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Last week, I sent an email with information about this corruption to every major newspaper in the country, the television and radio networks, the local Atlanta media, major online media, and assorted others. Hundreds of emails.
Guess how many responded.
Not a single solitary one.
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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:
Continue reading Violation #1 – Professional Misconduct of Attorneys – Ex Parte Communications
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The following information is taken from a sworn affidavit that I filed with the courts as part of complaints about the judicial misconduct of Judge Orinda D. Evans:
Continue reading Violation #1 – Judicial Misconduct of Judge Orinda D. Evans – Lack of Impartiality
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The following information is taken from a sworn affidavit that I filed with the courts as part of complaints about the judicial misconduct of Judge Orinda D. Evans:
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The following information is taken from a sworn affidavit that I filed with the courts as part of complaints about the judicial misconduct of Judge Orinda D. Evans:
1. Judge Evans allowed Maid’s Attorneys to run wild and abuse the legal system in this case. Judge Evans demonstrated pervasive bias throughout this proceeding. Judge Evans has demonstrated a personal bias in favor of Maid and a prejudice against Alcatraz and me, in particular. Judge Evans has withheld evidence from Alcatraz and me. Judge Evans has not demonstrated the impartiality required of a judge. To understand the gross professional misconduct of Judge Evans, see the Second Motion to Recuse filed June 4, 2009 and Dec #23 attached thereto [Evans Docket #406] and the Motion to Disqualify and Dec #23 and 32 attached thereto [Duffey Docket #17].
2. VIOLATIONS BY JUDGE ORINDA D. EVANS — Lack of Impartiality. I submit that this lack of impartiality is a violation of Canon 1 of the Code of Conduct for United States Judges; I submit that this lack of impartiality is a violation of Canon 2 and 2A. of the Code of Conduct for United States Judges; I submit that this lack of impartiality is a violation of Canon 3 and 3B.(5) of the Code of Conduct for United States Judges. (Proof is provided in paragraphs above, the Second Motion to Recuse filed June 4, 2009 and Dec #23 attached thereto (Evans Docket #406) and the Motion to Disqualify and Dec #23 and 32 attached thereto (Duffey Docket #17) and throughout Dec #25.)
I have filed a Judicial Misconduct Complaint against Judge Orinda D. Evans with the Eleventh Circuit Court of Appeals. I previously filed a Judicial Misconduct Complaint against Judge Evans that was ignored. I also have a lawsuit pending against Judge Orinda D. Evans for Fraud Upon the Court (Civil Action No. 1:09-CV-02027-WSD in the United States District Court for the Northern District of Georgia.
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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:
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The following information is taken from a sworn affidavit that I filed with the courts as part of complaints about the judicial misconduct of Judge Orinda D. Evans:
1. I submit that it is possible that Judge Evans and/or a clerk for Judge Evans may have been improperly influenced in this case. I believe it is possible that improper influence could be a criminal violation, though I have no proof. This is only a suspicion of a possibility, and I have this suspicion because the behavior of Judge Evans in this matter makes no logical sense to me.
2. The Time Slips of Maid’s Attorneys show that there was extensive ex parte communication between Maid’s Attorneys and Judge Evans and her staff. While some of this may be permissible, the volume of ex parte contact certainly indicates that there was plenty of opportunity for Judge Evans to be improperly influenced. There were conversations and communications between Judge Evans and Maid’s Attorneys that Judge Evans did not reveal to Alcatraz and me. (Exhibit #1 to Dec #23 – Evans Docket #406.) [Evans Docket #253-8, 253-15, 253-10.] (Exhibit #967 to Dec #25.) (I submit that this is a violation of Rule 3.4 and 8.4 of the GCPC and Local Rule 83.1C. I submit that this is a violation of Canon 3 of the Code of Conduct for United States Judges.)
3. VIOLATIONS BY JUDGE ORINDA D. EVANS — I submit that this ex parte communication is a violation of Canon 3 of the Code of Conduct for United States Judges. (Proof is provided in the paragraphs above, Evans Docket #253-8, 253-15, 253-10.) (Dec #25, Exhibit #967.)
I have filed a Judicial Misconduct Complaint against Judge Orinda D. Evans with the Eleventh Circuit Court of Appeals. I previously filed a Judicial Misconduct Complaint against Judge Evans that was ignored. I also have a lawsuit pending against Judge Orinda D. Evans for Fraud Upon the Court (Civil Action No. 1:09-CV-02027-WSD in the United States District Court for the Northern District of Georgia.
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 § 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.
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.)
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.
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.