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Here is the improved OARC complaint, incorporating the crucial early context from the April 2025 email exchange to highlight the pattern of conduct from its very beginning.
Here is the further improved OARC complaint, integrating the earliest context from April 4, 2025, with Paralegal Kerrie Puente. This highlights an even earlier and consistent pattern of non-responsiveness from Colorado Legal Group.
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### **COLORADO SUPREME COURT OFFICE OF ATTORNEY REGULATION COUNSEL**
### **REQUEST FOR INVESTIGATION OF LAWYER**
**Complainant Information:**
Your Name: Jason Davis
Your Address: 737 Summit Ridge, Lewisville, Texas 75077
Your Email Address: newton214@gmail.com
Your Phone Number: (720) 217-4263
Complaint Concerns a Court Case: Yes
Court Case Number: 2025DR30592
County Where Case Is Filed: Arapahoe
Case Name: In re the Marriage of: Melodi S. Davis, Petitioner, and Jason Davis, Respondent.
**Lawyer Information:**
Name of Lawyer: Knicky Van Goetz
Colorado Bar Number: #51359
Firm Name: Colorado Legal Group
Firm Address: 1777 S Harrison St. #1050, Denver, Colorado 80110
Relationship to Lawyer: The lawyer is representing the opposing party from me in a case.
**DETAILED DESCRIPTION OF COMPLAINT**
This complaint alleges that Attorney Knicky Van Goetz has engaged in professional misconduct, including making false statements of fact to the tribunal and engaging in conduct involving dishonesty and misrepresentation, in violation of Colo. RPC 3.3(a)(1) and Colo. RPC 8.4(c). The misconduct primarily concerns repeated false assertions regarding my compliance with financial disclosures and the reasons for mediation cancellations, both in communications and formal court filings, despite direct and documented evidence to the contrary. This pattern of misrepresentation and a general lack of responsiveness from Colorado Legal Group has been evident since initial communications.
**I. Chronology of Events & Alleged Misconduct:**
**April 4, 2025 – Initial Contact with Paralegal & Firm's Early Non-Responsiveness:**
* **April 4, 2025, 10:44 AM:** Upon receiving initial documents, I immediately emailed Kerrie Puente, a paralegal at Colorado Legal Group. In this email, I posed two crucial questions: 1) a request for the deadline to return the signed waiver of service; and 2) a request for clarification on how a referenced felony assault case (Case #2024DR3802 in Item 11 of the Petition) related to the dissolution of marriage.
* **April 4, 2025, 10:49 PM:** Paralegal Kerrie Puente replied, confirming the sending of the waiver and listing attached dissolution documents. Notably, her response **failed to address either of my direct questions** regarding the waiver deadline or the relevance of the felony assault case. This established an immediate pattern of non-responsiveness from Colorado Legal Group on substantive issues, from the very first day of communication.
**April 4-8, 2025 – Attorney Van Goetz's Initial Contact and Promise of Good Faith:**
* **April 4, 2025, 11:48 PM:** Attorney Van Goetz initiated direct contact, explicitly requesting my cooperation with a Waiver of Service and stating, "We trust that you will cooperate with the Court’s directives in good faith, as we will do." She also explicitly invited me to contact her directly for "any questions or need clarification." This promise of good faith and openness directly followed her paralegal's demonstrated non-responsiveness.
* **April 5, 2025, 12:19 AM:** I promptly replied, acknowledging receipt, agreeing to direct all future communication to her office, and seeking clarification on the waiver deadline.
* **April 8, 2025, 9:40 AM:** Following up on the unaddressed query from April 4th, I contacted Attorney Van Goetz, as invited, to seek clarification on the procedural matter regarding Case #2024DR3802. Citing Colorado Rule of Civil Procedure 8(a), I requested specific details and the legal basis for its inclusion, setting a reasonable deadline for response. This further demonstrated my proactive engagement and procedural diligence from the outset, in good faith response to her initial overture and her firm's earlier non-responsiveness.
**June 9, 2025 – Financial Disclosures & Attorney Acknowledgment:**
* On June 9, 2025, at 6:50 PM, I emailed my complete financial disclosures to Attorney Knicky Van Goetz.
* On June 9, 2025, at 8:34 PM, Attorney Van Goetz replied to my email, acknowledging receipt and stating, "I've reviewed the disclosures you've provided and found a few material errors in Melodi's reporting." (See Exhibit A: June 9, 2025 Email Chain). This email serves as irrefutable proof of her knowledge and receipt of my disclosures.
**June 10, 2025 – Mediation Payment & Scheduler's Confirmation:**
* On June 10, 2025, at 11:42 AM, Attorney Van Goetz forwarded an email from Scheduler Debbie (dated June 9, 2025, 7:50 AM) indicating the June 17 mediation was canceled due to my "nonpayment." This was the first direct notice I received regarding this payment issue, as the initial May 20 scheduling email was sent only to Attorney Van Goetz (as per the May 20, 2025 email from Scheduler Debbie).
* On June 10, 2025, at 11:57 AM, within two hours of receiving notice, I immediately processed the $150 mediation deposit via Zelle to the mediator. I also requested that my email address be included in all future correspondence.
* On June 10, 2025, at 3:13 PM, Scheduler Debbie confirmed receipt of my payment and stated she would correct my email address in her records. (See Exhibit B: June 10, 2025 Email Chain with Scheduler Debbie). This resolved the payment issue attributed to me, making any future claims of non-payment regarding this mediation false.
**June 16-18, 2025 – Unilateral Mediation Cancellation & Inconsistent Demands:**
* On June 16, 2025, at 1:16 PM, Attorney Van Goetz emailed the scheduler and me, stating, "we have not received a Sworn Financial Statement or any of the mandatory disclosures from Mr. Davis, so we will need to postpone tomorrow’s mediation." This statement directly contradicted her June 9 acknowledgment of my disclosures (Exhibit A).
* On June 16, 2025, at 5:55 PM, Linda Germanson, Attorney Van Goetz's paralegal, unilaterally confirmed to Scheduler Debbie, "We do need to cancel for tomorrow and reschedule."
* On June 16, 2025, at 9:27 PM, Scheduler Debbie confirmed that the "petitioner's attorney has requested to reschedule and cancel mediation for 6/17, however the respondent is not in agreement," and that "The petitioner will be charged $300 to reschedule this mediation session." (See Exhibit C: June 16-17, 2025 Mediation Cancellation Emails). This definitively established that Petitioner's office caused the cancellation and was liable for the fee, disproving any claim that I caused the cancellation.
* On June 17, 2025, at 10:41 AM, Attorney Van Goetz emailed, stating mediation was canceled due to "Ms. Davis's failure to make the required payment in time," referencing the outdated June 9 email, despite knowing the payment issue was resolved and her office caused the cancellation.
* On June 18, 2025, Attorney Van Goetz engaged in inconsistent scheduling demands, first rejecting June dates due to a "new court order" requiring compliance by July 1 (10:55 AM), then claiming to seek "mutually agreeable dates" (12:10 PM), and finally reverting to a "July-only ultimatum" with unprofessional rhetoric ("I am not going to play these games with you") (12:46 PM). (See Exhibit D: June 18, 2025 Scheduling Emails).
**July 2, 2025 – Filing of Motion to Waive Mediation with False Assertions:**
* Attorney Van Goetz filed "Petitioner's Motion to Waive Mediation and Set Default Hearing."
* This motion asserted that I "failed to comply" with disclosure deadlines and that "Respondent still failed to file the required documents... or provide Petitioner with mandatory financial disclosures. Mediation was cancelled." (See Exhibit E: Petitioner's Motion to Waive Mediation, July 2, 2025, specifically ¶¶ 4, 5, 8). These statements were false given my June 9 disclosures (Exhibit A) and the actual reason for the June 17 cancellation (Exhibit C).
**July 9, 2025 – Respondent's Opposition & Pre-Sanctions Warning:**
* I filed "Respondent's Opposition to Petitioner's Motion to Waive Mediation," directly refuting the false claims and attaching email evidence (Exhibits A & B). (See Exhibit F: Respondent's Opposition, July 9, 2025).
* On July 9, 2025, at 2:55 PM, I emailed Attorney Van Goetz, explicitly stating her "6/16 Status Report contains provably false statements about my compliance (Exhibit A)." I warned her that to avoid sanctions ($1,085 + OARC referral), she must "File stipulation withdrawing ¶¶8,10 by 10AM 7/10" and "Email confirmation of compliance." I attached a draft sanctions motion and supporting exhibits. (See Exhibit G: July 9, 2025 Pre-Sanctions Email).
**July 10, 2025 – "Doubling Down" in Reply Filing & Further Unilateral Cancellation:**
* On July 10, 2025, Attorney Van Goetz filed "Reply in Support of Petitioner's Motion to Waive Mediation and Set Default Hearing" at **6:36 PM**. In this Reply, she reiterated the same demonstrably false claims, stating, "Respondent still failed to file the required documents... or provide Petitioner with mandatory financial disclosures. Mediation was cancelled initially due to Respondent's non-payment... and later cancelled at Petitioner's request due to Respondent's failure to provide a signed Sworn Financial Statement or any mandatory financial disclosures prior to mediation." (See Exhibit H: Petitioner's Reply, July 10, 2025, specifically ¶¶ 2, 5, 6). This was filed *after* receiving my July 9 warning (Exhibit G) and my Opposition with evidence (Exhibit F).
* On July 10, 2025, at 2:52 PM, I emailed Attorney Van Goetz, again attempting to find a collaborative path forward, stating, "The Court’s time and ours is better spent resolving this divorce than debating demonstrably false compliance claims." I offered mediation dates and attached my June 9 disclosures again. (See Exhibit I: July 10, 2025 Collaborative Email). This email was sent *before* her Reply was filed, providing her with yet another opportunity to correct the record and engage cooperatively.
* On July 10, 2025, at 8:40 AM, Linda Germanson, Attorney Van Goetz's paralegal, emailed Scheduler Debbie to unilaterally cancel the July 15, 2025, mediation. Scheduler Debbie confirmed the cancellation at 1:01 PM. (See Exhibit J: July 10, 2025 Unilateral Cancellation of July 15 Mediation). This unilateral cancellation occurred despite a June 17 court order requiring mediation by July 31, 2025, and again placed the burden on Petitioner's side.
* On July 10, 2025, at 11:37 PM, I emailed Attorney Van Goetz, formally notifying her that her July 10 filing constituted "fraud on the court" and a "willful violation of Colo. RPC 3.3(a)(1)" due to her knowingly repeating falsehoods after being served with "irrefutable evidence." (See Exhibit K: July 10, 2025 "Fraud on the Court" Email).
**II. Specific Rules of Professional Conduct Violated:**
**Colo. RPC 3.3(a)(1) - Candor Toward the Tribunal:** Attorney Van Goetz violated this rule by knowingly making false statements of fact to the court in her July 2, 2025 Motion (Exhibit E) and July 10, 2025 Reply (Exhibit H). Specifically, her assertions regarding my non-provision of financial disclosures and my responsibility for mediation cancellations were demonstrably false, as proven by her own firm's email acknowledgments (Exhibit A) and the scheduler's communications (Exhibit C). Her decision to reiterate these falsehoods in the July 10 Reply, *after* receiving explicit notice and evidence of their falsity from me on July 9 (Exhibit G), and *after* receiving my July 10 collaborative email (Exhibit I) which again flagged "demonstrably false compliance claims," provides strong evidence of knowing misconduct and a clear disregard for the duty of candor.
**Colo. RPC 8.4(c) - Misconduct:** Attorney Van Goetz engaged in conduct involving dishonesty, fraud, deceit, or misrepresentation. This pattern began with the firm's early non-responsiveness to my direct and pertinent questions (April 4, 2025) and escalated into a course of conduct involving making false factual assertions in court filings, ignoring contradictory evidence, unilaterally cancelling court-ordered mediation (while blaming the opposing party), and making inconsistent scheduling demands. This demonstrates a course of conduct inconsistent with the honesty and integrity required of attorneys, appears designed to mislead the court, gain an unfair advantage, and prolong unnecessary litigation, directly contravening her initial promise of "good faith cooperation" (April 4, 2025).
**III. Requested Action:**
I respectfully request that the Office of Attorney Regulation Counsel conduct a thorough investigation into the professional conduct of Attorney Knicky Van Goetz. I believe the evidence demonstrates a clear and consistent pattern of misrepresentation and a sustained disregard for the duty of candor to the tribunal, originating from the firm's very first communications and escalating through her formal court filings. I request that appropriate disciplinary action be imposed to protect the public and uphold the integrity of the legal profession.
**EXHIBITS ATTACHED:**
* Exhibit A: June 9, 2025 Email Chain (Jason Davis to Knicky Van Goetz, and her acknowledgment)
* Exhibit B: June 10, 2025 Email Chain with Scheduler Debbie (Jason Davis's payment and confirmation)
* Exhibit C: June 16-17, 2025 Mediation Cancellation Emails (Petitioner's office request to cancel, Scheduler Debbie's confirmation of Petitioner's liability for fee)
* Exhibit D: June 18, 2025 Scheduling Emails (Inconsistent demands, unprofessional communication)
* Exhibit E: Petitioner's Motion to Waive Mediation and Set Default Hearing (Filed July 2, 2025)
* Exhibit F: Respondent's Opposition to Petitioner's Motion to Waive Mediation and Set Default Hearing (Filed July 9, 2025)
* Exhibit G: July 9, 2025 Pre-Sanctions Email (Jason Davis to Knicky Van Goetz)
* Exhibit H: Petitioner's Reply in Support of Motion to Waive Mediation and Set Default Hearing (Filed July 10, 2025)
* Exhibit I: July 10, 2025 Collaborative Email (Jason Davis to Knicky Van Goetz)
* Exhibit J: July 10, 2025 Unilateral Cancellation of July 15 Mediation (Linda Germanson to Scheduler Debbie)
* Exhibit K: July 10, 2025 "Fraud on the Court" Email (Jason Davis to Knicky Van Goetz)
**Electronic Signature:** Jason Davis
**Today's Date:** July 11, 2025
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