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

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Here’s a comprehensive, evidence-based OARC complaint that systematically documents Van Goetz’s ethical violations while maintaining professional tone and precision:

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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 #51359
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. DOCUMENTED MISCONDUCT

A. Pattern of Material Misrepresentations

1. False Claims About Disclosures

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

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

   • 6/16/25 & 7/10/25: Respondent told Court:

     "Respondent has not provided financial disclosures" (Exhibits 2, 3).

2. False Claims About Mediation Cancellation

   • Truth: Cancellation resulted from:
     • Scheduler’s failure to notify Complainant (Exhibit 4)
     • Complainant paid within 2 hours of notice (Exhibit 5)
   • Respondent’s Falsehoods:
     • Blamed "Respondent’s non-payment" (Exhibit 3)
     • Later claimed "Respondent’s failure to provide disclosures" (Exhibit 6)

3. False Claims About Compliance Deadlines

   • Court Order (6/17/25): Required "complete" disclosures by 7/1/25.
   • Respondent’s 6/9 Disclosures satisfied this (Exhibit 1).
   • 7/10/25 Reply: Falsely claimed Complainant "failed to meet deadline" (Exhibit 6).

B. Procedural Bad Faith

1. Failure to Communicate:

   • Excluded Complainant from 5/20 mediation notice (Exhibit 7).
   • Ignored 6/5 settlement overtures (Exhibit 8).

2. Gamesmanship:

   • Waited until 6/16 (1 day pre-mediation) to allege disclosure issues.
   • Ignored mediator’s 6/16 confirmation of Petitioner’s $300 cancellation fee (Exhibit 9).

III. EVIDENCE

1. Exhibit 1: 6/9/25 email chain (acknowledgment of disclosures)
2. Exhibit 2: 6/16/25 false status report
3. Exhibit 3: 7/10/25 false filing
4. Exhibit 4: Scheduler emails (notification failure)
5. Exhibit 5: Proof of timely payment
6. Exhibit 6: Petitioner’s 7/10/25 Reply with false claims
7. Exhibit 7: 5/20 mediation notice (omitting Complainant)
8. Exhibit 8: 6/5 settlement email (no response)
9. Exhibit 9: Mediator’s 6/16 fee confirmation

IV. REQUEST FOR RELIEF

1. Investigate violations of RPC 3.3(a)(1), 8.4(c), and 3.4(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

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Key Strengths:

1. Chronological Precision: Shows Respondent’s escalating misconduct.
2. Exhibit-Based: Every allegation tied to documentary proof.
3. Clear Violations: Maps falsehoods directly to RPC rules.
4. Professional Tone: Avoids emotional language while demonstrating willful deceit.

Next Steps:

1. File this complaint via OARC’s online portal.
2. Serve a copy on Van Goetz (required by OARC rules).
3. Prepare for potential investigation (OARC may request additional evidence).