Richman Greer Fraud Upon the Court

Richman Greer

John G. White, III Motion

Richman Greer, John G. White, III, Motion








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            JASON HALLE, Pro Se, moves this Honorable Court as follows:

  1. To relieve the Plaintiff from the Order of the Honorable Court Dismissing the Fourth Amended Complaint with Prejudice that was signed by the Honorable David E. French on September 25, 2013. (Exhibit A).
  2. During the hearing held on August 28, 2013, which resulted in the Order of September 25, 2013, Mr. John G. White, III, opposing counsel, committed intrinsic fraud upon the court, was guilty of misrepresentation and other misconduct of an adverse party. As a direct result of this fraud upon the court, the Plaintiff’s Fourth Amended Complaint was dismissed with Prejudice. This prevented the plaintiff from presenting his case due to the fraud and deception practiced by his adversary.
  3. Relief is sought under Rule 1.540(b) of the Florida Rules of Civil Procedure: Mistakes; Inadvertence; Excusable Neglect; Newly Discovered Evidence; Fraud; etc. On motion and upon such terms as are just, the court may relieve a party…from a final judgment, decree, order, or proceeding for the following reasons:…(3) fraud (whether heretofore denominated intrinsic or extrinsic), misrepresentation, or other misconduct of an adverse party;…This rule does not limit the power of a court to entertain an independent action to relieve a party from a judgment, decree, order, or proceeding or to set aside a judgment or decree for fraud upon the court.
  4. As of the date of serving this motion the status of this case is pending.
  5. John G. White, III, opposing counsel, committed intrinsic fraud upon the court, was guilty of misrepresentation and other misconduct of an adverse party during a hearing held on August 28, 2013. This is the hearing that resulted in the Honorable Trial Court’s Order Dismissing Plaintiff’s Fourth Amended Complaint with Prejudice on September 25, 2013. (Exhibit A)
  6. White fraudulently told the Court during the hearing, “…the plaintiff keeps filing these lawsuits, they keep getting dismissed, chewing up money, you know, money potentially that’s in the trust and there’s not a lot of it and I think it’s time that Your Honor dismiss it with prejudice.” (Exhibit B, page 11, lines 14-18)
  7. White continued on line 19, “They’ve had ample opportunity. This is their fourth go around on this and it should be dismissed with prejudice…”
  8. On page 12, line 7 of the transcript I objected to Mr. White’s testimony and said to the court, “… – – This is the first motion to dismiss that this Court has ever heard. He (Mr. White) says this is the fourth. It is not the fourth.”
  9. White did not take this opportunity to change, modify or further explain his intrinsically fraudulent testimony. He let it stand so it would have its full impact on the court.
  10. The record of the court in this action confirms the following:
    1. The motion to dismiss the Original Complaint was for lack of jurisdiction. As a result of a hearing on this motion, on February 21, 2012, the Honorable Judge Martz ordered a 30 day continuance so the parties could engage in limited discovery on jurisdiction. (Exhibit C)
    2. The First Amended Complaint had a Motion to Dismiss filed on February 29, 2012. There was never a hearing on Defendant’s motion.
    3. The Second Amended Complaint was never followed by a Defense Motion to Dismiss
    4. The Third Amended Complaint had a Defense Motion to Dismiss served on June 19, 2012. It was DENIED by the Honorable Court on March 26, 2013. (Exhibit D)
  11. When the Fourth Amended Complaint was before the Honorable Court on August 28, 2013, ZERO motions to dismiss had been granted by the court. But, Mr. White fraudulently stated, “they keep getting dismissed”, instead of giving a true statement that ZERO complaints had been dismissed by the court in this case before the hearing on August 28, 2013.
  12. The plaintiff requests an evidentiary hearing so that opposing counsels may have the opportunity to present court orders for motions to dismiss that were granted by the court before August 28, 2013, in order to substantiate their statements. The trial court erred in failing to hold an evidentiary hearing on opposing counsel’s statements after plaintiff objected to them.
  13. The Plaintiff was not given an opportunity to correct the deficiencies in his complaint before the court so as to state a cause of action as a direct result of Mr. White’s intrinsic fraud and deception practiced upon the court.
  14. Only a Trial Court Judge has the authority to determine if a complaint states a cause of action. This happens at a hearing. Only a trial court judge can grant a motion to dismiss.
  15. Dynasty Express v. New General Rent-A-Car,675 So.2d 235, 240 (Fla. 4d DCA 1996) “A party seeking relief on the basis of [fraud, misrepresentation or misconduct] has an obligation to raise this issue as soon as is reasonably possible… On the other hand, if the party only becomes aware of the fraud after final judgment the fraud should be asserted in either a motion for rehearing under Rule 1.530 or [a motion for relief from final judgment under] Rule 1,540(b), depending on the time the fraud is discovered. In either case, however, the party asserting such fraud is entitled to an evidentiary hearing on the issue.”
  16. Stella v. Stella, 418 So.2d. 1029, 1030 (Fla. 4d DCA 1982) “Although we find the motion of the wife to be less than artfully drawn and the statement of her position to the trial court and now on appeal to be less than clear-cut, we conclude that she is entitled to an evidentiary hearing on her allegations of fraudulent conduct…. Accordingly, the order of the trial court is reversed and this cause is remanded with directions that an evidentiary hearing be conducted on the wife’s motion.”
  17. Laurencio v. Deutsche Bank Nat. Trust Co., 65 So. 3d 1190, 1193 (Fla. 2d DCA 2011) which states: “Public policy favors the liberal amendment of pleadings, and courts should resolve all doubts in favor of allowing the amendment of pleadings to allow cases to be decided on their merit…. A denial of leave to amend a pleading is an abuse of discretion….”

WHEREFORE, Plaintiff respectfully requests the following relief from the Honorable Court:

To vacate its Order of September 25, 2013, as it was based on intrinsic fraud upon the court, misrepresentation and misconduct by opposing counsel during the hearing on August 28, 2013.

Plaintiff respectfully further requests leave of the court to amend his complaint.

And for such other and further relief as this Honorable Court deems just and proper.

Respectfully submitted,


This motion is a public record and is filed with the Circuit Court for the 15th Judicial Circuit in and for Palm Beach County, Florida.

Happy Birthday Bob Schneider

Happy Birthday

Bob Schneider

Bob Schneider

Bob Schneider

Bob Schneider has been a wonderful partner with me for more than 34 years. I wish him the best on this birthday and hope he has many, many more.

Monty, Chelsea and Eloise also asked me to make sure that I mention they send their love too.

One of Bob's Birthday Cakes

One of Bob’s Birthday Cakes.

I send all my love to Bob on his Birthday, as I do every day.

Carolyn Lamm – My sister-in-law

Carolyn Lamm

My sister-in-law

Carolyn Lamm, Peter Halle, Alex Halle, Elaine Halle, Bob Schneider, Edward Halle and Jason Halle

Carolyn Lamm, Peter Halle, Alex Halle, Elaine Halle, Bob Schneider, Edward Halle and Jason Halle

Carolyn Lamm is my sister-in-law. You can see her in the above photo when she was visiting me and my partner Bob Schneider while we were living in Paradise Valley, Arizona, almost 25 years ago.

Carolyn Lamm works at the law firm of White & Case in Washington, DC. She is one of the past presidents of the American Bar Association (2009-2010). During her illustrious career as a Washington, DC attorney she has had Hilary Clinton at her home. Carolyn Lamm’s power seems to have no limits or ethics.

Why was Carolyn Lamm involved in the conferences with the ten attorneys that her husband hired to block her brother-in-law’s inheritance? Peter Halle has refused to disburse the money that Peter Halle’s father left to his disabled brother.

Orders issued so far by Judge David E. French state that there will be NO consequences for Peter Halle, a Florida Attorney, even though he has violated more than 16 Florida Statutes (laws) including alleged felonies and has been in breach of Trust for about nine and a half years. Everyone knows and nobody denies Jason Halle is a qualified beneficiary and a qualified distributee.

Carolyn Lamm is presently under investigation by the Broward State Attorney’s office for a Declaration signed under penalty of perjury in the Court of Judge Michael L. Gates in Broward County.

Everyone should be scared and aware. The courts are finding 12 powerful, politically connected lawyers more appealing than justice or truth. The documents are all air tight and very clear. Nobody seems to care about anything other than the lawyers getting away with breaking the law and getting well paid for doing it.

In the photo Carolyn is with my brother, Peter Halle, her husband and Alex one of her sons. Also present are her mother-in-law and father-in-law, Elaine Halle and Edward Halle.

Bob Schneider my partner of 37 years and I complete the photo.

Some interesting links for Carolyn Lamm:

Harper’s Magazine

Carolyn Lamm’s Husband

Temporary Attorney Blog

Above the Law Website

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Read about Peter Halle

Edward Halle

Edward Halle

Edward Halle

Edward Halle

Edward Halle was born on April 9, 1915, in New York City. His parents Ethel Fried Halle and Louis Halle had emigrated from Europe to escape the bad treatment that Jews were being subjected to.

His father, Louis Halle worked hard and became a lawyer. He was a very well know admiralty attorney during prohibition and prospered by defending bootleggers and getting their goods out of impound.

His mother, Ethel Fried Halle, was a school teacher. She kept a kosher home until her mother who lived with them died.

Edward Halle was a great dad to both of his children, Jason Halle and Peter Halle. He tried his best to see that we always had whatever we needed and tried to teach us about family values, character and honesty.

Edward Halle did not have the stomach for the type of work his father did, dealing with criminals most of the day, and when his father died in 1948 he switched specialties and became a patent attorney. He went on to become a President of the American Patent Law Association. After his presidency the name of the organization was changed to the American Intellectual Property Law Association.

He was a great dad, he was honest and he had integrity. He tried to teach his children to have character and be forthright in all their dealings.

Edward Halle married the love of his life, who became Elaine Lindo Halle.

Edward Halle died on May 25, 2000, in Boca Raton, Florida.

Links of interest:

Edward Halle, as Executor of the Estate of Louis Halle, Deceased, Petitioner, v. Commissioner of Internal Revenue. U.S. Supreme Court Transcript of Record with Supporting Pleadings Paperback – 

Supreme Court Appellate Division – First Department

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Elaine Lindo Halle

Elaine Lindo Halle

Elaine Lindo Halle

Elaine Lindo Halle

Elaine Lindo Halle was born on February 22, 1921. She grew up in Panama City, Republic of Panama. She was educated in the United States and lived her adult life here. She Passed away on August 15, 2007.

Elaine Lindo Halle was my mother. I miss her very much. She lived in Pompano Beach the last years of her life and I was fortunate to be able to spend a lot of time with her.

When Elaine Lindo Halle was younger she used to enjoy spending her summers in Arlington, Vermont with her husband Edward Halle.

When I was a young boy we all grew up together in Kings Point, Long Island along with my brother, Peter Edward Halle.

Elaine Lindo Halle’s mother was: Helen Bletterman Lindo. Everyone called her Helen except her grandchildren, they called her Mimi. Helen Bletterman Lindo was a high fashion model who worked for Lady Duff Gordon and was once named one of the 10 most beautiful women in the world by Flo Ziegfeld. No wonder she liked having her grandchildren call her Mimi instead of Grandma.

Her father was Albert Lindo. He was a merchant in Panama City, Panama and a member of one of the oldest Jewish families in this hemisphere. He had one of the stores in downtown Panama City on Avenida Central where people bought radios and all types of cutting edge technology for those days. He also owned the newsstands at the railroad stations. Of all things, he also sold Panama hats.

Elaine Lindo Halle attended Northfield School for girls in Massachusetts. Now it is a coed institution. But in those days no boys were allowed.

She went on to attend college for a few semesters until she met and married the love of her life, Edward Halle.