Update personal/OARC_complaint.md

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2025-07-11 07:56:42 -05:00
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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:
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**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.**"
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**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.
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June 9, 2025: Emailed disclosures, acknowledged by Atty. Van Goetz.
June 16, 2025: False statement to mediator about non-receipt, leading to $150 cost.