medusa/the_information_nexus
1
0
Fork 0
Code Issues Pull Requests Actions Packages Projects Releases Wiki Activity

Update personal/OARC_complaint.md

Browse Source
This commit is contained in:
medusa
2025-07-11 08:12:57 -05:00
parent 5a3b9a7311
commit b63068112a
1 changed files with 59 additions and 0 deletions
Download Patch File Download Diff File Expand all files Collapse all files

59
personal/OARC_complaint.md
View File

@@ -1,3 +1,62 @@
Here's a concise outline for Mr. Davis's talk-track when speaking to OARC investigators and the judge. They should indeed be very close, if not identical, as the facts and the legal arguments remain consistent across both forums.
---
### **Mr. Jason Davis's Talk-Track Outline**
**Overall Guiding Principles:**
* **Factual & Evidence-Based:** Stick strictly to the documented timeline and refer to exhibits.
* **Concise & Clear:** Get straight to the point without unnecessary detail.
* **Professional & Respectful Tone:** Maintain composure, even when discussing serious allegations. Avoid emotional language or personal attacks.
* **Focus on Knowledge/Intent:** Emphasize how Attorney Van Goetz knew or should have known her statements were false.
* **Focus on Impact:** Briefly explain how her actions harmed the process and you.
---
#### **Talk-Track for OARC Investigators & The Judge**
**(Start by stating your name and your role as Respondent/Complainant)**
**1. Introduction & Purpose:**
* "My purpose today is to present evidence of Attorney Knicky Van Goetz's professional misconduct, specifically her pattern of making false statements to the tribunal and engaging in misrepresentation, which has unnecessarily prolonged this case and undermined the integrity of the court process."
**2. Core Allegations (Chronological, Evidence-Backed):**
* "The misconduct centers on two key areas: false claims about my financial disclosures and misrepresentations regarding mediation cancellations."
* **Point 1: Disclosures & Acknowledgment:**
* "On **June 9, 2025, at 6:50 PM**, I emailed my complete financial disclosures to Attorney Van Goetz."
* "Crucially, on **June 9, 2025, at 8:34 PM**, Attorney Van Goetz herself replied, acknowledging receipt and stating she had 'reviewed the disclosures you've provided.' (Referencing Exhibit A)"
* **Point 2: False Claims & Mediation Cancellation:**
* "Despite her acknowledgment, on **June 16, 2025**, Attorney Van Goetz falsely told the mediator I had not provided disclosures, leading to the cancellation of court-ordered mediation and costing me $150. Her firm unilaterally initiated this cancellation. (Referencing Exhibit B, C)"
* "She repeated this false claim in her Status Report filed on **June 17, 2025**."
* **Point 3: Escalation & "Doubling Down":**
* "On **July 2, 2025**, Attorney Van Goetz filed a Motion to Waive Mediation, reiterating these same false claims."
* "On **July 9, 2025**, I filed my Opposition, directly refuting her claims with evidence, and sent her an email explicitly warning her of the provably false statements and offering an opportunity to correct them by 10 AM on July 10th. (Referencing Exhibit F, G)"
* "On **July 10, 2025, at 1:35 PM**, I formally filed my Motion for Sanctions."
* "Later that day, on **July 10, 2025, at 2:52 PM**, I sent her a collaborative email, urging 'adult collaboration' and to move past 'demonstrably false compliance claims.' (Referencing Exhibit I)"
* "However, on **July 10, 2025, at 6:36 PM**, Attorney Van Goetz filed her Reply, **doubling down** on these demonstrably false claims, *after* receiving my warnings and collaborative offer. (Referencing Exhibit H)"
* "This forced me to file a Sur-Reply and send a formal notice accusing her July 10th filing of 'fraud on the court' due to her knowing repetition of falsehoods. (Referencing Exhibit J, K)"
**3. Key Violations & Legal Basis:**
* "This conduct, particularly the knowing repetition of false statements after being presented with evidence and warnings, violates:"
* "**Colo. RPC 3.3(a)(1): Candor Toward the Tribunal**, by knowingly making false statements of material fact to the court."
* "**Colo. RPC 8.4(c): Misconduct**, by engaging in conduct involving dishonesty and misrepresentation."
* "**CRCP 11:** For presenting factual contentions without evidentiary support and for an improper purpose."
**4. Impact & Requested Outcome:**
* "Her actions have caused unnecessary delays, increased litigation costs, and forced me to expend significant time and resources refuting demonstrably false claims, rather than resolving the divorce."
* "Most importantly, her conduct undermines the integrity of the judicial process itself."
* "I respectfully request that [Judge: my Motion for Sanctions be granted, including monetary reimbursement, a corrective affidavit, and a formal referral to the OARC] / [OARC: a thorough investigation be conducted, and appropriate disciplinary action be imposed to protect the public and uphold the integrity of the legal profession]."
**5. Conclusion & Open to Questions:**
* "I have provided all supporting documentation to substantiate these claims, including her own firm's emails."
* "I am prepared to answer any questions you may have."
---
This outline ensures consistency, emphasizes the critical evidence, and clearly articulates the legal and ethical implications of Attorney Van Goetz's alleged conduct.
---
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: