Will and
the Petition for Temporary Administration.
 The Accounts held at Wachovia/First Union belonged to Mr. Stegeman and
myself and legal transfer June 12, 2002 was reversed. The claim was made, the
accounts belonged solely to Ms. Caffrey, the accounts actually belonged solely to
Ms. McDonald, myself as shown in Notarized Directive signed by Ms. Caffrey
assigning Ms. McDonald, myself as owner. I did not authorize Mr. Lillig to
continue the frivolous lawsuit. All expenses shown as expenses of the suit, are
unnecessary expenses. Therefore he defrauded me.
 Mr. Lillig became Emergency Administrator of the Caffrey Estate by making
fraudulent claims. He swore that there were no other Wills and that Mr. Stegeman
was under investigation by the DeKalb County’s DA’s Office for Felony Theft by
Taking and Elder Abuse which was a lie and therefore Fraud.
 There were two Wills, one on file at DeKalb County Courthouse since 1992. Mr.
Lillig’s deposition on June 17, 2003 at 11:15 a.m., page 30, Mr. Lillig admits
knowing that there was another Will. Therefore he perjured himself under oath
with intent to defraud The Probate Court and Mr. Stegeman and give himself the
upper hand in a Civil Suit by being named as Substitute for Ms. Caffrey. Mr.
Lillig fraudulently continued a frivolous lawsuit in Superior Court that tied up the
monies that belonged legally to Mr. Stegeman and myself caused undue hardship
on Mr. Stegeman and myself.
 The Withdrawal of Caveat was voided by Mr. Lillig when he instructed Mr.
Turner to notify Wachovia/First Union not to release funds because Mr. Stegeman
and or his attorney had violated the agreement. Only after the signing of the
Consent Order dated and filed with Superior Court on September 23, 2004, could
the Withdrawal of Caveat be used as Mr. Stegeman’s attorney was no longer Ms.
Williams. Again fraud.
 New attorney for Stegeman/McDonald, Mr. Stephen Apolinsky was hired to file
the end to the fraudulent/frivolous Civil suit in Superior Court. Since the original
Memorandum of Understanding had been violated, Mr. Apolinsky was forced to
draw up a Consent Order which was filed after much negotiations with Mr. Lillig.
The cost should not have been incurred and we pray that the Probate Court will
 order the cost, $5,000 be repaid to Mr. Stegeman and Ms. McDonald. If Mr.
Lillig had not violated and voided the original agreement made on March 25,
2004 there would have been no need for the Consent Order of September 30,
2004.
 In negotiating the new Consent Order, at one point Mr. Lillig and Mr. Turner
demanded that Mr. Stegeman pay the debts of Caffrey, this was unacceptable as
the original agreement never stated such.
 Mr. Lillig never honored any of the agreements with Mr. Stegeman.
 Mr. Lillig and Mr. Turner did everything in their power to prevent Mr. Stegeman
and or Ms. McDonald from ever gaining access to their accounts.
 Mr. Lillig never intended to pay any of the debts of Ms. Caffrey’s.
 The billing he submitted has also been falsified. The dates are wrong, and the
claims are ridiculous to the point that it shows fraud. Again, I did not give anyone
authorization to carry on a lawsuit to get money that belonged to me. I would not
sue myself. I would not be in a suit against Mr. Stegeman as he did honor the
contract of Ms. Caffrey and did have the name changed on the account, until Mr.
Joyner had it changed again.

1. 05/27/2003: Meeting With investigator elder care. According to the copy of the
transcript that I have, DeKalb County Solicitor’s Office of Chanda Sukhanath’s
Investigator from Elder Abuse division of DeKalb County Solicitor’s Office,
INTERVIEW with Geneva S. Caffrey was conducted on March 4, 2003. It makes
no sense that one month and a half before Ms. Caffrey’s death there is finally an
interview. According to Secretary of State, Cathy Cox’s website, the investigation
has to be done BEFORE a Guardianship Hearing. Mr. Joyner, Mr. Turner and Mr.
Lillig repeatedly have claimed that Mr. Stegeman was found guilty of fraud and
elder abuse by the Probate Court of DeKalb County. (Considering Mr. Turner did
not allow Ms. Williams and James Stegeman a copy of the transcript until after
the January 14, 2004 hearing in Probate Court, this also was illegal.
2. Mr. Lillig, Mr. Turner and Mr. Joyner have lied and perjured themselves under
Oath numerous times by saying that the DeKalb County District Attorney’s Office
was investigating Mr. Stegeman for Felony Fraud and Felony Elder Abuse.
3. 07/26/2004: cost for court reporter Spherion. I called Spherion. It is an
employment agency in the same building as Joyner’s office. They claim that there
is no record of a court reporter on file, I talked with the Manager.
4. 11/04/2003: Telephone Call with Wachovia about Equity line of credit. Ms.
Caffrey’s home equity loan legally had to be paid off when the 5190 Sheppard Rd
house sold December 2003. Therefore this is a fake charge or there has been
fraud committed when the house sold.
5. 11/10, 11/11, and 11/12/2003: Telephone call about bank documents and equity
loan. This is fraud. Again the house sold almost a year beforehand.
6. 11/19/2003: Again call about equity loan. Preposterous. The other charge is for
telephone call with Mavis Turner about Caffrey’s personal property. Mavis
Turner could not be involved with Ms. Caffrey’s personal property, she was not
named in either Will, in fact Ms. Turner was no one. According to Mr. Lillig’s
 deposition, he gave away Ms. Caffrey’s belonging right after her death. As
Temporary Administrator that was also illegal.
7. 12/23/2003: Going to Court. There was no Court Hearing.
8. 01/18, 01/19, 01/21, 01/22, 01/23: Summary Judgement brief for Superior Court.
Five days and $5670 is ridiculous.
9. 02/26/2004 Dealing with Wachovia to make sure all info provided to Stegeman.
The Settlement agreement was not made until 03/25/2004. Then directly after Mr.
Lillig filed the Withdrawal of Caveat he contacted the bank (according to certified
back records) and told them not to release anything to Mr. Stegeman because
there was still an issue about the LIABILITIES! The credit card debt that turned
into a marginal debt, I guess that is what this means even though Mr. Lillig and
the Estate was responsible for all of Caffrey’s debts.
10. The whole 3rd page of billing is ludicrous. No charges should have incurred in
2005 at all. He is talking with witnesses after the Court Hearing had been
cancelled. There is obvious fraud going on. Then Spherion is listed again,
Levelsmier deposition is listed again. At this point there is no choice accept for
DeKalb County Probate Court Judge Jeryl Rosh to bring charges against Mr.
Lillig and Mr. Turner.
11. And the discussion with Wachovia about the home equity loan. Legally the loan
had to be satisfied when the house sold in December 2002. Therefore this too
must be a lie.

O.C.G.A.30-5-1.
This chapter shall be known and may be cited as the 'Disabled Adults and Elder Persons
Protection Act.'
O.C.G.A. 30-5-8.
(a)(1) In addition to any other provision of law, it shall be unlawful for any person to
abuse, neglect, or exploit any disabled adult or elder person.
(2) Except as otherwise provided in Title 16, any person violating the provisions of this
subsection shall be guilty of a felony and, upon conviction, shall be punished by
imprisonment for not less than one nor more than five years.
(b)(1) It shall be unlawful for any person or official required by paragraph (1) of
subsection (a) of Code Section 30-5-4 to report a case of disabled adult or elder person
abuse to fail knowingly and willfully to make such report.
(2) Any person violating the provisions of this subsection shall be guilty of a
misdemeanor.
(c) Any violation of this Code section shall constitute a separate offense.

Intrinsic Fraud, Deceit, False Pretenses, Moral Turpitude, Malfeasance, Vexatious

Litigation, Slander, Defamation, Exploitation, Perjury, Abuse these are some of the
crimes that Mr. Lillig, Mr. Turner and Mr. Joyner are guilty of. Mandate requires that
knowledge of crimes must be presented to the proper authorities by a Judge and or
Court System. Mr. Stegeman and I have the proof and the documents that we have
and are submitting to The Probate Court of DeKalb County shows concrete proof of
these crimes.

FURTHER SAYETH NOT,

 ____________________________
JANET D. MCDONALD

Sworn to and subscribed

before me this ___ day
of September, 2005.

______________________
Notary Public