Author: William M. Windsor

I have stated in my filings with the courts that I felt Maid of the Mist’s attorneys, Carl Hugo Anderson of Hawkins Parnell Thackson Young and Marc Brown of Phillips Lytle, devised an unconscionable scheme to win the lawsuit.

I filed the following.  If you are facing a dishonest attorney (which is always a high possibility), see if some of these techniques seem familiar:

1.               The scheme of Maid and Maid’s Attorneys will be a factor in fraud on the court, so I believe it will be helpful to understand what I believe the unconscionable scheme of Maid and Maid’s Attorneys was in Civil Action No. 1:06-CV-0714-ODE.  These paragraphs, 13 to 39, represent my opinions, based upon information and belief, but as you read the chronology, I believe you will see what happened and will agree with my opinion.

2.               I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Have Maid’s Buffalo New York attorney, Mr. Brown of Phillips Lytle, draft a scary lawsuit that included criminal accusations of theft and bribery by Alcatraz, even though they knew the complaint was false.

3.               I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Continue with the lies that Maid began making in June 2005, and expand on these lies, and create more lies.  Create a Verified Complaint that was one lie after another.

4.               I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Raise so many different issues that Alcatraz and I would have to respond to all types of different things thus diluting their ability to effectively respond on motions due to page limits.  Do not identify a cause of action so Alcatraz and I would have to guess and respond to all types of different things thus diluting our ability to effectively respond on motions due to page limits.

5.               I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Name me personally to put legal pressure on me to want to avoid a lawsuit where I could be held personally responsible and so that Alcatraz and I would have twice as much legal expense.

6.               I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Use the lies in the complaint to try to scare Alcatraz and me into settling the lawsuit in September 2005 and agreeing to an injunction.

7.               I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Use the lies in the Verified Complaint to paint such a negative picture of Alcatraz and me that the judge would quickly and easily grant a Temporary Restraining Order.

8.               I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Get a quick settlement as that would be the best solution to all the slander by Maid’s employees; it would end Maid’s breach of contract problem with the Niagara Parks Commission (“NPC”) and New York State Parks (“OPRHP”); and it would cover up all the lies and perjury; and Maid would not have to explain why Maid and its attorneys refused to speak to Alcatraz.

9.               I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Get an attorney in Atlanta who wasn’t familiar with the client or the case to sign the bogus pleadings.

10.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Recruit mean, nasty customer Judith L. Berry (“Berry”) as part of the conspiracy.  Get her to lie and distort the truth so information from her could be used in the Verified Complaint.

11.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Get the commitment of key Maid employees to continue to participate in this conspiracy to commit fraud, especially Christopher Glynn (“Glynn”), Timothy P. Ruddy (“Ruddy”), and Robert J. Schul (“Schul”).

12.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  “Modify” some documents to go with the Verified Complaint in an attempt to manufacture documents that would support the lies.

13.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Call Alcatraz and me as soon as we had a few days to review the Verified Complaint, and try to get us to settle.

14.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  When Alcatraz and I refused to settle because the Verified Complaint was one false sworn statement after another, the scheme had to become lie again and again and again.  That was the best way to try to keep Glynn from being found guilty of perjury.

15.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Refund the prepayments of over $10,000 that Alcatraz had made so retention of that money would not become a counterclaim and do it would eliminate that money as a set-off against any damages.

16.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Have as much ex parte communication as possible with the Judge and the Judge’s staff.

17.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Make discovery abuse even more important because Glynn had lied too much.

18.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Give Alcatraz and me as little information as possible, stall, delay, and abuse discovery to gain an advantage over Alcatraz and me.

19.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Provide essentially no information in Interrogatory responses.

20.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Produce only a few documents that Alcatraz and I didn’t already have when required to produce documnets.

21.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Sandbag on documents and witnesses on the Joint Preliminary Report and Discovery Schedule.

22.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Delay producing anyone for a 30(b)(6) deposition for as long as possible.

23.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Stall on producing additional documents and stall on producing witnesses for depositions while claiming to cooperate with the Defendants in scheduling all needed witnesses.

24.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Pretend that witnesses will be produced, and then refuse to produce the Canadian witnesses when Alcatraz and I would no longer have the time to go through the Hague Convention to arrange their depositions.

25.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Decide which documents to never produce that would hurt Maid’s position, and decide which documents that would help Maid’s position to conceal until it was too late for Alcatraz and me to do much with it.

26.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Hold some documents back until the last week of discovery so Alcatraz and I would not have the information when they were completing their depositions.

27.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  Lie.  For example, when some documents appeared in a deposition of a non-party witness in January 2007, Mr. Anderson claimed he had already provided those documents.  That was, of course, false.

28.            I believe the unconscionable scheme of Maid and Maid’s Attorneys was:  In summary judgment filings, use affidavits for many witnesses not on Maid’s witness list, and use many documents that were held back until December 5, 2006.  In fact, most of the documents attached to these affidavits were documents that should have been produced in December 2005 but were concealed from Alcatraz and me until 25 days before discovery closed in 2006.