When Your Own Paralegal Notarizes Your Affidavits: The Notary Conflict at the Center of the Ellison Case

Philip L. Ellison submitted sworn affidavits in a case where his own law firm is the plaintiff. Those affidavits were notarized by Lisa Edgecomb, his legal assistant and a salaried employee of that same firm. Under Michigan law, that notarization is void. I caught it. I filed the motion.

What I Found and Why It Matters

I have been fighting this lawsuit for six months. During that time I have read every filing, every exhibit, and every affidavit Philip L. Ellison has submitted in this proceeding. When you are pro se, you do not have the luxury of letting anything slide past you. You read everything because no one else is reading it for you.

What I found in the affidavit filings was a name I recognized: Lisa Edgecomb. Not as a witness. Not as a party. As the notary. The same Lisa Edgecomb identified on the Outside Legal Counsel PLC website, captured in a screenshot on May 16, 2026, as Ellison’s legal assistant.

I pulled MCL 55.265. The statute is not ambiguous. A notary public shall not perform a notarial act with respect to a record in which the notary public has a direct beneficial interest. Michigan courts and the Secretary of State have extended that prohibition to notaries who are employed by a party to the document being notarized. A salaried employee of a law firm is financially dependent on that firm’s operation and success. When that firm is the named plaintiff in active litigation, the employee has a direct financial interest in how that litigation resolves. Edgecomb notarizing Ellison’s affidavits in a case where Outside Legal Counsel PLC is the plaintiff is exactly the conflict the statute was written to prevent.

Why This Is Structural, Not Technical

There is a category of notary error that is curable. A missing seal. An incorrect date. A signature in the wrong location. These are technical defects that courts can overlook when the underlying intent of the notarization is clear and the conflict is minor.

This is not that category. This is a structural conflict, the kind the statute was written specifically to prevent. The notary’s employer is the plaintiff in the case. The notary is financially dependent on that employer’s litigation success for her salary and her continued employment. Every favorable ruling for Outside Legal Counsel PLC directly benefits Lisa Edgecomb. Every unfavorable ruling directly threatens her position. She cannot be a neutral authenticating officer for her employer’s sworn statements in a proceeding where her employer’s interests are at stake.

The motion argues, and I believe correctly, that this defect cannot be cured by re-notarization after the fact. The affidavits have already been submitted to this court as competent sworn evidence. They have been relied upon. The prejudice from having unsworn, conflicted testimony treated as evidence in the record is not undone by taking the documents to a different notary later. The appropriate remedy is to strike the affidavits, not to permit Ellison to quietly fix a problem he created and was only caught because the opposing party read every single document in the file.

What the Affidavits Actually Claim

The defective notarization problem would be significant on its own. It is more significant because of what the affidavits say, and because what they say is contradicted by documentary evidence already in this court’s record.

The affidavits make two categories of claim. First, that Ellison had no involvement in the submission of false evidence in connection with the Samantha Aljouny matter. Aljouny is the witness Ellison submitted in this proceeding who does not appear to exist in any verifiable public, professional, or institutional record. His only response to my documented supplemental notice on this point was an unsworn denial that never appeared on the docket under oath. The affidavit repeats that denial with a notarization that is now void.

I have since obtained additional evidence bearing on the Aljouny question. Email header analysis of the Proton Mail account used by Samantha Aljouny of Aljouny Media Consulting establishes that the account was created in September 2023. That date matters for one specific reason: a professional journalist or media consultant operating a legitimate business under the name Aljouny Media Consulting would have a documentable professional presence predating September 2023 by years. Bylines. Press credentials. A LinkedIn profile. Industry directory listings. Client work product. Some trace somewhere in the professional record that establishes this person existed and practiced journalism or media consulting before a Proton Mail account was opened in their name.

There is none. The Proton Mail account was created in September 2023. The account’s first documented public appearance is November 2025, when it appeared as the submission vehicle for witness materials in Ellison’s court filings. Two years of account existence with no professional footprint anywhere, followed by a sudden appearance as a media witness in a Michigan defamation case. A real journalist operating a real consulting firm does not leave a two-year gap between their email account creation and their first documented professional appearance. The September 2023 account creation date does not prove the witness is fabricated on its own. Combined with the complete absence of any verifiable public, professional, or institutional record of this person’s existence anywhere, it compounds a picture that Ellison’s unsworn denial has never addressed under oath.

Second, that Ellison had no involvement in registering the domain names targeting me and my minor children. The Domain Registration Forensic Report in this court’s record traces those registrations, which incorporated the personal names of family members including a minor child, to activity consistent with the Outside Legal Counsel PLC GoDaddy account. IP address 162.247.150.54, documented as Ellison’s office IP in federal PACER records from Lindke v. King, Case No. 2:22-cv-11767 (E.D. Mich.), appears in the domain registration chain. And Ellison’s own September 10, 2025 email acknowledges that he received my cease and desist identifying those exact domains as the problem, yet his response was to forward it to his client rather than to deny any connection to the registrations.

The Adverse Inference and the GoDaddy Records

Michigan courts recognize that when a party has exclusive control over evidence, fails to produce it, and the missing evidence would be relevant to the case, a court may draw an adverse inference: a conclusion that the missing evidence would have been unfavorable to the party who withheld it. The leading cases are Trupiano v. Cully, 349 Mich 568 (1957), and Lagalo v. Allied Corp, 457 Mich 278 (1998).

All three conditions for an adverse inference are satisfied here with unusual clarity. Ellison has exclusive control over the GoDaddy account records for Outside Legal Counsel PLC. Those records include domain purchase history, payment methods, account login logs, and IP address records. They are not publicly available. He controls them and he has not produced them. His defectively notarized affidavit denying domain involvement is the only evidence he has offered on this issue. He has not produced a single document that would corroborate the denial. And the Domain Registration Report already in the record traces the domains to activity consistent with his firm’s GoDaddy account.

If those account records exonerated him, he would produce them. The failure to produce them, in the face of forensic evidence pointing at his firm’s account, is exactly what the adverse inference doctrine was designed to address.

The motion also asks the court to compel production of those records within 21 days of resolution of the pending UPEPA special motion. The UPEPA automatic stay currently applies to all discovery. When it lifts, the GoDaddy records should be the first thing produced. They will either confirm or contradict the forensic analysis. Either way, this court and the parties will know the answer.

What This Means for Anyone in Litigation

I found this because I read everything. Most people do not. Most people, especially pro se litigants going up against experienced attorneys with support staff, assume that if a document has a notary seal on it, the notarization is valid. That assumption is wrong and it can be costly.

If you are in litigation and the opposing party has submitted notarized affidavits, there are a few things worth checking. First, who is the notary and what is their relationship to the signing party? A notary who works for a party, is related to a party, or has a financial interest in the outcome of the proceeding has a disqualifying conflict under MCL 55.265. Second, does the affidavit claim facts that are contradicted by documentary evidence you have in your possession? A notarization does not make a false statement true. It just means someone signed it in front of a witness. Third, are the facts claimed in the affidavit exclusively within the signing party’s control, and have they refused to produce the underlying documents that would corroborate or contradict those facts? If so, the adverse inference doctrine may be available to you.

None of this is esoteric law. MCL 55.265 is a public statute. The adverse inference doctrine is documented in published Michigan Supreme Court opinions. The problem is that most people in litigation do not know to look for these issues, and opposing counsel who knows they exist is counting on that.

I looked. I found it. I filed the motion. The notarizations are void, the affidavits are unsworn, and the GoDaddy records that would resolve the domain question are now subject to compelled production when the UPEPA stay lifts.

This is what it looks like when you actually read the file.