Violation #7 – Professional Misconduct of Attorneys – Subornation of Perjury and False Sworn Pleadings 1

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 found in the deposition testimony of Maid of the Mist’s managers who admitted they had no proof.  A Verified Complaint such ads this requires that the statements are true and within the personal knowledge of the person verifying the complaint.  People filing lawsuits can make accusations thatb they can’t prove and aren’t sure about in an UNverified complaint.  But in this case, Christopher Glynn was told to swear that all of this was true and within his personal kinowledge when he knew it was not.  Therefore, this is a False Sworn Pleading.

1.   On August 25, 2005, Christopher Glynn (“Glynn”), President of Maid of the Mist of the Mist and son of the owner, signed and dated a sworn affidavit in anticipation of the filing of the Verified Complaint in Georgia.  (Exhibit #63 to Dec #5 – Evans Docket #378.)  I have stated that 46 of the 50 sworn under penalty of perjury statements in the Affidavit of Glynn were false.  (Evans Docket #378 — Dec #5 ¶ 3.)  I believe I have proven that 44 of the 46 are false with the testimony of Glynn himself or with the testimony of his two managers, Ruddy or Schul.  (Dec #3 — Exhibits 1 and 2.)  Glynn did not have personal knowledge.   I submit that this is a violation of Rule 3.1, 3.3, 4.1, and 8.4 of the GCPC and Local Rule 83.1C.  I submit that this is a violation of Rule 11 of the Federal Rules of Civil Procedure (“FRCP”).  I submit that this is perjury, a violation of O.C.G.A. 16-10-70 and USC 18 § 1621 and USC 18 § 1623.  I submit that this is Making False Statements in violation of 18 USC § 1001.  I submit that this subjects Maid of the Mist to set aside of the judgment and orders pursuant to O.C.G.A. 17-1-4.  I submit that this is theft by deception, a violation of O.C.G.A. 16-8-3.  I submit that this was fraud.  I submit that this was conspiracy to commit fraud.  I sumit that the preparation of the affidavit by Mr. Brown and the signature of Mr. Anderson on the filing constitute subornation of perjury and conspiracy to suborn perjury. I submit that this was one act in violation of the Georgia RICO Act, including O.C.G.A. 16-14-3 and 16-14-4.  I submit that this was a Violation of Federal Civil RICO Act — 18 USC § 1964(c) and 18 USC § 1962(c) and 18 USC § 1962(d).  I submit that this is Witness Tampering in violation of O.C.G.A. 16-10-93 and 18 U.S.C. 1503.  I submit that this is Obstruction Of Justice — influencing testimony — 18 USC § 1512(b).

2.   The sworn statements of Glynn in this Affidavit of August 25, 2005 and Verification of August 29, 2005 are discussed in paragraphs 900 to 1509.

3.    VIOLATIONS BY CHRISTOPHER GLYNN — False Statements in Affidavit of 8-25-2005 and Verification of 8-29-2005 – Paragraph 1 of the Affidavit in support of the Complaint for Injunctive Relief filed August 29, 2005:  “I am the President of Plaintiff Maid of the Mist of the Mist Corporation and Maid of the Mist of the Mist Steamboat Company, Ltd. (collectively “Maid of the Mist”).  As such, I have personal knowledge of the facts set forth herein.” (Evans Docket #1 — Verified Complaint for Injunctive Relief filed August 29, 2005.)  (Proof is detailed in Evans Docket # 377 — Amended Dec #3, Dec #5 — Evans Docket #378, and the paragraphs below.)

4.    Mr. Christopher Glynn (“Glynn”) did not have personal knowledge of the facts set forth in the Verified Complaint, and many of the alleged facts were false. This is detailed quite clearly in paragraphs 900 to 1509 below. (Evans Docket #378 — Dec #5 ¶ 9.)

5.    Glynn knowingly made false statements.  Glynn has subsequently admitted under oath that he did NOT have personal knowledge of various statements made in this affidavit.  He has knowingly made two or more declarations that are inconsistent to the degree that one of them is necessarily false.  This is considered proof positive of perjury.

6.    Glynn signed a false sworn affidavit and has provided a verification of the Complaint that is filled with false sworn statements.  (Evans Docket #378 — Dec #5 ¶ 10.)

7.    VIOLATIONS BY CHRISTOPHER GLYNN — False statements in Affidavit and Verification of Complaint — Perjury — O.C.G.A. 16-10-70 and USC 18 § 1621 and USC 18 § 1623; Making False Statements — 18 USC § 1001; Violation of Federal Civil RICO Act — 18 USC § 1964(c) and 18 USC § 1962(c) and 18 USC § 1962(d); Fraud; Conspiracy to Commit Fraud; Fraud on the Court — Rule 60(d)(3) of the Federal Rules of Civil Procedure; Conspiracy To Defraud United States (Obstruct Justice) — 18 USC § 371. (Proof is in the paragraphs above and the citations therein and exhibits thereto.)

8.   VIOLATIONS BY HAWKINS & PARNELL — FALSE SWORN PLEADINGS — Violation of Rule 11 — False Sworn Pleading.  Violation of RULE 3.1  MERITORIOUS CLAIMS AND CONTENTIONS — shall not file a suit that isn’t meritorious — frivolous if the lawyer is unable to make a good faith argument on the merits of the action based on the facts and the law; Violation of Rule 3.3 of the GCPC — Candor Toward the Tribunal — made false statements of a material fact to the Court; offered evidence that the lawyer knew to be false; Violation of Rule 8.4 of the GCPC — Misconduct; Violation of Local Rule 83.1C — Standards of Professional Conduct.  (Proof is in the paragraphs 898 to 1509 above and the citations therein and exhibits thereto.)

 

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.