The complaint that has been filed with the Office of Chief Disciplinary Counsel of the Supreme Court of Missouri naming Anthony R. Friedman as Respondent covers the time that of initial evaluation by Friedman to represent the complainant Albert B. Pepper Jr. in a medical malpractice case between the dates of January 1, 2019 through June 30, 2023 while Friedman was employed with The Simon Law Firm P.C. in St. Louis, Missouri
The complaint is comprehensive and exhaustive citing nine violations of the Missouri Rules of Professional Conduct within fifteen separate or co-occurring contexts during representation that include, and are supported by exhibits. Acts on nonfeasance, misfeasance and of particular note, malfeasance.
Because the complaint is comprehensive and exhaustive the complaint is comprised of thirty seven pages. The preponderance of which are the evidence and attached exhibits.
As a result, I am at this time going to forgo uploading the entire complaint for your review and consideration until I have prepared an appropriately redacted pdf file for download. I will however at that time upload for your consideration the executive summary for your review presented as follows.
EXECUTIVE SUMMARY
Complaint Against Attorney Anthony R. Friedman (Bar No. 65531) Submitted by: Albert B. Pepper Jr., Pro Se
Case Background
● Representation: Albert Pepper v. Vladimir Gelfand, M.D., Chesterfield MedCenter, et al., Case No. 19SL‑CC04680.
● Jurisdiction: 21st Judicial Circuit, St. Louis County, Missouri.
● Timeline: February 15, 2019 – June 30, 2023.
● Respondent withdrew following failed mediation and departed The Simon Law Firm P.C. without adequate notice or protection of client interests. Core Allegations
1. Misleading Communications
● Guaranteed trial and high assurances of punitive damages “10–20 times compensatory” despite not having any knowledge at time of statement of $1,000,000 policy cap.
● Failed to correct Complainants unjustified expectations for over three years.
● Respondent falsely assured Complainant early in litigation that statutory caps could be successfully argued as inapplicable but reversed this position at mediation without prior client consultation. Rules Violated: 4-1.4, 4‑7.1(a), 4‑7.1(b), 4‑8.4(c), 4-8.4(d).
2. Discovery Failures
● No spoliation letter sent to defense prior to litigation. ● Ignored missing medical records noted in deposition.
● Successor counsel later recovered 81 pages (one‑third of file) critical to malpractice claim.
● Failed to competently prepare Complainant and key non-party witnesses for deposition,
● Failed to protect Complainant and key non-party witnesses in deposition by not raising timely, waivable objections to the form of questions, thereby allowing prejudicial testimony to be admitted and permanently preserved against the Complainant. Rules Violated: 4-1.1, 4-1.3, 4-1.4 3.
Expert Witness Mismanagement
● Promised 3–5 sessions; arranged only one phone call.
● Provided incomplete medical file to expert.
● Dismissed expert without seeking second opinion, abandoning causation/damages development. Rules Violated: 4‑1.1, 4‑1.3, 4‑1.4.
4. Dismissal of Client Input
● Ignored repeated requests for case theory and valuation.
● Failed to interview ex‑wife and son despite acknowledging urgency.
● Used a single “case weakness” to pressure settlement, disregarding client’s counterarguments. Rules Violated: 4‑1.1, 4‑1.3, 4‑1.4, 4‑8.4(c).
5. Mediation Misconduct
● No preparation, demand letter, valuation metrics, or lien/expense calculations.
● Admitted handling multiple mediations the same day.
● Failed to clarify mediator’s confidentiality assurance.
● Volunteered statutory caps, undermining Complainants negotiation strategy, in direct contradiction to prior assurances that the caps were inapplicable.
● Disclosed privileged client email to opposing counsel without consent. Rules Violated: 4‑1.1, 4‑1.3, 4‑1.4, 4‑1.6, 4‑8.4(c), 4‑8.4(d).
6. Improper Withdrawal
1. First notice of withdrawal given mid‑mediation. 2. Transferred case to junior associate with no trial experience. Rules Violated: 4‑1.16(d), 4‑1.4, 4‑1.3, 4‑8.4(c).
Conclusion
Respondent’s conduct demonstrates a pattern of negligence, dishonesty, and breach of fiduciary duty, including:
● Misleading promises and misrepresentation of the law.
● Failure to secure critical evidence,
● Breach of confidentiality, and
● Abandonment of client at a critical juncture.
Requested Action: Formal investigation and appropriate discipline to protect the public and uphold the integrity of the legal profession.
Respectfully submitted,
Albert B. Pepper Jr., Pro Se