66 lines
2.7 KiB
Markdown
66 lines
2.7 KiB
Markdown
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**
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**OFFICE OF ATTORNEY REGULATION COUNSEL**
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**Complainant:**
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Jason Davis
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737 Summit Ridge, Lewisville, TX 75077
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(720) 217-4263 | newton214@gmail.com
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**Respondent Attorney:**
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Knicky Van Goetz, Esq.
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Colorado Attorney Registration #______
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Colorado Legal Group
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1777 S. Harrison St., Ste. 1050
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Denver, CO 80210
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**Re:** Ethical Violations in Case No. 2025DR30592 (Arapahoe County District Court)
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### **I. VIOLATIONS**
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Respondent violated:
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1. **Colo. RPC 3.3(a)(1)**: Knowingly false statements to tribunal
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2. **Colo. RPC 8.4(c)**: Conduct involving dishonesty, fraud, deceit or misrepresentation
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3. **Colo. RPC 3.4(c)**: Knowingly disobeying court rules
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### **II. FACTUAL ALLEGATIONS**
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**A. False Statements Regarding Disclosures**
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1. **6/9/25 6:50 PM**: I emailed complete disclosures to Respondent (Exhibit 1).
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2. **6/9/25 8:34 PM**: Respondent acknowledged receipt, stating:
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> "I've reviewed the disclosures you've provided and found material errors" (Exhibit 1).
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3. **6/16/25**: Respondent told the Court:
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> "Respondent has not provided financial disclosures" (Exhibit 2).
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**B. False Claims About Mediation Cancellation**
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1. True reason: Scheduler's failure to notify me of payment deadline (Exhibit 3).
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2. **6/10/25**: I paid immediately upon learning of deadline (Exhibit 4).
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3. **6/16/25**: Respondent falsely told Court cancellation was due to my "noncompliance" (Exhibit 2).
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4. **6/17/25**: Respondent admitted in email cancellation was due to "Ms. Davis's failure to pay" - a false claim since:
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- I had already paid (Exhibit 4)
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- Respondent knew the scheduler failed to notify me (Exhibit 3)
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**C. Post-Warning Misconduct**
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1. **7/9/25**: I served Respondent with evidence disproving her claims (Exhibit 5).
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2. **7/10/25**: She repeated false statements in court filing (Exhibit 6).
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### **III. EXHIBITS**
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1. Exhibit 1: 6/9/25 email chain (acknowledgment of disclosures)
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2. Exhibit 2: 6/16/25 false status report
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3. Exhibit 3: Scheduler emails showing notification failure
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4. Exhibit 4: Proof of timely payment
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5. Exhibit 5: 7/9/25 notice to Respondent
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6. Exhibit 6: 7/10/25 false filing
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### **IV. REQUEST FOR RELIEF**
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1. Investigate Respondent for violating RPC 3.3(a)(1) and 8.4(c)
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2. Order Respondent to correct all false pleadings
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3. Impose appropriate discipline
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**CERTIFICATION**
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I declare under penalty of perjury that the foregoing is true and correct.
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**Date:** _______________
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**Signature:** __________________________
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Jason Davis, Complainant |