Violation #9 – Professional Misconduct of Attorneys – Subornation of Perjury and False Sworn Pleadings 3

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:  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.    VIOLATIONS BY CHRISTOPHER GLYNN — False Statements in Affidavit of 8-25-2005 and Verification of 8-29-2005 – Paragraph 3 of the Affidavit in support of the Complaint for Injunctive Relief filed August 29, 2005 (Paragraph 23 of the Verified Complaint):  “Since 1846, Maid of the Mist has operated boat tours of Niagara Falls for millions of tourists from around the world.”  (Evans Docket #1 — 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.)

2.    Maid of the Mist has not operated boat tours of Niagara Falls since 1846. The two corporate entities defined as “Maid of the Mist” in this lawsuit did not begin in 1846.  The current operator of the boat rides has been operating the business since 1971.

3.    Glynn admitted this in his deposition. (Evans Docket #159 — Deposition of Christopher Glynn, P 276: 22-25, P 277: 1-23.) (Evans Docket #378 — Dec #5 ¶ 24.)  (Exhibit 197 and 198 to Dec #5 — Evans Docket #378.)

4.    I obtained corporate records that prove this statement was false.  (Exhibits 197 and 198 to Dec #5.)

5.   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.)

6.   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.