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 that much of what was in the Verified Complaint drated by Marc W. Brown of Phillips Lytle was false and was not the personal knowledge of anyone, much less the President who signed the verification saying it was on his “personal knowledge.” Exhibit 1 to Windsor Declaration #3 – Motion to Reopen the Case — Each of the false statements is listed with the proof that it is false shown beneath with citations to the record.
1. On August 17, 2005, Time Slips show that Mr. Marc Brown (“Mr. Brown”) of Phillips Lytle became involved in this matter. He asked Mr. Anderson what should be in Glynn’s affidavit for the lawsuit. Mr. Brown then outlined the affidavit and drafted the affidavit. [Evans Docket #253-15, P 2.] This establishes that both Mr. Brown and Mr. Anderson are guilty of preparing the false sworn affidavit. Mr. Russ was also involved. One of the most basic things that all attorneys must know is what “personal knowledge” means. Very little of what Mr. Brown and Mr. Anderson drafted for Glynn was within his personal knowledge. These attorneys knew he did not have the personal knowledge of the various false claims that they wrote for him. Glynn, Schul, and Ruddy all testified that statements made by Glynn in this affidavit were false.
2. VIOLATIONS BY HAWKINS & PARNELL — Violation of Rule 1.2(D) of the GCPC — A lawyer shall not counsel to engage in conduct that the lawyer knows is criminal or fraudulent; shall not knowingly assist a client in such conduct; Conspiracy to Commit Fraud; Subornation of Perjury in violation of O.C.G.A. 16-10-72, USC 18 § 1622, O.C.G.A. 16-10-72, and O.C.G.A. 16-10-93; Obstruction Of Justice — influencing testimony in violation of 18 USC § 1512(b); Violation of Local Rule 83.1C — All lawyers practicing before this court shall be governed by and shall comply with the specific rules of practice adopted by this court and, unless otherwise provided, with the Georgia Rules of Professional Conduct contained in the Rules and Regulations of the State Bar of Georgia and with the decisions of this court interpreting these rules and standards; Violation of Rule 8.4 of the GCPC — A lawyer shall not violate or attempt to violate the Georgia Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another; shall not engage in professional conduct involving dishonesty, fraud, deceit or misrepresentation. (Proof is provided in the paragraph above and the exhibits cited therein, oral contract, Evans Docket #253-15, Evans Docket #90 and 132 — Ruddy Depo testimony, Evans Docket #159 — Glynn Depo testimony, Evans Docket #133 and 160 — Schul Depo testimony, Docket #377 — Exhibits 1 to 28 in Amended Dec #3 and all citations therein.)
3. VIOLATIONS BY CARL HUGO ANDERSON — Violation of Rule 1.2(D) of the GCPC — A lawyer shall not counsel to engage in conduct that the lawyer knows is criminal or fraudulent; shall not knowingly assist a client in such conduct; Conspiracy to Commit Fraud; Subornation of Perjury in violation of O.C.G.A. 16-10-72, USC 18 § 1622, O.C.G.A. 16-10-72, and O.C.G.A. 16-10-93; Obstruction Of Justice — influencing testimony in violation of 18 USC § 1512(b); Violation of Local Rule 83.1C — All lawyers practicing before this court shall be governed by and shall comply with the specific rules of practice adopted by this court and, unless otherwise provided, with the Georgia Rules of Professional Conduct contained in the Rules and Regulations of the State Bar of Georgia and with the decisions of this court interpreting these rules and standards; Violation of Rule 8.4 of the GCPC — A lawyer shall not violate or attempt to violate the Georgia Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another; shall not engage in professional conduct involving dishonesty, fraud, deceit or misrepresentation. (Proof is provided in the paragraph above and the exhibits cited therein, oral contract, Evans Docket #253-15, Evans Docket #90 and 132 — Ruddy Depo testimony, Evans Docket #159 — Glynn Depo testimony, Evans Docket #133 and 160 — Schul Depo testimony, Docket #377 — Exhibits 1 to 28 in Amended Dec #3 and all citations therein.)
4. VIOLATIONS BY PHILLIPS LYTLE — Violation of Rule 1.2(D) of the GCPC — A lawyer shall not counsel to engage in conduct that the lawyer knows is criminal or fraudulent; shall not knowingly assist a client in such conduct; Conspiracy to Commit Fraud; Subornation of Perjury in violation of O.C.G.A. 16-10-72, USC 18 § 1622, O.C.G.A. 16-10-72, and O.C.G.A. 16-10-93; Obstruction Of Justice — influencing testimony in violation of 18 USC § 1512(b); Violation of Local Rule 83.1C — All lawyers practicing before this court shall be governed by and shall comply with the specific rules of practice adopted by this court and, unless otherwise provided, with the Georgia Rules of Professional Conduct contained in the Rules and Regulations of the State Bar of Georgia and with the decisions of this court interpreting these rules and standards; Violation of Rule 8.4 of the GCPC — A lawyer shall not violate or attempt to violate the Georgia Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another; shall not engage in professional conduct involving dishonesty, fraud, deceit or misrepresentation. (Proof is provided in the paragraph above and the exhibits cited therein, oral contract, Evans Docket #253-15, Evans Docket #90 and 132 — Ruddy Depo testimony, Evans Docket #159 — Glynn Depo testimony, Evans Docket #133 and 160 — Schul Depo testimony, Docket #377 — Exhibits 1 to 28 in Amended Dec #3 and all citations therein.)
5. VIOLATIONS BY MARC W. BROWN — Violation of Rule 1.2(D) of the GCPC — A lawyer shall not counsel to engage in conduct that the lawyer knows is criminal or fraudulent; shall not knowingly assist a client in such conduct; Conspiracy to Commit Fraud; Subornation of Perjury in violation of O.C.G.A. 16-10-72, USC 18 § 1622, O.C.G.A. 16-10-72, and O.C.G.A. 16-10-93; Obstruction Of Justice — influencing testimony in violation of 18 USC § 1512(b); Violation of Local Rule 83.1C — All lawyers practicing before this court shall be governed by and shall comply with the specific rules of practice adopted by this court and, unless otherwise provided, with the Georgia Rules of Professional Conduct contained in the Rules and Regulations of the State Bar of Georgia and with the decisions of this court interpreting these rules and standards; Violation of Rule 8.4 of the GCPC — A lawyer shall not violate or attempt to violate the Georgia Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another; shall not engage in professional conduct involving dishonesty, fraud, deceit or misrepresentation. (Proof is provided in the paragraph above and the exhibits cited therein, oral contract, Evans Docket #253-15, Evans Docket #90 and 132 — Ruddy Depo testimony, Evans Docket #159 — Glynn Depo testimony, Evans Docket #133 and 160 — Schul Depo testimony, Docket #377 — Exhibits 1 to 28 in Amended Dec #3 and all citations therein.)
6. VIOLATIONS BY ARTHUR P. RUSS — Violation of Rule 1.2(D) of the GCPC — A lawyer shall not counsel to engage in conduct that the lawyer knows is criminal or fraudulent; shall not knowingly assist a client in such conduct; Conspiracy to Commit Fraud; Subornation of Perjury in violation of O.C.G.A. 16-10-72, USC 18 § 1622, O.C.G.A. 16-10-72, and O.C.G.A. 16-10-93; Obstruction Of Justice — influencing testimony in violation of 18 USC § 1512(b); Violation of Local Rule 83.1C — All lawyers practicing before this court shall be governed by and shall comply with the specific rules of practice adopted by this court and, unless otherwise provided, with the Georgia Rules of Professional Conduct contained in the Rules and Regulations of the State Bar of Georgia and with the decisions of this court interpreting these rules and standards; Violation of Rule 8.4 of the GCPC — A lawyer shall not violate or attempt to violate the Georgia Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another; shall not engage in professional conduct involving dishonesty, fraud, deceit or misrepresentation. (Proof is provided in the paragraph above and the exhibits cited therein, oral contract, Evans Docket #253-15, Evans Docket #90 and 132 — Ruddy Depo testimony, Evans Docket #159 — Glynn Depo testimony, Evans Docket #133 and 160 — Schul Depo testimony, Docket #377 — Exhibits 1 to 28 in Amended Dec #3 and all citations therein.)
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.