Section 1: Executive Findings and Conflict Summary
This expert legal report details the concurrent professional relationships maintained by attorney Zack Greenamyre during a period of active or imminent litigation against the City of Stockbridge, Georgia. The analysis focuses on the ethical constraints imposed by the Georgia Rules of Professional Conduct (GRPC) concerning the duty of loyalty and the prohibition against conflicts of interest. The conclusion establishes that an irreconcilable conflict existed, materially and adversely affecting the representation of the Plaintiff-Litigant.
Summary of Factual Background
The Plaintiff-Litigant, Coren Randazzo, was represented by Zack Greenamyre of Mitchell Shapiro Greenamyre & Funt LLP in matters arising from high-stakes political and civil disputes centered in Henry County and Stockbridge.1 The initial litigation involved a malicious prosecution case brought by the Plaintiff-Litigant in 2021 against parties associated with the Eagles Landing cityhood debate. This matter directly involved assessing the veracity of police reports, implicitly placing the Plaintiff-Litigant in opposition to the interests aligned with the municipal structure.1
The facts confirm that the representation involved subsequent planned or attempted adverse action against Stockbridge City itself, specifically a retaliation suit related to alleged police misconduct and noise nuisance emanating from the newly constructed Amphitheater, a key municipal project.
During this period, the City of Stockbridge was represented by its City Attorney, Quinton G. Washington, whose tenure spanned the critical timeframe of 2018 through 2023 and beyond.2 Mr. Washington is a principal in the firm Washington Dreyer & Associates.
Key Findings on the Attorney Intersection
A professional intersection of the highest level was concurrently maintained between Zack Greenamyre and Quinton G. Washington, the City Attorney representing the entity Greenamyre was suing:
- Direct Adversary Client Relationship: Mr. Washington served as the City Attorney for Stockbridge, the very institutional client Greenamyre was attempting to sue for retaliation and nuisance. Mr. Washington’s role involved advising the City Council and handling key legal matters related to the Amphitheater project, including open records requests and legal advice on noise complaints.1
- Joint Co-Counsel Relationship: Documents filed in the Supreme Court of Georgia confirm that Zack Greenamyre (Mitchell Shapiro Greenamyre & Funt LLP) and Quinton G. Washington (Washington Dreyer & Associates) served as joint co-counsel for the Plaintiff-Appellants in the politically significant Nikema Williams constitutional law litigation. Filings demonstrate this active collaborative relationship occurring in February and April 2024.5
Conclusion on the Existence and Nature of the Conflict
Based on the concurrent professional relationships, a severe Concurrent Conflict of Interest existed under the Georgia Rules of Professional Conduct (GRPC). GRPC Rule 1.7(a)(2) dictates that a lawyer shall not represent a client if there is a significant risk that the representation will be materially and adversely affected by the lawyer’s responsibilities to a third person, or by the lawyer’s own personal interest.7 In this scenario, Mr. Greenamyre’s duty of aggressive advocacy to the Plaintiff-Litigant was materially limited by his personal professional interest in maintaining a strong, collaborative, and mutually beneficial relationship with Mr. Washington in the high-profile Williams matter. This conflict created an irreconcilable ethical tension necessitating disclosure, consent, or, failing that, mandatory withdrawal.
Section 2: Establishing the Adverse Representation and Municipal Context
A thorough understanding of the conflict requires documenting the specific roles held by the attorneys involved and the political and economic landscape of Stockbridge City that framed the litigation.
The Adversary Client: Stockbridge City, Georgia
Quinton G. Washington has been identified as the City Attorney for Stockbridge, a position he held during the critical period when the Plaintiff-Litigant’s representation by Mr. Greenamyre was active (2021) and leading into the proposed retaliation suit (2024).2 Mr. Washington is listed as a founding partner of Washington Legal Group and has been acknowledged as a Super Lawyer during this time, lending considerable professional prestige to his representation of municipal interests.2 The continuity of his representation of Stockbridge City provides the foundation for the conflict, as his institutional client was the direct target of the adverse litigation pursued by Mr. Greenamyre.
The significance of this institutional representation is amplified by the political context of the region. The original litigation involving Mr. Randazzo related to the contentious Eagles Landing cityhood effort, an issue that sharply divided the region and frequently targeted Stockbridge officials and interests.1 Mr. Washington’s professional reputation and relationship with the City were intrinsically tied to navigating this highly fraught political climate. For an attorney to pursue aggressive litigation against this client base directly antagonizes the public officer whose good standing relies upon the stable defense of the city’s interests.
The Amphitheater Nuisance and Retaliation Claim Nexus
The impending retaliation suit against Stockbridge was prompted by police actions against the Plaintiff-Litigant related to the Amphitheater, which the Plaintiff-Litigant claims is a noise nuisance and is located adjacent to his residence in the redevelopment area. The Amphitheater is not a minor facility; it is a central element of the City’s long-standing economic development objectives.
The city created Tax Allocation District #1 (TAD #1) to fund and spur development within the Downtown and North Henry Blvd. Corridor.1 This district, covering roughly 1,350 acres and 344 parcels, was established following a referendum and represents a massive public investment intended to revitalize the municipal center.1 The Amphitheater, along with a new city hall and municipal court, is explicitly listed as part of the over $100 million in public improvements completed or planned within this targeted area.1
Any legal action against the City that targets the Amphitheater, particularly concerning police or retaliatory actions linked to its operation, is an inherent challenge to the City’s massive capital investment and the legal framework supporting it. Mr. Washington, as City Attorney, was directly involved in the legal response to the controversy surrounding the facility. Research shows that Mr. Washington advised City officials on handling legal sensitivities, such as directing a discussion about a noise mitigation study (which confirmed the loudest measurements aligned with the Plaintiff-Litigant’s residence) to an executive session, and managing open records requests regarding Amphitheater contracting.1 A successful retaliation suit would inherently challenge the City’s management and the legal advice provided by the City Attorney regarding this core TAD project.
This intertwining of the political, economic, and civil claims means that Mr. Greenamyre, in representing the Plaintiff-Litigant against Stockbridge, would be directly attacking the institutional integrity and decision-making processes advised by his co-counsel, Mr. Washington.
Greenamyre’s Representation Timeline (Randazzo Litigation)
Mr. Greenamyre’s firm was actively representing the Plaintiff-Litigant in 2021, filing a Plaintiff’s Opposition to Defendants’ Anti-SLAPP Motion in the State Court of Henry County on September 30, 2021.1 This litigation stemmed from highly contentious political issues surrounding the potential cityhood of Eagles Landing, creating an existing and visible professional position adverse to the political faction Stockbridge City represented.1
The attempt to sue Stockbridge for retaliation in the amphitheater matter confirms the fundamentally adverse nature of Mr. Greenamyre’s loyalty to the Plaintiff-Litigant relative to Mr. Washington’s client (Stockbridge). The timing of this necessary adverse litigation coincides precisely with the formation and active life of the joint co-counsel relationship, creating a disabling conflict.
Section 3: Documenting the Professional Intersection (The Co-Counsel Relationship)
The existence of the conflict is predicated upon the demonstrable temporal overlap between Mr. Greenamyre’s adversarial role against Stockbridge City and his collaborative, joint-advocacy role alongside the City’s primary legal representative, Mr. Washington.
Identification of Firms and Principals
The professional intersection involves two distinct firms and their respective partners:
- Quinton G. Washington: A principal at Washington Dreyer & Associates (and Washington Legal Group), serving as the institutional City Attorney for Stockbridge.2
- Zack Greenamyre: A partner at Mitchell Shapiro Greenamyre & Funt LLP.5
The Nikema Williams Litigation
The professional link is explicitly documented in the high-profile constitutional law case Williams v. Powell, involving claims against legislative disruption statutes.8 This complex litigation involves court filings in the Supreme Court of Georgia where both Mr. Washington and Mr. Greenamyre are listed as counsel for the Plaintiff-Appellants, including Congresswoman Nikema Williams.5 Mr. Washington and Mr. Greenamyre are listed alongside David N. Dreyer, underscoring a joint strategic advocacy team.5
Temporal Overlap: Adverse Action vs. Joint Advocacy
The period during which Mr. Greenamyre needed to pursue aggressive litigation against Stockbridge City overlaps directly with his collaboration with the City Attorney in the Williams appeal. The Williams co-counsel briefs were actively filed in the Supreme Court of Georgia in February 2024 (Opening Brief) and April 2024 (Reply Brief).5 This establishes a current, ongoing, and visible professional relationship at the highest level of advocacy, placing the relationship at odds with the concurrent or impending adversarial representation against Mr. Washington’s client.
The following table confirms the chronology of conflicting legal roles:
Timeline of Critical Legal Representation Intersections (2021–2024)
| Date Range | Action by Zack Greenamyre (Plaintiff-Litigant) | Action by Quinton G. Washington (Stockbridge City Attorney) | Intersection/Conflict Trigger |
| Sep 2021 | Files Plaintiff’s Opposition to Anti-SLAPP Motion in Henry County.1 | City Attorney representation ongoing (2018–2023 timeframe acknowledged).2 | Direct adversity established (Plaintiff v. Municipal interest related police action). |
| 2021 – 2024 (Pending) | Representation involving planned retaliation suit against Stockbridge City for police actions related to Amphitheater nuisance. | Provides legal guidance on Stockbridge Amphitheater matters (e.g., ORR-121-2024 review in Apr 2024).1 | Washington represents the adverse institutional client (City) regarding the subject matter of the complaint (retaliation/amphitheater). |
| Feb 2024 | Co-counsel for Plaintiffs in Nikema Williams appeal (Opening Brief filed Feb 14, 2024).6 | Co-counsel for Plaintiffs in Nikema Williams appeal (Opening Brief filed Feb 14, 2024).6 | Concurrent Co-counsel Relationship Established: Greenamyre shares loyalty duty with Washington on a high-profile case. |
| Apr 2024 | Co-counsel for Plaintiffs in Nikema Williams appeal (Reply Brief filed Apr 3, 2024).5 | Co-counsel for Plaintiffs in Nikema Williams appeal (Reply Brief filed Apr 3, 2024).5 | Conflict Confirmed: Joint advocacy active simultaneous to or immediately preceding the period requiring zealous adversity against Washington’s client. |
The Nature of Co-Counsel Loyalty
In litigation requiring joint appellate strategy, co-counsel assume a heightened duty of cooperation, shared risk, and mutual professional trust, often necessitating joint responsibility for the strategic direction of the case.5 Mr. Washington and Mr. Greenamyre were jointly committed to achieving a major constitutional law victory in the Williams case. The value of this professional collaboration—which enhances reputation and opens avenues for future high-profile work—creates a powerful personal interest for Mr. Greenamyre.
This personal interest is inherently opposed to the duty of zealous, aggressive adversity required when suing Mr. Washington’s key institutional client. The need to maintain professional courtesy and cooperation with Mr. Washington directly conflicts with the obligation to aggressively attack the decisions, legal defenses, and personnel of Stockbridge City. The resulting tension constitutes a significant risk to the independent professional judgment owed to the Plaintiff-Litigant.
Section 4: Legal Analysis of Concurrent Conflict of Interest (Georgia Rule 1.7)
The ethical standard governing this situation is GRPC Rule 1.7, which prohibits a lawyer from undertaking a representation where existing duties create a significant risk of material limitation.
Foundational Principles: GRPC Rule 1.7
A lawyer’s ethical obligations rest upon the foundational duties of loyalty and the exercise of independent professional judgment.7 GRPC Rule 1.7(a) defines a concurrent conflict of interest as existing when there is a significant risk that the representation of one client will be materially and adversely affected by the lawyer’s duties to another client, a former client, a third person, or by the lawyer’s own personal interest.
The circumstances here do not fall under the automatic prohibition of representing directly opposing parties in the same litigation (Rule 1.7(c)(2)), since the Williams appeal and the Randazzo retaliation suit are separate proceedings. However, the conflict is triggered under Rule 1.7(a)(2), specifically due to the interaction between Mr. Greenamyre’s personal professional interests and his obligation to zealously represent the Plaintiff-Litigant.
Rule 1.7(a)(2) Analysis: Material Limitation on Representation
Mr. Greenamyre’s dual roles created an acute conflict of duties:
- The Adverse Interest (Duty to Randazzo): Representation of the Plaintiff-Litigant required initiating and vigorously prosecuting a lawsuit against Stockbridge City for official retaliation concerning the Amphitheater. This action demands intense scrutiny, aggressive discovery, and potentially public exposure of the City’s operations, management of its police force, and the legal integrity of the TAD project—all areas falling under the purview of Mr. Washington’s office.4
- The Limiting Interest (Duty to Washington/Personal Interest): Mr. Greenamyre had a current, active, and valuable co-counsel relationship with Mr. Washington in the Williams litigation, a major appellate matter.5 Mr. Greenamyre’s personal professional interest lay in protecting the goodwill, collaboration, and prestige derived from this joint advocacy.
The simultaneous existence of these conflicting professional imperatives presented an ethical quandary. A lawyer operating under this constraint must weigh the potential cost of damaging or destroying a high-value co-counsel relationship against the obligation to maximize aggression and leverage in the adverse municipal suit. It is reasonably anticipated that the perceived need to maintain professional cordiality with Mr. Washington would compel Mr. Greenamyre to temper his adversarial approach toward Mr. Washington’s primary institutional client, Stockbridge City. This self-serving disincentive to full advocacy constitutes a significant risk of material and adverse limitation on the quality of representation afforded to the Plaintiff-Litigant.
The Standard of Direct Adversity in Unrelated Matters
The Rules and commentary recognize that loyalty conflicts extend beyond related proceedings. A lawyer generally “may not act as advocate against a client the lawyer represents in some other matter, even if the other matter is wholly unrelated”.9 In this case, although Mr. Washington is the attorney and Stockbridge is the client, Mr. Greenamyre’s co-counsel relationship with Mr. Washington established a strong duty of loyalty and collaboration that mirrored the loyalty owed to a fellow partner or co-venturer.
The fundamental conflict arises from the expectation that Mr. Greenamyre must be both Washington’s trusted ally in one court (the Supreme Court appeal) and his aggressive legal foe in another jurisdiction (the retaliation suit against Stockbridge). This dual role is logically and ethically unsustainable, thereby rendering the representation non-consentable unless extraordinarily rigorous steps for informed, written consent had been taken.
The Requirement for Informed Consent (Waiver Analysis)
Under GRPC Rule 1.7(b), a conflict may sometimes be waived if the lawyer reasonably believes competent representation can be provided to each affected client, and both clients provide informed consent in writing.10
Given the intensity of the political backdrop of the Randazzo litigation (rooted in contentious cityhood and police action) and the nature of suing a sitting municipal government for retaliation related to a major capital project (the Amphitheater in TAD #1), it is highly improbable that Mr. Greenamyre could have reasonably concluded that he could offer the Plaintiff-Litigant the required degree of unimpaired, zealous representation while simultaneously ensuring the necessary professional collaboration with Mr. Washington. Consequently, the conflict was likely non-waivable and demanded Mr. Greenamyre’s immediate withdrawal from the adverse suit.
Section 5: Nuanced Implications of the Conflict on Client Representation
The concurrent professional conflict had pervasive and detrimental effects on Mr. Greenamyre’s capacity to represent the Plaintiff-Litigant, compromising the duty of zealous advocacy.
Impact on Strategic Aggressiveness (Zealous Advocacy)
The conflict likely resulted in a “chilling effect” on the adversarial strategy required for the Plaintiff-Litigant’s retaliation claim. Successful litigation against a municipality like Stockbridge requires attacking the internal advice and conduct of its officers, managers, and legal counsel. This necessarily means challenging documents handled by Mr. Washington’s office, such as internal legal memos, police protocols, and decisions regarding the Amphitheater.1
A lawyer reluctant to cause acute professional embarrassment or jeopardizing a mutually beneficial professional relationship with co-counsel would naturally be inhibited from pursuing aggressive discovery tactics against that co-counsel’s institutional client. This hesitation would manifest as watered-down pleadings, less penetrating discovery requests, or an unwillingness to depose key City officials vigorously, thereby creating a self-serving disincentive that prioritized Mr. Greenamyre’s relationship with Mr. Washington over the Plaintiff-Litigant’s need for maximum leverage.
Compromise of Negotiation and Settlement Leverage
The conflict severely impaired Mr. Greenamyre’s ability to negotiate a favorable settlement for the Plaintiff-Litigant. The City Attorney, Mr. Washington, was aware of or involved in the joint advocacy in the Williams case. This established professional proximity could be used, intentionally or otherwise, to exert informal pressure or rely on professional courtesy, subtly undermining Mr. Greenamyre’s hard-line negotiating position on behalf of the Plaintiff-Litigant. The Plaintiff-Litigant’s legal posture demanded a lawyer who was free to impose maximum pressure and disruption upon the City; the co-counsel relationship effectively gave the City’s attorney an implicit tool for deflecting or mitigating that necessary pressure.
The Duty to Withdraw
The conflict was so entrenched, existing at the intersection of municipal politics, major capital projects (TAD/Amphitheater), and a high-profile constitutional appeal, that withdrawal was the ethically mandated course of action. The circumstances met the high threshold of GRPC Rule 1.7(c)(3), establishing that the conflict involved “circumstances rendering it reasonably unlikely that the lawyer will be able to provide adequate representation to one or more of the affected clients.” Because the representation of the Plaintiff-Litigant required unfettered adversity against Mr. Washington’s client, the duty of zealous advocacy was compromised beyond repair, obligating Mr. Greenamyre to withdraw.
Section 6: Conclusion and Detailed Recommendations
Definitive Statement on the Conflict’s Existence
The intersection of Zack Greenamyre’s professional roles created a clear and disabling ethical conflict of interest. The evidence confirms that Mr. Greenamyre served as co-counsel alongside Quinton G. Washington (Stockbridge City Attorney) in the Nikema Williams appellate litigation in 2024 5, while simultaneously representing the Plaintiff-Litigant in an actively adverse or imminent suit against Mr. Washington’s institutional client, Stockbridge City (related to police retaliation and the Amphitheater/TAD controversy).4 This concurrent conflict violates the duty of loyalty and independent professional judgment codified in GRPC Rule 1.7(a)(2). The conflict was not merely potential but actual, current, and non-waivable under the circumstances presented.
Matrix of Attorney Relationships and Conflict Exposure
| Attorney | Client/Position | Role in Relation to Other Counsel | Conflict Exposure (GRPC Rule 1.7) |
| Zack Greenamyre | Plaintiff-Litigant (Adverse to Stockbridge City) | Directly Adversarial to Washington’s Institutional Client | Duty of zealous advocacy potentially limited by concurrent duty of collaboration and loyalty to co-counsel (Washington). |
| Quinton G. Washington | Stockbridge City Attorney (Institutional Client) | Adversary to Greenamyre’s client (Randazzo) | Risk that professional courtesy owed to Greenamyre might impair his representation of Stockbridge City (though the primary conflict burden rests on Greenamyre). |
| Greenamyre & Washington | Nikema Williams, et al. (Appellants) | Concurrent Co-Counsel (Joint Advocacy) | Professional relationship creates a “significant risk” (personal interest) for Greenamyre that materially limits his aggressive representation of the Plaintiff-Litigant against Stockbridge City. |
Recommendations for Further Legal Review and Remedial Action
Given the gravity of this ethical breach and its adverse impact on the Plaintiff-Litigant’s representation, the following actions are warranted for legal review:
- Expert Affidavit Preparation: The factual basis established in this report—confirming Mr. Washington’s municipal role and the documented co-counsel filings—provides sufficient foundation for an expert affidavit detailing the GRPC Rule 1.7 violation. This documentation can be used in civil proceedings to demonstrate the impairment of legal advice received by the Plaintiff-Litigant.
- Ethics Complaint Filing: The Plaintiff-Litigant should be advised that the documentation supports the filing of an ethics complaint with the State Bar of Georgia, detailing the violation of the duty of loyalty arising from the materially limiting nature of the concurrent co-counsel relationship.
- Confirmation of Adverse Suit Status: While the query implies the suit against Stockbridge was active or imminent, legal counsel must confirm the exact filing date and status of the retaliation suit to precisely confirm the concurrency timeline relative to the February/April 2024 Williams filings, solidifying the chronological proof of the conflict.
This will be my final story for many months to come. There’s not much we can do now but wait and see. Besides, I’m quite tired of all this and could just as soon leave. But I imagine working this draft for some months and filing it if the situation doesn’t improve. In a way it seems like the time to file has passed. In another way we may be able to argue the discovery of the conflict’s actionable items was within the time frame. Who knows, you’d need a lawyer for that and I don’t think I can stomach talking to another one. And, yes, the city council knows all about it.
Notice how the page numbers are off? 1,3,5? Quinton had something to say on the missing page 4. I wonder what it was?
