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Here’s a structured, professional, and legally precise template for your Colorado OARC complaint against Attorney Van Goetz. This focuses on documented violations while avoiding emotional language that could undermine your case.
OFFICE OF ATTORNEY REGULATION COUNSEL (OARC) COMPLAINT
Subject: Formal Complaint Against Knicky Van Goetz, Esq. (Colorado Bar #[Number])
Re: Case No. 2025DR30592 (Arapahoe County District Court)
1. Attorney’s Misconduct
Van Goetz violated:
- Colo. RPC 3.3(a)(1) (Knowingly false statements to a tribunal)
- Colo. RPC 8.4(c) (Dishonesty, fraud, deceit, or misrepresentation)
- Colo. RPC 1.4 (Failure to communicate)
2. Factual Summary
A. False Certification to the Court (6/16 Status Report)
- Her 6/9 Email to Me:
“I’ve reviewed the disclosures you’ve provided and found material errors.”
- Her 6/16 Status Report to Court:
“Respondent has not provided financial disclosures.”
- Contradiction: She acknowledged receiving disclosures on 6/9 but denied receiving them on 6/16.
B. Fraudulent Mediation Cancellation Claim
- Scheduler’s 6/9 Email:
“Mediation canceled due to nonpayment by Jason Davis.”
- Her 6/16 Status Report:
“Mediation failed due to Respondent’s noncompliance.”
- Intentional Misrepresentation: She knew cancellation was due to payment but falsely blamed “noncompliance.”
C. Post-Warning Misconduct (7/10 Filing)
- After I served her with proof of her falsehoods on 7/9, she repeated the lies in her 7/10 filing.
3. Evidence Attached
- Exhibit 1: 6/9 Email Chain (Van Goetz acknowledges disclosures)
- Exhibit 2: 6/16 Status Report (False claim of no disclosures)
- Exhibit 3: Scheduler’s 6/9 Email (True reason for mediation cancellation)
- Exhibit 4: My 7/9 Notice to Van Goetz (Demanding correction)
- Exhibit 5: Her 7/10 Filing (Repeating false statements)
- Exhibit 6: 6/17 Email (“Ms. Davis” typo proving bad faith)
4. Request for Relief
- Investigate Van Goetz for knowing misrepresentations to the court.
- Impose disciplinary action, including potential suspension.
- Require her to correct all false pleadings and notify the tribunal.
5. Certification
I declare under penalty of perjury that this complaint is truthful to the best of my knowledge.
Complainant:
Jason Davis
737 Summit Ridge, Lewisville, TX 75077
(720) 217-4263 | newton214@gmail.com
Date: [Today’s Date]
Key Tips for Submission
- File Online: Use the OARC’s complaint portal.
- Tone: Stick to facts only—avoid emotional language.
- Follow Up: OARC may request additional evidence. Respond promptly.
Why This Works
- Focuses on ethics violations, not personal grievances.
- Uses Van Goetz’s own words to prove misconduct.
- Forces OARC to act—they cannot ignore documented falsehoods.
Need help refining the exhibits or drafting a supplemental affidavit? I can tighten this further.