Tariq Davis, a minor, by his parents and next friends, Dianne Bynoe and Roosevelt Davis, and Dianne Bynoe and Roosevelt Davis on their own behalf v. American Youth Soccer Organization, Virgin Islands American Youth Soccer Organization, the University of the Virgin Islands, and Lavar Browne

Superior Court of The Virgin Islands·Decided October 15, 2024·No. ST-2009-CV-70·Unpublished

Opinion

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN

TARIQ DAVIS, a minor, by his parents and next ) CASE NO. ST-2009-CV-00070 friends, DIANNE BYNOE and ROOSEVELT ) DAVIS, and DIANNE BYNOE and ROOSEVELT ) DAVIS on their own behalf, )

)

Plaintiffs ) ACTION FOR DAMAGES vs )

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)

AMERICAN YOUTH SOCCER } ORGANIZATION, VIRGIN ISLANDS ) JURY TRIAL DEMANDED AMERICAN YOUTH SOCCER ) ORGANIZATION, THE UNIVERSITY OF THE ) VIRGIN ISLANDS, and LAVAR BROWNE )

)

Defendants )

)

2024 VI Super 40U

MEMORANDUM OPINION q! THIS MATTER is before the Court on Defendants American Youth Soccer Organization and Virgin Islands American Youth Soccer Organization, (“Defendants”) Motion to Disqualify Plaintiffs’ Counsel, filed November 18, 2015.! For the reasons set forth below, Defendants’ motion to disqualify will be denied

' This matter is fully briefed. Plaintiffs Tariq Davis and his parents, Dianne Bynoe and Roosevelt Davis, (“Plaintiffs’’) filed an opposition on December 2, 2015, and Defendants filed a reply on January 27, 2016. On February 11, 2016 Plaintiffs filed a motion for leave to respond to Defendants’ reply because attached to Defendants reply is an affidavit signed by John McDonald on January 11, 2026. which was apparently created to refute some of the arguments in Plaintiff's Opposition. The motion for leave to respond will be denied under separate order and the January 11. 2026 affidavit will not be considered

Tariq Ron Bynoe Davis v. American Youth Soccer Organization Case No. ST-2009-CV-00070 Cite as 2024 VI Super 40U Memorandum Opinion (motion to disqualify plaintiffs’ counsel re: attorney-witness) Page 2 of 13

BACKGROUND AND PROCEDURAL POSTURE

q2 Plaintiffs Tariq Davis and his parents, Dianne Bynoe and Roosevelt Davis, are residents of St. Thomas, Virgin Islands. In 2007, Plaintiff Tariq Davis (““Tariq”), a minor at the time, was practicing soccer with his teammates at the University of Virgin Islands soccer field. Compl. {| 13 While Tariq was practicing on the field with his teammates, he chased an errant ball out into the public roadway located next to the field that runs parallel to a public roadway. /d. Plaintiffs allege that Tariq was hit by a car and thrown into the air. He was knocked unconscious and remained so for a period of eleven weeks. /d. In addition, the Complaint alleges that Tariq suffered from a traumatic brain injury, a concussion, and a fractured femur. Compl. 14. Plaintiffs allege that American Youth Soccer Organization was an organization dedicated to sponsoring youth soccer teams nationwide and in the Virgin Islands at the time of the incident. Compl. J] 4 43 On February 12, 2009, Plaintiffs, by and through the Law Offices of Desmond Maynard filed a complaint against Defendants American Youth Soccer Association and Virgin Islands American Youth Soccer Organization (“Defendants” or “AYSO” “VI AYSO”), jointly and severally, in an action for premises liability and negligence and Defendants AYSO and VI AYSO filed a joint Answer and Affirmative Defenses, by and through the Law Office of A. Jeffrey Weiss 44 On February 17, 2015, Defendants filed a Motion for Partial Summary Judgment against plaintiff Diane Bynoe. The Plaintiffs’ Opposition to that Motion, filed on August 3, 2015, included the following exhibits, a declaration by Attorney Maynard-Hahnfeld, an affidavit she had drafted for Mr. John McDonald (‘““McDonald’’)’s signature, and email correspondence between plaintiffs’

Tarig Ron Bynoe Davis v. American Youth Soccer Organization Case No. ST-2009-CV-00070 Cite as 2024 VI Super 40U Memorandum Opinion (motion to disqualify plaintiffs’ counsel re: attommey-witness) Page 3 of 13

counsel and McDonald dated July 22, 2015.7 That motion for partial summary judgment was denied by order and memorandum opinion entered May 18, 2016 q5 However, Defendants subsequently filed this Motion to Disqualify Plaintiffs’ counsel based upon Plaintiffs’ filing of Attomey Maynard-Hahnfeld’s Declaration and the draft affidavit for McDonald that were attached to Plaintiffs’ Opposition to Defendants’ motion for partial summary judgment. Defendants assert that Attorney Desmond Maynard (“Maynard”) and Attorney Shawn Maynard-Hahnfeld (“Maynard-Hahnfeld”) (or collectively “the Maynards”) made themselves necessary witnesses in this case in violation of Virgin Island Supreme Court Rule 211.3.7 by filing the Declaration and an unsigned draft affidavit of a witness, McDonald, in support of their opposition to Defendants’ Motion for Partial Summary Judgment. In total, Defendants contend Plaintiffs’ counsel violated ethical rules, specifically Virgin Islands Supreme Court Rules 211.3.7, 211.3.3 and 211.8.4.7

2 According to the filings, Plaintiffs’ counsel met with McDonald on June 8, 2015, and prepared an affidavit for McDonald's signature. McDonald picked up the draft affidavit on July 22, 2015, and Plaintiffs’ counsel emailed McDonald to ask him to advise them if there were any necessary corrections to the draft affidavit. On July 31, 2015 counsel for AYSO sent a letter to the Maynards asserting their conduct was unethical. In an apparent response to that charge of unethical conduct, Maynard-Hahnfeld prepared her Declaration to set the record straight and attached the Declaration and McDonald's draft affidavit to the Plaintiffs’ opposition to the Defendant’s Motion For Partial Summary Judgment, which plaintiffs filed on August 3, 2015. The filing of those two documents then opened the avenue Defendants are pursuing to move for disqualification of plaintiffs’ counsel

’ Although Defendants’ Motion to Disqualify references two other rules, Virgin Islands Supreme Court Rules 211.4.1 and 211.3.4(b), in the fact section and the header of one of its arguments, Defendants do not cite to the rule nor provide any legal argument in favor of disqualification under V.I S. CT. R.211.4.1 and V.I.S. Cr. R. 211.3.4(b) in the motion Therefore, the court will not consider the applicability of Rule 211.4.1 and Rule 211.3.4(b). The court notes Defendants subsequently outline and argue under those two rules in their reply briefing. Because the Defendants motion in chief did not raise arguments under Rules 211.4.1 and 211.3.4(b), the court will not consider those new arguments outlined in the reply brief because Plaintiffs’ counse! was not afforded an opportunity to respond. See Perez v. Ritz-Carlton (Virgin Islands), Inc., 59 V1, 522, 528 (2013) (“[A]n issue raised for the first time in a reply brief is deemed waived because the opposing party typically does not have the opportunity to respond.”) (alteration in original), Accordingly, the court considers the arguments under Rules 211.4.1 and 211.3 4(b) waived

Tariq Ron Bynoe Davis v. American Youth Soccer Organization Case No. ST-2009-C V-00070 Cite as 2024 VI Super 40U Memorandum Opinion (motion to disqualify plaintiffs’ counsel re: attorney-witness) Page 4 of 13

LEGAL ANALYSIS

A. Disqualification of an Attorney a. Rule 211.3.7 does not disqualify Plaintiffs’ counsel

16 Defendants argue that Plaintiffs’ counsel should be disqualified because both Maynard and Maynard-Hahnfeld have made themselves necessary witnesses by submitting an unsigned draft affidavit of John McDonald, a witness in the case, in support of Plaintiffs’ Opposition to a Partial Motion for Summary Judgment. In particular, Defendants contend that Plaintiffs’ counsel filed the draft affidavit of McDonald to directly contest the sworn affidavit that Defense counsel obtained from McDonald. For that reason, Defendants asserts that Plaintiffs’ counsel has forced themselves into the role of a witness and must be disqualified for attempting to dispute McDonald’s sworn statement

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Tariq Davis, a minor, by his parents and next friends, Dianne Bynoe and Roosevelt Davis, and Dianne Bynoe and Roosevelt Davis on their own behalf v. American Youth Soccer Organization, Virgin Islands American Youth Soccer Organization, the University of the Virgin Islands, and Lavar Browne, (visuper 2024).

Tariq Davis, a minor, by his parents and next friends, Dianne Bynoe and Roosevelt Davis, and Dianne Bynoe and Roosevelt Davis on their own behalf v. American Youth Soccer Organization, Virgin Islands American Youth Soccer Organization, the University of the Virgin Islands, and Lavar Browne (Tariq Davis, a minor, by his parents and next friends, Dianne Bynoe and Roosevelt Davis, and Dianne Bynoe and Roosevelt Davis on their own behalf v. American Youth Soccer Organization, Virgin Islands American Youth Soccer Organization, the University of the Virgin Islands, and Lavar Browne) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.