the_information_nexus/personal/OARC_complaint.md

Here's the cleaned-up, precise OARC complaint incorporating all corrections and focusing strictly on documented violations:

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BEFORE THE COLORADO SUPREME COURT
OFFICE OF ATTORNEY REGULATION COUNSEL

Complainant:
Jason Davis
737 Summit Ridge, Lewisville, TX 75077
(720) 217-4263 | newton214@gmail.com

Respondent Attorney:
Knicky Van Goetz, Esq.
Colorado Attorney Registration #______
Colorado Legal Group
1777 S. Harrison St., Ste. 1050
Denver, CO 80210

Re: Ethical Violations in Case No. 2025DR30592 (Arapahoe County District Court)

I. VIOLATIONS

Respondent violated:

1. Colo. RPC 3.3(a)(1): Knowingly false statements to tribunal
2. Colo. RPC 8.4(c): Conduct involving dishonesty, fraud, deceit or misrepresentation
3. Colo. RPC 3.4(c): Knowingly disobeying court rules

II. FACTUAL ALLEGATIONS

A. False Statements Regarding Disclosures

1. 6/9/25 6:50 PM: I emailed complete disclosures to Respondent (Exhibit 1).
2. 6/9/25 8:34 PM: Respondent acknowledged receipt, stating:

   "I've reviewed the disclosures you've provided and found material errors" (Exhibit 1).

3. 6/16/25: Respondent told the Court:

   "Respondent has not provided financial disclosures" (Exhibit 2).

B. False Claims About Mediation Cancellation

1. True reason: Scheduler's failure to notify me of payment deadline (Exhibit 3).
2. 6/10/25: I paid immediately upon learning of deadline (Exhibit 4).
3. 6/16/25: Respondent falsely told Court cancellation was due to my "noncompliance" (Exhibit 2).
4. 6/17/25: Respondent admitted in email cancellation was due to "Ms. Davis's failure to pay" - a false claim since:
   • I had already paid (Exhibit 4)
   • Respondent knew the scheduler failed to notify me (Exhibit 3)

C. Post-Warning Misconduct

1. 7/9/25: I served Respondent with evidence disproving her claims (Exhibit 5).
2. 7/10/25: She repeated false statements in court filing (Exhibit 6).

III. EXHIBITS

1. Exhibit 1: 6/9/25 email chain (acknowledgment of disclosures)
2. Exhibit 2: 6/16/25 false status report
3. Exhibit 3: Scheduler emails showing notification failure
4. Exhibit 4: Proof of timely payment
5. Exhibit 5: 7/9/25 notice to Respondent
6. Exhibit 6: 7/10/25 false filing

IV. REQUEST FOR RELIEF

1. Investigate Respondent for violating RPC 3.3(a)(1) and 8.4(c)
2. Order Respondent to correct all false pleadings
3. Impose appropriate discipline

CERTIFICATION
I declare under penalty of perjury that the foregoing is true and correct.

Date: _______________
Signature: __________________________
Jason Davis, Complainant