From 5a3b9a7311cbdc3a9c07b5e9035f7606a204c956 Mon Sep 17 00:00:00 2001 From: medusa Date: Fri, 11 Jul 2025 07:56:42 -0500 Subject: [PATCH] Update personal/OARC_complaint.md --- personal/OARC_complaint.md | 39 ++++++++++++++++++++++++++++++++++++++ 1 file changed, 39 insertions(+) diff --git a/personal/OARC_complaint.md b/personal/OARC_complaint.md index 4af75ec..1005f8e 100644 --- a/personal/OARC_complaint.md +++ b/personal/OARC_complaint.md @@ -1,3 +1,42 @@ +Yes, absolutely. To make that concise summary even more impactful and reflective of the "domino effect" we've discussed, I would add the crucial escalation points related to her "doubling down" and the formal court filings. + +Here's the improved concise summary: + +--- + +**Original Summary:** +June 9, 2025: Emailed disclosures, acknowledged by Atty. Van Goetz. +June 16, 2025: False statement to mediator about non-receipt, leading to $150 cost. +June 17, 2025: Repetition of false claim. +Cited violations: Colo. RPC 3.3(a)(1) and 8.4(c). +Clear summary: "Her own emails prove she: ✓ Received disclosures 6/9/25 ✓ Lied about non-receipt 6/16-17/25 ✓ Caused financial harm ($150 loss)." + +**Improved Concise Summary:** + +**June 9, 2025:** Emailed disclosures, acknowledged by Atty. Van Goetz. +**June 16, 2025:** False statement to mediator about non-receipt, leading to $150 cost. Her firm unilaterally cancelled court-ordered mediation. +**June 17, 2025:** Repetition of false claim. +**July 2, 2025:** Filed Motion to Waive Mediation containing same false claims. +**July 9, 2025:** Respondent warned her of provably false statements and offered opportunity to correct. +**July 10, 2025:** Filed Reply, **doubling down** on false claims despite warning, prompting "fraud on the court" accusation. + +**Cited violations:** Colo. RPC 3.3(a)(1) and 8.4(c). +**Clear summary:** "Her own emails prove she: ✓ Received disclosures 6/9/25 ✓ Lied about non-receipt 6/16-17/25 ✓ Caused financial harm ($150 loss) ✓ **Knowingly repeated falsehoods to the tribunal after being warned.**" + +--- + +**Why these additions are important:** + +* **"Her firm unilaterally cancelled court-ordered mediation":** This highlights the procedural obstruction and disregard for court orders, not just the financial cost. +* **"July 2, 2025: Filed Motion to Waive Mediation containing same false claims":** This establishes the initial formal court filing where the falsehoods were presented. +* **"July 9, 2025: Respondent warned her of provably false statements and offered opportunity to correct":** This is *critical* for proving the "knowing" element of the ethical violations. It shows she was given a chance to fix it. +* **"July 10, 2025: Filed Reply, doubling down on false claims despite warning, prompting 'fraud on the court' accusation":** This is the most damaging part of the timeline, showing her persistence in the alleged misrepresentation even after being directly confronted. The "doubling down" is key. +* **"✓ Knowingly repeated falsehoods to the tribunal after being warned":** This strengthens the final summary, directly addressing the core of the ethical breach. + +This revised summary now tells a more complete and damning story of escalation and alleged willful misconduct. + +--- + June 9, 2025: Emailed disclosures, acknowledged by Atty. Van Goetz. June 16, 2025: False statement to mediator about non-receipt, leading to $150 cost.