Memorandum – Lindsay N. Sudman, ESQ., Fair Cadora, APC


Date: 11 MAY 2021

From: Michael J. Merritt, USN Retired/Writer
PO BOX 187
Newton, IA 50208

To: Lindsay N. Sudman, ESQ.
Fair Cadora, APC
600 B Street, STE. 2210
San Diego, CA 92101

Info: The State Bar of California
180 Howard Street
San Francisco, CA 94105

San Diego District Attorney
330 W Broadway Ste 1300
San Diego, CA 92101
(619) 531-4040

San Diego County Sheriff
9621 Ridgehaven Ct
San Diego, CA 92123
(858) 974-2222

Law Offices of Colleen A. Warren, APC
3530 Camino del Rio North
Suite 202
San Diego, CA 92108

Subject: San Diego East County Superior Court Case: ED100465 – Claudia J. Bergman f.k.a Claudia J. Merritt vs. 4d69636861656c204a2e204d6572726974740d0a0d0a0d0a0d0a0d0a0d0a

I have several concerns I would like to address with you through The State Bar of California and in court regarding:

1. The representation of your former client alleging sexual abuse occurred prior to your retainment.
2. Failure to pursue a DVRO in January 2017 for a client alleging sexual abuse.
3. The second incident of alleged sexual abuse occurred in June 2017, which was preventable if your former client had a restraining order as she has alleged on court documents.
4. Failure to follow child concealment protocol in accordance with California Penal Code 278.7

Your former client communicates on MC-030 dated 05 JUN 2019 regarding your representation: “January 2017 – My then lawyer was going to file a restraining order but since he physically left the state of California, she recommended that he was no longer a physical threat as he was going back to his home state of Iowa and back to his Navy duties in Bahrain.”

Important timeline of events during your tenure on this case:
25 DEC 2016 – Your former client begins covertly coordinating with members of my family while accusing me of false allegations of sexual abuse, other forms of abuse, and violations of the law (IAC Exhibit C).

30 DEC 2016 – 07 JAN 2017 – The Petitioner communicates with multiple commands within the US Navy throughout the world while accusing me of false allegations of sexual abuse, other forms of abuse, and violations of the law (CA Exhibit H).

Late January 2017 – Early June 2017 – The Petitioner attempts to reconcile with me (CA Exhibit A).

10 JUN 2017– The Petitioner sent an email to the Executive Officer of NCTS Bahrain (Respondent’s US Navy Command) retracting her previous statements and apologizing for her behavior (Exhibit H) stating: “Hello, Six months ago I was under extreme emotional duress. 4d69636861656c204a2e204d6572726974740d0a0d0a0d0a0d0a0d0a0d0a had been a husband to me for 15 years. I filed for divorce and dismissed on 5/3/17. All my emotions skyrocketed for the first time in my life. The purpose of this note is to attempt to salvage 4d69636861656c204a2e204d6572726974740d0a0d0a0d0a0d0a0d0a0d0a’s name. There were many misunderstandings and Im in San Diego and he’s in Bahrain and I just couldn’t seem to get a hold of him and I was afraid to as well. Many of the issues brought up were due to miscommunication and misunderstanding. 4d69636861656c204a2e204d6572726974740d0a0d0a0d0a0d0a0d0a0d0a has always acted as honorable as he possibly could. He’d always tried to be the best husband and father as the military allowed him to be. I have no ill will towards 4d69636861656c204a2e204d6572726974740d0a0d0a0d0a0d0a0d0a0d0a and hope for nothing but the best for him. I also wish to disclose that I am a damaged and broken person as I was sexually abused as a child for many years. I love 4d69636861656c204a2e204d6572726974740d0a0d0a0d0a0d0a0d0a0d0a and he got a bad deal when he married me. He loved serving his country and was gone often. This coupled with my being a broken girl did not allow 4d69636861656c204a2e204d6572726974740d0a0d0a0d0a0d0a0d0a0d0a to be the best that he could be at his Navy duties. I apologize for all the unnecessary drama that resulted from my emotional upheaval as I tried my best to make sense of how to proceed without a husband. 4d69636861656c204a2e204d6572726974740d0a0d0a0d0a0d0a0d0a0d0a is the best possible human being that has ever walked on this earth. Im attempting to let it be known that the demise of my marriage and actions just after filing for divorce are all my fault. I take responsibility for everything that was said against 4d69636861656c204a2e204d6572726974740d0a0d0a0d0a0d0a0d0a0d0a. I deeply am sorry and apologize for my misbehavior. Very Respectfully, Claudia J Merritt”

Summer 2017 – San Diego County Sheriff initiate’s case: 17136819 regarding allegations of child molestation towards a child involved in this court case and a current client of Colleen A. Warren. At this time, your office again fails to file a DVRO against me to protect your client from alleged abuse.

Summer 2017 – The US Navy initiates an investigation regarding allegations of “spousal rape” and “child molestation”. The allegation of “spousal rape” was not filed against me by your former client with the San Diego County Sheriff possibly to avoid violating CA PC 148.5. Your former client later filed charges against me regarding “spousal rape” with the San Diego County Sheriff case: 20103437 in January 2020 after retracting her 17 MAY 2019 DVRO request on 31 OCT 2019 after submitting no evidence to support it.

01 AUG 2017 – Your former client begins concealing the children in this court case.

11 AUG 2020 – Deadline to file a report with the San Diego County District Attorney’s office regarding intentions to conceal children. California Penal Code 278.7(c)

30 AUG 2017 – The Petitioner begins providing the following address to me regarding the location of my children (Ramona USPS).

1444 Main St #792
Ramona, CA 92065

31 AUG 2017 – Deadline to commence a custody proceeding regarding child concealment. California Penal Code 278.7(c)

January 2018 – I receive a text from a phone on your former clients’ mobile phone bill informing me that the truth will be released that no abuse occurred if I provide your former client more financial resources monthly (CA Exhibit C).

31 JAN 2018 – MC-050 is submitted to San Diego East County Superior Court substituting Claudia J. Merritt as a Pro Se litigant removing you from this case.

I am requesting the name and address of the court/party that you filed documents as required by California Penal Code 278.7(c) when a party intends to conceal a child/children. I am making this request because I was never served with any paperwork, and I see no record of this required paperwork on the San Diego East County Portal listing events for this court case.

This situation illustrates either negligence or deceit by you or your former client as your actions as a licensed lawyer in the State of California are not reflective of state law or consistent with your former clients documented testimony with multiple parties and investigations during your tenure as her lawyer. I have spent the last 3 years building this case while pursuing your former client and my children across three states.

I am requesting the following:

1. Verification of your mailing address or agreeance to being electronically served legal paperwork.
2. Any legal documents that you have filed during your tenure on this case regarding your responsibilities to your former client to conceal children in the state of California.


Michael J. Merritt, USN Retired/Writer
Creative Writer/Musician
Information Warfare Specialist
Information Systems Manager
PO BOX 187
Newton, IA 50208