2005 Archives - Lawless America

Violation #3 – Professional Misconduct of Attorneys – Concealing Windsor’s Fax of July 28, 2005

The following information is taken from a sworn affidavit that I filed with the courts as part of complaints about the professional misconduct of the attorneys involved:

1. July 27, 2005 — Just before midnight, I made the changes to the E-Ticket that Carlson requested Alcatraz make by July 28, 2005. Proof of this can be seen in the E-Tickets for July 28, 2005, because every E-Ticket purchased that day showed this change to the E-Ticket. (Exhibit 252 to Dec #5 – Evans Docket #378.)

2. Because Alcatraz had emphatically refused to make such a change to the Alcatraz E-Tickets previously, I believe Maid of the Mist felt like they would be able to use such a refusal to justify their wrongful termination of the contract. They were very surprised when they discovered that Alcatraz had made the change. They had to scramble, and that meant more lies.

3. On July 28, 2005 at 10:28 am, I emailed Carlson, Glynn, Schul, and Bazzo to advise that the change had been made to the E-Ticket as requested in the July 19, 2005 letter. “The change you requested was made last night: Maid of the Mist base ticket price is $13.00 Canadian for adults and $8.00 Canadian for children. There is an additional service charge added to the cost of these tickets, which was included in the price you agreed to pay on the web site. We have shown the price in Canadian funds. We are converting our system so most of our Niagara Falls prices will be shown Canadian since we primarily deal with Canadian tour operators. We have sold 1,697 tickets for you thus far this year. Bill Windsor.” (Exhibit #115 to Dec #5 – Evans Docket #378.)

4. July 28, 2005 — A copy of this changed E-Ticket was faxed to Carlson by me on July 28, 2005. (Maid of the Mist never produced this fax.) (Exhibit #117 to Dec #5 – Evans Docket #378.) E-Tickets for July 28, 2005 customers prove that the change was made. (Exhibit #252 and 610 to Dec #5 – Evans Docket #378.)

5. VIOLATIONS BY HAWKINS & PARNELL –“ Violation of Rule 3.4 of State Bar of Georgia Code of professional Conduct by concealing Windsor’s fax of July 28, 2005. A lawyer shall not unlawfully obstruct another party’s access to evidence;shall not unlawfully alter, destroy or conceal a document or other material having potential evidentiary value;shall not counsel or assist another person to do any such act; shall ensure that evidence in a case is to be marshaled competitively; shall not disregard the rights of the opposing party or counsel. (Proof is provided in the paragraph above and citations therein, oral contract, and in Exhibits 115, 117, and 252 to Dec #5 – Evans Docket #378.)

6. VIOLATIONS BY HAWKINS & PARNELL — Violation of Rule 34 of the Federal Rules of Civil Procedure by failing to produce Windsor’s fax of July 28, 2005; Violation of Rule 11 of the Federal Rules of Civil Procedure by signing false pleadings about document production and failing to produce Windsor’s fax of July 28, 2005; Violation of Local Rule 83.1C by concealing Windsor’s fax of July 28, 2005; Obstruction Of Justice — concealing documents — concealing Windsor’s fax of July 28, 2005, in violation of 18 USC § 1512(c) and O.C.G.A. 16-10-93; Conspiracy To Defraud United States (Obstruct Justice) in concealing Windsor’s fax of July 28, 2005 in violation of 18 USC § 371; Fraud on the Courtin concealing Windsor’s fax of July 28, 2005 in violation of FRCP Rule 60(d)(3); Violation of Federal Civil RICO Act pursuant to 18 USC § 1964(c) and 18 USC § 1962(c) and 18 USC § 1962(d). (Proof is provided in the paragraph above and citations therein, oral contract, and in Exhibits 115, 117, and 252 to Dec #5 – Evans Docket #378.)

7. VIOLATIONS BY CARL HUGO ANDERSON — Violation of Rule 3.4 of State Bar of Georgia Code of Professional Conduct by concealing Windsor’s fax of July 28, 2005. A lawyer shall not unlawfully obstruct another party’s access to evidence; shall not unlawfully alter, destroy or conceal a document or other material having potential evidentiary value;shall not counsel or assist another person to do any such act; shall ensure that evidence in a case is to be marshaled competitively; shall not disregard the rights of the opposing party or counsel. (Proof is provided in the paragraph above and citations therein, oral contract, and in Exhibits 115, 117, and 252 to Dec #5 – Evans Docket #378.)

8. VIOLATIONS BY CARL HUGO ANDERSON — Violation of Rule 34 of the Federal Rules of Civil Procedure by failing to produce Windsor’s fax of July 28, 2005; Violation of Rule 11 of the Federal Rules of Civil Procedure by signing false pleadings about document production and failing to produce Windsor’s fax of July 28, 2005; Violation of Local Rule 83.1C by concealing Windsor’s fax of July 28, 2005; Obstruction Of Justice — concealing documents — concealing Windsor’s fax of July 28, 2005, in violation of 18 USC Â§ 1512(c) and O.C.G.A. 16-10-93; Conspiracy To Defraud United States (Obstruct Justice) in concealing Windsor’s fax of July 28, 2005 in violation of 18 USC § 371; Fraud on the Courtin concealing Windsor’s fax of July 28, 2005 in violation of FRCP Rule 60(d)(3); Violation of Federal Civil RICO Act pursuant to 18 USC § 1964(c) and 18 USC § 1962(c) and 18 USC § 1962(d). (Proof is provided in the paragraph above and citations therein, oral contract, and in Exhibits 115, 117, and 252 to Dec #5 – Evans Docket #378.)

9. VIOLATIONS BY PHILLIPS LYTLE — Violation of Rule 3.4 of State Bar of Georgia Code of Professional Conduct by concealing Windsor’s fax of July 28, 2005. A lawyer shall not unlawfully obstruct another party’s access to evidence;shall not unlawfully alter, destroy or conceal a document or other material having potential evidentiary value;shall not counsel or assist another person to do any such act; shall ensure that evidence in a case is to be marshaled competitively; shall not disregard the rights of the opposing party or counsel. (Proof is provided in the paragraph above and citations therein, oral contract, and in Exhibits 115, 117, and 252 to Dec #5 – Evans Docket #378.)

10. VIOLATIONS BY PHILLIPS LYTLE — Violation of Rule 34 of the Federal Rules of Civil Procedure by failing to produce Windsor’s fax of July 28, 2005; Violation of Rule 11 of the Federal Rules of Civil Procedure by signing false pleadings about document production and failing to produce Windsor’s fax of July 28, 2005; Violation of Local Rule 83.1C by concealing Windsor’s fax of July 28, 2005; Obstruction Of Justice — concealing documents — concealing Windsor’s fax of July 28, 2005, in violation of 18 USC § 1512(c) and O.C.G.A. 16-10-93; Conspiracy To Defraud United States (Obstruct Justice) in concealing Windsor’s fax of July 28, 2005 in violation of 18 USC § 371; Fraud on the Court in concealing Windsor’s fax of July 28, 2005 in violation of FRCP Rule 60(d)(3); Violation of Federal Civil RICO Act pursuant to 18 USC § 1964(c) and 18 USC § 1962(c) and 18 USC § 1962(d). (Proof is provided in the paragraph above and citations therein, oral contract, and in Exhibits 115, 117, and 252 to Dec #5 – Evans Docket #378.)

11. VIOLATIONS BY MARC W. BROWN — Violation of Rule 3.4 of State Bar of Georgia Code of Professional Conduct by concealing Windsor’s fax of July 28, 2005. A lawyer shall not unlawfully obstruct another party’s access to evidence;shall not unlawfully alter, destroy or conceal a document or other material having potential evidentiary value;shall not counsel or assist another person to do any such act; shall ensure that evidence in a case is to be marshaled competitively; shall not disregard the rights of the opposing party or counsel. (Proof is provided in the paragraph above and citations therein, oral contract, and in Exhibits 115, 117, and 252 to Dec #5 – Evans Docket #378.)

12. VIOLATIONS BY MARC W. BROWN — Violation of Rule 34 of the Federal Rules of Civil Procedure by failing to produce Windsor’s fax of July 28, 2005; Violation of Rule 11 of the Federal Rules of Civil Procedure by signing false pleadings about document production and failing to produce Windsor’s fax of July 28, 2005; Violation of Local Rule 83.1C by concealing Windsor’s fax of July 28, 2005; Obstruction Of Justice — concealing documents — concealing Windsor’s fax of July 28, 2005, in violation of 18 USC § 1512(c) and O.C.G.A. 16-10-93; Conspiracy To Defraud United States (Obstruct Justice) in concealing Windsor’s fax of July 28, 2005 in violation of 18 USC § 371; Fraud on the Courtin concealing Windsor’s fax of July 28, 2005 in violation of FRCP Rule 60(d)(3); Violation of Federal Civil RICO Act pursuant to 18 USC § 1964(c) and 18 USC § 1962(c) and 18 USC § 1962(d). (Proof is provided in the paragraph above and citations therein, oral contract, and in Exhibits 115, 117, and 252 to Dec #5 – Evans Docket #378.)

I have filed a Verified Complaint of Professional Misconduct against Carl Hugo Anderson, Hawkins Parnell Thackston Young, Sarah Bright, Brett Mendell, Phillips Lytle, Marc Brown, and Arthur P. Russ. I have also filed a lawsuit against most of these attorneys for fraud upon the courts, RICO violations, and other violations in the United States District Court for the Northern District of Georgia – Civil Action No. 1:09-CV-02027-WSD. I am filing a complaint with the State Bar of Georgia and the New York State Bar Association.

Violation #4 – Professional Misconduct of Attorneys – Concealing Windsor’s Fax of August 10, 2005

The following information is taken from a sworn affidavit that I filed with the courts as part of complaints about the professional misconduct of the attorneys involved: The proof of this violation is quite simple. The Time Slips of Maid of the Mist’s Attorneys show that the attorneys received these documents. The document productions from Maid of the Mist show that these requested documents were never produced. These documents were damaging to them, so they concealed them.

1. On August 10, 2005, I decided to contact Maid of the Mist’s Attorney in Buffalo, New York, Mr. Arthur P. Russ. I sent him a six page fax that included a credit card authorization for Maid of the Mist to use. (Exhibit #3040 to Dec #25.) (Exhibit 735 to Dec #5 — Evans Docket #378.)

2. On August 10, 2005, Time Slips prove that Mr. Russ reviewed the fax from me. [Evans Docket #253-15, P 1.] Maid of the Mist never produced this fax, but this Time Slip shows that Maid of the Mist’s Attorneys had the fax. The fax was important because it included the credit card authorization. The fax is not included in the documents produced; I have placed all of Maid of the Mist’s document production into the record as evidence. (Evans Docket #378 — Exhibit 178, 92, 266, 660, and 84 to Dec #5; Exhibit 1270 to Dec #25; and Exhibit S-1 to Schul Depo — Evans Docket #133 and 160.) (Exhibit 3041 to Dec #25.)

3. VIOLATIONS BY HAWKINS & PARNELL — Violation of FRCP Rule 37 by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Local Rule 83.1C; Violation of Rule 8.4 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Rule 3.3 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Rule 3.4 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Rule 4.1 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Obstruction Of Justice — concealing documents by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005, in violation of 18 USC § 1512(c) and O.C.G.A. 16-10-93. Proof is provided in the paragraph above and the citations therein;Exhibit #3040 to Dec #25; Evans Docket #378 — Exhibit 178, 92, 266, 660, and 84 to Dec #5; Exhibit 1270 to Dec #25; and Exhibit S-1 to Schul Depo — Evans Docket #133 and 160.)

4. VIOLATIONS BY CARL HUGO ANDERSON — Violation of FRCP Rule 37 by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Local Rule 83.1C; Violation of Rule 8.4 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Rule 3.3 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Rule 3.4 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Rule 4.1 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Obstruction Of Justice — concealing documents by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005, in violation of 18 USC § 1512(c) and O.C.G.A. 16-10-93. Proof is provided in the paragraph above and the citations therein; Exhibit #3040 to Dec #25; Evans Docket #378 — Exhibit 178, 92, 266, 660, and 84 to Dec #5; Exhibit 1270 to Dec #25; and Exhibit S-1 to Schul Depo –“ Evans Docket #133 and 160.)

5. VIOLATIONS BY PHILLIPS LYTLE — Violation of FRCP Rule 37 by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Local Rule 83.1C; Violation of Rule 8.4 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Rule 3.3 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Rule 3.4 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Rule 4.1 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Obstruction Of Justice — concealing documents by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005, in violation of 18 USC § 1512(c) and O.C.G.A. 16-10-93. Proof is provided in the paragraph above and the citations therein; Exhibit #3040 to Dec #25; Evans Docket #378 — Exhibit 178, 92, 266, 660, and 84 to Dec #5; Exhibit 1270 to Dec #25; and Exhibit S-1 to Schul Depo — Evans Docket #133 and 160.)

6. VIOLATIONS BY MARC W. BROWN — Violation of FRCP Rule 37 by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Local Rule 83.1C; Violation of Rule 8.4 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Rule 3.3 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Rule 3.4 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Rule 4.1 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Obstruction Of Justice –“ concealing documents by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005, in violation of 18 USC § 1512(c) and O.C.G.A. 16-10-93. Proof is provided in the paragraph above and the citations therein; Exhibit #3040 to Dec #25; Evans Docket #378 — Exhibit 178, 92, 266, 660, and 84 to Dec #5; Exhibit 1270 to Dec #25; and Exhibit S-1 to Schul Depo — Evans Docket #133 and 160.)

7. VIOLATIONS BY ARTHUR P. RUSS — Violation of FRCP Rule 37 by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Local Rule 83.1C; Violation of Rule 8.4 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Rule 3.3 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Rule 3.4 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Violation of Rule 4.1 of the GCPC by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005; Obstruction Of Justice –“ concealing documents by failing to produce the six-page fax that I sent to Mr. Arthur P. Russ on August 10, 2005, in violation of 18 USC § 1512(c) and O.C.G.A. 16-10-93. Proof is provided in the paragraph above and the citations therein; Exhibit #3040 to Dec #25; Evans Docket #378 — Exhibit 178, 92, 266, 660, and 84 to Dec #5; Exhibit 1270 to Dec #25; and Exhibit S-1 to Schul Depo — Evans Docket #133 and 160.)

Background for this Legal Action about Judicial Corruption — December 28, 2005

This information is taken from a legal filing in the United States District Court for the Northern District of Georgia.

Maid of the Mist Files False Sworn Interrogatories

1. On December 28, 2005, Maidâ€™s Response to Interrogatories was sworn to by Christopher Glynn.

2. On December 28, 2005, two (2) False Sworn Statements were in Maidâ€™s Response to Interrogatories sworn to by Christopher Glynn.

3. This is addressed on pages 681 to 715 of (Dec #25 â€“ Evans Docket #462).

4. Glynn swears the following is true as of December 28, 2005:

5. â€œâ€¦Maid is unaware of any discussions initiated by Maid or its employees that defendants are â€œdishonest, operate a scam, or are fraudulentâ€ during its communications with customers, prospective customers, and other internet tour operators.â€

6. â€œThe facts and circumstances forming the basis for Maidâ€™s allegation that defendants failed to refund its customers who purchased Defendantsâ€™ Maid Vouchers includes the email and follow-up telephone conferences with Judith Berry, a Maid customer who purchased Defendantsâ€™ Maid Vouchers.â€

7. The filing of the response to Interrogatories by Mr. Anderson, signed while under his oath as an officer of the court as a member of the State Bar of Georgia, was a false sworn pleading.

8. The Plaintiff believes this is subornation of perjury as well as fraud upon the court and violations of the GCPC and FRCP.

9. Maid attorneys knew that these statements were false, but they did nothing about it.

10. The Plaintiff believes this is subornation of perjury as well as fraud upon the court and violations of the GCPC and FRCP.

11. Glynn swore that Maid knew nothing about Maid employees telling customers that Alcatraz was an Internet Scam.

12. This was not true.

13. Glynn swore that The Plaintiff and Alcatraz stole from customers, but he knew that was false.

14. Glynn acted with reckless indifference to the truth.

15. 94 alleged lies and countingâ€¦.

Background for this Legal Action about Judicial Corruption — August 29, 2005

This information is taken from a legal filing in the United States District Court for the Northern District of Georgia.

Maid of the Mist files a Lawsuit against Alcatraz Media and William M. Windsor

1. On August 25, 2005, Christopher Glynn (â€œGlynnâ€), President of Plaintiffs (Maid of the Mist), signed a sworn affidavit to be used with the filing of the lawsuit in Gwinnett County Court, Georgia. [Evans Docket #1.]

2. The Plaintiff believes that as many as 46 of the 50 paragraphs were false or incorrect.

3. This is a False Sworn Affidavit.

4. Proof to show that as many as 46 of the statements are false is set out on pages 364 to 553 of Dec #25 (Evans Docket #462).

5. Glynn swore that his statements were his personal knowledge, but that was false.

6. Personal knowledge means the information is known from direct experience rather than hearing about it from someone else or making it up.

7. Glynn swore that everything in his affidavit was true and correct, but that was false.

8. MOTM, Steamboat, Glynn, and Maidâ€™s Attorneys each swear that each statement was true on August 25, 2005:

9. â€œI am the President of Plaintiffs Maid of the Mist Corporation and Maid of the Mist Steamboat Company, Ltd. (collectively â€œMaidâ€). As such, I have personal knowledge of the facts set forth herein.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶1.)

10. â€œI am making this Declaration in support of Maidâ€™s application for a Temporary Restraining Order and interlocutory and permanent injunctive relief to enjoin Defendants Alcatraz Media, LLC, Alcatraz Media, Inc., William M. Windsor from advertising and selling vouchers/e-tickets that are redeemed for Maid tours (â€œDefendantsâ€™ Maid Vouchersâ€) and forcing Defendants to remove any reference to Maid from web sites Defendants currently operate or plan to operate. (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶2.)

11. â€œSince 1846, Maid has operated boat tours of Niagara Falls for millions of tourists from around the world.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶3.)

12. â€œThe tour operators Maid uses are at Maidâ€™s discretion and their rights and privileges to sell vouchers/e-tickets that are redeemed for Maid tickets can be revoked by Maid at any time.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶5.)

13. â€œOn July 29, 2004, Maid accepted Defendantsâ€™ application for credit and to serve as a tour operator with rights and privileges to sell Defendantsâ€™ Maid Vouchers. A copy of Maidâ€™s letter dated July 29, 2004 is attached as Exhibit 1.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶6.)

14. â€œUpon Information and belief, defendants used the world wide web to sell Defendantsâ€™ Maid Vouchers to Maid customers who would obtain Maid tickets at Maidâ€™s ticket offices when Maid vouchers were redeemed. A copy of Defendantsâ€™ Maid Voucher for a Maid tour on July 2, 2005 is attached as Exhibit 2.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶7.)

15. â€œMaid would then bill Defendants at the group rate for Maid tickets, which was $9.65 US or $10.70 Can. The Canadian dollar is approximately worth $0.82 to the United States dollar. A copy of Maidâ€™s 2005 ticket rate sheet is attached as Exhibit 3.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶8.)

16. â€œOn April 21, 2005, Maid opened its 2005 season and began redeeming Defendantsâ€™ Maid Vouchers for Maid tickets.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶9.)

17. â€œHowever, shortly thereafter, Maid began receiving complaints from its customers regarding the cost of Defendantsâ€™ Maid Vouchers.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶10.)

18. â€œSpecifically, Maidâ€™s customers complained that Defendantsâ€™ Maid Vouchers were higher than Maidâ€™s retail ticket prices and that Defendantsâ€™ Maid Vouchers did not include additional services or attractions for the additional cost.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶11.)

19. â€œThese complaints were also directed at Maid.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶12.)

20. â€œIn June 2005, Maid learned that on Defendantsâ€™ web site, Defendants misrepresented Maidâ€™s retail ticket prices as costing $18.95 US.â€ Affidavit of Christopher Glynn dated August 25, 2005, Â¶13.)

21. â€œMaid also learned that Defendantsâ€™ Maid Vouchers cost $13.95 US for adults and $12.95 US for children while Maidâ€™s retail tickets cost $11.50 US or $13.00 Can for adults and $6.75 US or $8.00 Can for children. See Exhibit 3.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶14.)

22. â€œOn June 14, 2005, Maid informed Defendants about its customers who complained that they were overcharged by Defendants. A copy of Maidâ€™s letter dated June 14, 2005 is attached as Exhibit 4.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶15.)

23. â€œIn addition, Maid informed Defendants that they would no longer be accepting Defendantsâ€™ Maid Vouchers after June 30, 2005. See Exhibit 4.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶16.)

24. â€œShortly thereafter, Maid spoke with Defendantsâ€™ representative and allowed Defendants an opportunity to rectify the pricing problem regarding the sale of Defendantsâ€™ Maid Vouchers.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶17.)

25. â€œHowever, over the next month, Maid continued to receive daily complaints from customers who purchased Defendantsâ€™ Maid Vouchers at prices higher than Maidâ€™s retail ticket prices.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶18.)

26. â€œAgain, these complaints were also directed at Maid.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶19.)

27. â€œOn July 19, 2005, Maid informed Defendants that Maidâ€™s customers continue to feel that they were misled and overcharged by Defendants and Maid. A copy of Maidâ€™s letter dated July 19, 2005 is attached as Exhibit 5.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶20.)

28. â€œMoreover, Maid specifically requested that Defendants state Maidâ€™s retail ticket prices and Defendantsâ€™ service charges on Defendantsâ€™ Maid Vouchers and gave Defendants until July 27, 2005 to fix their pricing problem. See Exhibit 5.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶21.)

29. â€œOn July 29, 2005, after Defendants failed to rectify their pricing problem, Maid requested that Defendants immediately discontinue the advertising and sale of Defendantsâ€™ Maid Vouchers. A copy of Maidâ€™s letter dated July 29, 2005 is attached as Exhibit 6.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶22.)

30. â€œOn July 30, 2005, Maid informed its customers that they would no longer honor Defendantsâ€™ Maid Vouchers that were purchased after July 29, 2005. A copy of Maidâ€™s notice dated July 30, 2005 is attached as Exhibit 7.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶23.)

31. â€œOn July 30, 2005, Defendants continued to sell Defendantsâ€™ Maid Vouchers for Maid tour dates in August, 2005. A copy of Defendantsâ€™ Maid Voucher with receipt for a tour on August 2, 2005 is attached as Exhibit 8.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶24.)

32. â€œWhen Maid customers attempted to redeem Defendantsâ€™ Maid Vouchers for Maid tickets, Maid informed them that Defendantsâ€™ Maid Vouchers were no longer honored. See Exhibit 7.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶25.)

33. â€œThese customers became irate and blamed Maid for not accepting Defendantsâ€™ Maid Vouchers.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶26.)

34. â€œOn August 5, 2005, Maidâ€™s counsel informed Defendants that their actions damaged Maidâ€™s reputation and goodwill and demanded that Defendants immediately discontinue their advertisement and sale of Defendantsâ€™ Maid Vouchers. A copy of the letter from Maidâ€™s counsel dated August 5, 2005 is attached as Exhibit 9.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶27.)

35. â€œOn August 8, 2005 Defendants responded by threatening Maid and by trying to bribe Maid to sell the company. A copy of Defendantsâ€™ e-mail dated August 8, 2005 is attached as Exhibit 10.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶28.)

36. â€œSpecifically, Defendants stated â€œWouldnâ€™t you rather just pay us a seven figure amount and accept that we will be selling Maid of the Mist tickets forever? Write us a big fat check. See Exhibit 10 (emphasis added).â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶29.)

37. â€œIn addition, Defendants stated in their August 12, 2005 e-mail: â€œAlcatraz Media has complied and continue [sic] to comply with all the terms of the contract with Maid of the Mist. Therefore, Alcatraz Media will continue to sell. Alcatraz Media has no intention of ever stopping to sell Maid of the Mist tickets. I myself, personally, am busily preparing a new web site that will solely sell Maid of the Mist tickets.â€ A copy of Defendantsâ€™ e-mail dated August 12, 2005 is attached as Exhibit 11.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶30.)

38. â€œDefendants also claimed they had a contract with Maid, but Maid is unaware of any contract with Defendants. See Exhibit 11 to the Affidavit.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶31.)

39. â€œIndeed, Defendantsâ€™ rights and privileges to act as Maidâ€™s tour operator can be revoked at any time by Maid.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶32.)

40. â€œAs of August 25, 2005, Defendants continue to advertise and sell Defendantsâ€™ Maid Vouchers and include misleading information about Maid on its web site. A copy of Defendantsâ€™ web site dated August 10, 2005 is attached as Exhibit 12.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶33.)

41. â€œSpecifically, Defendants misrepresent Maidâ€™s ticket prices by stating that Maid charges $20.95 US. See Exhibit 3.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶34.)

42. â€œDefendants continue to offer Defendantsâ€™ Maid Vouchers throughout the remainder of the 2005 season, schedule reservation times when Maid does not allow reservations, and state that prior dates were â€œsold outâ€ when, in fact, Maidâ€™s tours were not sold out.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶35.)

43. â€œIn addition, Defendants use their web site to encourage Maidâ€™s customers, including those who did not purchase Defendantsâ€™ Maid Vouchers to file complaints with the Better Business Bureau. A copy of a complaint with the Better Business Bureau dated August 16, 2005 is attached as Exhibit 13.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶36.)

44. â€œOn August 16, 2005, Maid customer Scott McGrew informed the Better Business Bureau that he â€œattemptedâ€ [sic] to contact the company online and they directed me to the BBB. I bought ticketsâ€¦when we visited the park.â€ See Exhibit 13 (emphasis added).â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶37.)

45. â€œIndeed, Mr. McGrew did not purchase Defendantsâ€™ Maid Vouchers and, as set forth in their August 12, 2005 e-mail, Defendants are clearly using their web site to direct Maidâ€™s customers to file complaints with the Better Business Bureau. See Exhibit 11.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶38.)

46. â€œIf Mr. McGrew would have truly contacted â€œthe company,â€ Maid would have addressed and resolved his complaint.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶39.)

47. â€œIn fact, Maid is unaware of any complaint ever filed with the Better Business Bureau by Maidâ€™s customers.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶40.)

48. â€œMoreover, upon information and belief, Defendants are not refunding their customers who purchased Defendantsâ€™ Maid Vouchers that were not honored by Maid. A copy of an e-mail dated August 25, 2005 from a Maid customer who purchased Defendantsâ€™ Maid Vouchers is attached as Exhibit 14.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶41.)

49. â€œOn August 25, 2005, Judie Berry, one of Maidâ€™s customers who purchased Defendantsâ€™ Maid Vouchers, wrote that Defendants left threatening messages on her answering machine in response to her e-mail and telephone messages requesting a refund for her purchase.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶42.)

50. â€œSpecifically, Ms. Berry wrote that Defendants stated that they were: â€œgoing to â€˜come after me.â€™ Called me the b— word. Called me a â€˜lowlife, scumbag, scum of the earth.â€™ [Defendants] also stated that [they] hoped I do something against the law, something criminal, so â€˜we can put you in jail.â€™â€ See Exhibit 14 (emphasis added).â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶43.)

51. â€œNotably, Maid never billed Defendants for Defendantsâ€™ Maid Vouchers that were not honored.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶44.)

52. â€œTherefore, by threatening and stealing from Maidâ€™s customers, Defendants are damaging Maidâ€™s reputation and goodwill.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶45.)

53. â€œUnless Defendants are enjoined from advertising and selling Defendantsâ€™ Maid Vouchers and are forced to remove Maid from web sites they currently operate or plan to operate, Maid will continue to suffer immediate and irreparable harm and its reputation and goodwill will continue to be tarnished.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶46.)

54. â€œThe harm suffered by Maid far exceeds any inconvenience that would be caused to Defendants if Defendants continue to hold themselves out as authorized to sell Defendantsâ€™ Maid Tickets and use Maidâ€™s name and images on web sites that they maintain, use and/or control.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶47.)

55. â€œBased on Maidâ€™s termination of Defendantsâ€™ right to sell Defendantsâ€™ Maid Vouchers and Defendantsâ€™ misrepresentations on its web site regarding Maidâ€™s ticket prices, the availability of Maidâ€™s tickets, and their ability to sell Defendantsâ€™ Maid Vouchers, the equities clearly balance in Maidâ€™s favor.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶48.)

56. â€œIt is highly likely that Maid will ultimately succeed on the merits and be granted a permanent injunction enjoining Defendants from advertising and selling Defendantsâ€™ Maid Vouchers and forcing Defendants to remove Maid from web sites that Defendants currently operate or plan to operate.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶49.)

57. â€œIn addition, based on Defendantsâ€™ bad faith actions, Maid should be entitled to attorneyâ€™s fees and costs of litigation.â€ (Evans Docket #1 — Affidavit of Christopher Glynn dated August 25, 2005, Â¶50.)

58. In deposition testimony, Glynn admitted that some of the statements in his August 25, 2005 Affidavit were not true.

59. In his deposition testimony, Ruddy testified that some of the statements in Glynnâ€™s August 25, 2005 affidavit were not true.

60. In his deposition testimony, Schul testified that some of the statements in Glynnâ€™s August 25, 2005 affidavit were not true.

61. Alcatraz, Windsor, and Bazzo testified in depositions that statements in Glynnâ€™s affidavit were not true.

62. Glynnâ€™s August 25, 2005 affidavit was drafted by Mr. Anderson, Mr. Brown, and Mr. Russ.

63. The drafting of this affidavit by Mr. Anderson, Mr. Brown, and Mr. Russ, while under oath as officers of the court as members of the Bar, was improper, and statements in the affidavit were known to be false by the attorneys.

64. In drafting this affidavit, Mr. Anderson, Mr. Brown, and Mr. Russ acted with reckless disregard for the truth.

65. No Maid attorney ever advised the courts that any of these statements were false.

66. The Plaintiff believes the conduct of Maid attorneys is subornation of perjury as well as fraud on the court, and it violates the GCPC and FRCP.

67. 46 alleged lies and countingâ€¦.

68. On August 29, 2005, Maid filed a Verified Complaint in Gwinnett County Court, Georgia with a sworn verification by Glynn.

69. Plaintiff believes that as many as 46 of the 50 paragraphs were false or incorrect. [Evans Docket #1.]

70. This is a False Sworn Pleading.

71. Proof to show that as many as 44 of the 46 paragraphs are false is set out on pages 364 to 553 of (Dec #25 â€“ Evans Docket #462).

72. The filing of this Verified Complaint by Mr. Anderson, signed while under his oath as an officer of the court as a member of the State Bar of Georgia, constituted a false sworn pleading.

73. Plaintiff believes Mr. Andersonâ€™s actions are subornation of perjury as well as fraud on the court and violate the GCPC and FRCP.

74. Maid attorneys knew and/or subsequently learned that many of these statements were false, but no Maid attorney ever notified the courts.

75. The Plaintiff believes this is subornation of perjury as well as fraud on the court and violations of the GCPC and FRCP.

76. 92 alleged lies and countingâ€¦.

77. When Maid sued, they sued Alcatraz and William M. Windsor personally (Ryanâ€™s Dad).

78. The lawsuit falsely and maliciously claimed that Windsor operated his own business and did everything that Alcatraz was accused of doing.

79. Maid and Maid attorneys knew this was false.

80. Ruddy testified that Windsor should not have been included in many of the sworn paragraphs in Glynnâ€™s affidavit and verification.

81. The Plaintiff and Alcatraz testified in depositions that these claims of Maid against Windsor were false.

82. Maid never produced any evidence to prove that Maid had any valid legal claim against Windsor for tortious interference.

83. Maid never produced any evidence to prove that Maid had any valid legal claim against Windsor for anything.

84. Maid attorneys never amended the Verified Complaint.

85. Maid attorneys never advised the courts of Ruddyâ€™s 30(b)(6) testimony in this regard.

Background for this Legal Action about Judicial Corruption — 2001

This legfal action is best understood with some background.

When Alcatraz Media added a toll-free number in 2001, the phone started “ringing off the hook.” Much to my son’s chagrin, the callers were not interested in Internet services; they wanted tickets to Alcatraz. There apparently were no companies named Alcatraz listed with directory assistance in San Francisco, because Ryan was told that when people called directory assistance for a number for “Alcatraz,” the operators would apparently say the only listing they had was a toll-free number for “Alcatraz Media.” Many would then call the toll-free number to reach my son.

My son was the only employee, and every incoming call rang to his cell phone. After many days telling people that Alcatraz Media offered email service, web hosting, and web design, and didn’t sell Alcatraz tickets, and after many hundreds of dollars in toll-free telephone bills, my son seriously considered changing the company’s name. The other option was to begin to sell Alcatraz tours. This was a joke when first discussed, but after getting the toll-free telephone bill and realizing how many calls he was getting, my son thought it might make sense to try to capitalize on this accident. So, he began selling tours to Alcatraz Penitentiary in San Francisco in 2001.

Soon after launching the Alcatraz/San Francisco website late in 2001, my sonan felt it would be wise to diversify so Alcatraz Media would not be totally dependent upon one market. Tours and activities were added in Hollywood, Los Angeles, San Diego, Seattle, Orlando, and a few other markets in 2003.

The Company was largely a two-person operation (a computer person and my son) until the summer of 2003. Alcatraz opened its first real office in April 2004 when the first employees were hired. Prior to that time, the business was a virtual company with a few independent contract workers scattered around the country.

From September 2003 through March 2004, the business operated with a telephone system installed in our garage in Atlanta Georgia. My wife and brother handled the calls. A small office was finally opened in Norcross Georgia in April 2004. Alcatraz moved to a larger space less than a year later. Atlanta was chosen because family was here to help, and the cost of an office and staff in San Francisco was cost-prohibitive for a business such as this that works on a very small net profit margin.

A major expansion was undertaken in 2004 and 2005. By the close of 2005, Alcatraz had achieved most of its North American territorial expansion goals with operations in 215 cities in all 50 states and most of the Canadian provinces.

Total revenues for the business were less than $60,000 in 2001 but grew to tens of millions of dollars by 2008.