Perjury Broward County

Perjury by Carolyn Lamm

Did Carolyn Lamm commit perjury in Broward County?

One of the Defendants in a Broward County lawsuit is alleged to have committed perjury. Carolyn B. Lamm, a past president of the American Bar Association (2009-2010) signed a Sworn declaration under penalty of perjury on November 23, 2015 that was later filed in Broward County. In that declaration in paragraph 13 she stated, “…nor have I ever taken any actions for or on behalf of the (Edward Halle) Trust. I have not met or communicated with anyone in the State of Florida or elsewhere in that regard.

On December 4, 2015, another Defendant, also an attorney, Michael J. Napoleone of Richman Greer, filed Ms. Lamm’s alleged perjurious Declaration with the 17th judicial Circuit in and for Broward Country, Florida, Case No: CACE-15-017841.

At least seven instances of contacts by Carolyn Lamm with Florida are memorialized on bills from Richman Greer. These bills were served to Plaintiff Jason Halle and are clearly identified by using the Bates numbering system by the Defendant for identification purposes. (Exhibit I)

The reasons for Carolyn Lamm’s involvements, according to the bills, all pertained to the lawsuit taking place in Palm Beach County. Each one of these represents a contact with the State of Florida and together they represent substantial activity in Florida, and all with respect to the (Edward Halle) Trust.

Carolyn Lamm’s sworn Declaration stating no contacts with Florida or with anyone concerning the Trust proceeding in Palm Beach seems to have committed a third degree felony, Perjury in a official Proceeding.

Michael Napoleone filed this Declaration with the court in Broward County, Florida. He was one of the main people who the Richman Greer bill shows was having contact with Carolyn Lamm while he was in Florida working on the (Edward Halle) Trust.

Michael Napoleone is alleged to have both suborned perjury and committed fraud upon the court by knowingly filing false information in a official proceeding.

Judge Gates does not care much about justice. He keeps ruling in favor of the alleged felons that have stolen hundreds of thousands of dollars from the disabled senior victim. The Defendant and his wife are very wealthy attorneys with political connections. It must be great to control justice with your checkbook and position as an officer of the court. Seems attorneys can break the law in Judge Gates’ courtroom without consequences and steal as much as they want.

Florida Bar

FloridaBar

FloridaBar

Ms. Shanell M Schuyler at the Florida Bar has the duty of protecting attorneys that have committed fraud upon the court and misconduct.

The Florida Bar is a deceptive institution that gives the public the impression it was formed in the public interest and one of its main duties is to police Florida lawyers so that a public agency would not be needed to do this important job.

After a complaint I made regarding Michael J. Napoleone of the powerful Richman Greer Professional association was rejected a second time with no explanation that pertained to the facts in the complaint, I wrote Ms. Schuyler the following letter on November 27, 2015. The letter was never answered by her or anybody else at the Florida Bar.

VIA US Mail

Shanell M. Schuyler
Director of Intake
The Florida Bar
651 East Jefferson Street
Tallahassee, FL 32399-2300

Re: Mr. Michael Joseph Napoleone; RFA No: 15-9614

Dear Ms. Schuyler,

I am in receipt of your letter of September 28, 2015. I appreciate the time and you took to respond to my serious concerns.

A fully documented complaint was submitted to the Florida Bar detailing clear, compelling, and indisputable evidence that a Florida attorney, “with intent to deceive the court” knowingly made false statements and withheld material information.

No defense was ever offered to the fact that Mr. Michael Joseph Napoleone made knowingly false statements to the Courts.

Fact One: On June 6, 2013, Michael Joseph Napoleone of Richman Greer stated in a court document that, “Notably, Plaintiff’s motions to amend have not arisen as a result of the Court’s dismissal of any of Plaintiff’s prior complaints or claims…”

Fact Two: on August 28, 2013, just a few weeks later with no hearing in between, in the Courtroom of Judge David E. French, John George White, III, of Richman Greer stated, “…the plaintiff keeps filing these lawsuits, they keep getting dismissed,… and I think it’s time that Your Honor dismiss it with prejudice.”

It’s amazing to me how “not arising as a result of the Court’s dismissal of any of Plaintiff’s prior complaints or claims” can magically turn into, “they keep getting dismissed” in such a short interval of time.

Fact Three: On February 21, 2014, Mr. Michael Joseph Napoleone made false statements to the Fourth District Court of Appeal in a Reply Brief where he stated, “Mr. White did not “lie,” as Appellant alleges in his ad hominem attack.”

Fact Four: On October 27, 2014, I wrote a letter to Mr. Napoleone asking him to state to the Fourth District Court of Appeal that his statements in his Reply Brief on February 21, 2014 were false. (Letter attached)

Fact Five: On October 28, 2014, Mr. Napoleone wrote me a letter again stating that he was not aware of any false statements by Mr. White during the hearing on September 28, 2013. (Letter attached)

Fact Six: As requested by Mr. Napoleone I sent him the clarifications that he requested regarding Mr. White’s testimony on September 28, 2013. (Letter attached)

Fact Seven: Mr. Napoleone again stated there were no false facts during the hearing of August 28, 2013. This is again in direct contradiction to the court document he authored with Mr. White on June 6, 2013, claiming there had been no dismissals. (Fact One)

It seems that Mr. Napoleone believes that if you tell a lie often enough, people will begin to believe it.

Does the Florida Bar approve of this shameful pattern of misconduct? The duty of keeping the promise fell to you, Bar Counsel, Shanell M. Schuyler. It seems you did exactly what Mr. Napoleone expected you to do.

You betrayed the public trust and closed the file. Your letter closing the bar file rained rhetoric about not second-guessing the court and not retrying the underlying civil and appellate cases but you failed to offer any analysis of the facts or to justify your decision about Mr. Napoleone’s misconduct and why it was ethical to give conflicting testimony that seemed to change when the case required it.

Conspicuously missing from your letter is any comment regarding the undisputed evidence that Mr. Michael J. Napoleone, a partner in the politically potent Richman Greer law firm, offered false statements to a Florida Trial Court and then again to the Florida Fourth District Court of Appeal.

There has been no comment on the proven facts that Mr. Napoleone offered contradicting signed statements. No comment on the fact that Mr. Napoleone did not deny that he offered false testimony both to the Fourth District Court of Appeal that directly contradicted what he had previously stated to the Trial Court in a signed document.

You simply closed the file. Moving on is not fair to the people of Florida that rely on the Bar to keep attorney’s ethics on a high enough level to prevent the appearance of fraud and double-dealing.

Convenient for the corrupt, a decision of bar counsel to close any file is not subject to appeal. This caveat trumps truth. Get out of jail free; a cheap bar trick. The deceit goes on.

No wonder Mr. Napoleone was so confident his fraud upon the court was not going to be a problem for him.

An appeal to the court of public opinion seems to be the only thing left to expose the deep corruption being practiced in the Florida Bar. Is the bar a protector of public integrity in the Florida courts, or a purveyor of perversion? Is the bar a trustworthy arm of the Florida Supreme Court or a fraternity of fraud and cronyism?

The public will decide if the Florida Bar ignored the truth and encourages false statements in the Florida Trial Courts and the Florida Fourth District Courts of Appeal.

Your message that attorney misconduct is allowed and encouraged in the State of Florida, by the Florida Bar Association that you represent, is loud and clear.

Respectfully,

Jason Halle

Additional Links

http://www.tedjec.com/anna-michalik/audrey-jefferis/index.html

Hypocrisy of the Bar – A Case Study

Shanell M. Schuyler

Does the Florida Bar approve of this pattern of misconduct? The duty of keeping the promise fell to you, Bar Counsel, Shanell M Schuyler.

Does the Florida Bar approve of this pattern of misconduct? The duty of keeping the promise fell to you, Bar Counsel, Shanell M Schuyler.

I wrote the following letter to Ms. Shanell M Schuyler, Director of Intake at The Florida Bar in Tallahassee, Florida on November 25, 2015:

Re: Mr. George White, III; RFA No: 15-9437

Dear Ms. Schuyler,

I am in receipt of your letter of September 25, 2015. I appreciate the time and effort you took to respond to my serious concerns.

A fully documented complaint was submitted to the Florida Bar detailing clear, compelling, and indisputable evidence that a Florida attorney, “with intent to deceive the court” knowingly made false statements and withheld material information.

No defense was ever offered to the fact that Mr. George White, III made knowingly false statements to the Courts.

Fact One: On June 6, 2013, John G. “Jay” White, III of Richman Greer stated in a court document that, “Notably, Plaintiff’s motions to amend have not arisen as a result of the Court’s dismissal of any of Plaintiff’s prior complaints or claims…” You seem to have missed this in your review of the docket.

Fact Two: on August 28, 2013, just a few weeks later with no hearing in between, in the Courtroom of Judge David E. French, John George White, III, stated, “…the plaintiff keeps filing these lawsuits, they keep getting dismissed,… and I think it’s time that Your Honor dismiss it with prejudice.”

It’s amazing to me how “not arising as a result of the Court’s dismissal of any of Plaintiff’s prior complaints or claims” can magically turn into, “they keep getting dismissed” in such a short interval of time.

Fact Three: On February 21, 2014, Mr. White again made further false statements to the Fourth District Court of Appeal in a Reply Brief where he stated, “Mr. White did not “lie,” as Appellant alleges in his ad hominem attack.”

Does the Florida Bar approve of this pattern of misconduct? The duty of keeping the promise fell to you, Bar Counsel, Shanell M Schuyler. Perfectly suited for this job, you did exactly what your colleagues expected you to do. You betrayed the public trust and closed the file. Your letter closing the bar file rained rhetoric about not second-guessing the court and not retrying the underlying civil and appellate cases but you failed to offer any analysis of the facts or to justify your decision about Mr. White’s misconduct.

Conspicuously missing from your letter is any comment regarding the undisputed evidence that Mr. White, a partner in the politically potent Richman Greer law firm, offered false statements to a Florida Trial Court and then again to the Florida Fourth District Court of Appeal.

There has been no comment on the proven facts that Mr. White offered contradicting sworn statements. No comment on the fact that Mr. White did not deny that he offered false testimony both to the Trial Court and again to the Fourth District Court of Appeal. You simply closed the file.  Moving on is not fair to the people of Florida that rely on the Bar to keep attorney’s ethics out of the sewer.

Convenient for the corrupt, a decision of bar counsel to close any file is not subject to appeal. This caveat trumps truth. Get out of jail free; a cheap bar trick. The deceit goes on.

An appeal to the court of public opinion seems to be the only thing left to expose the deep corruption being practiced in the Florida Bar. Is the bar a protector of public integrity in the Florida courts, or a purveyor of perversion? Is the bar a trustworthy arm of the Florida Supreme Court or a fraternity of fraud and cronyism?

The public will decide if the Florida Bar ignored the truth and encourages false statements in the Florida Trial Courts and the Florida Fourth District Court of Appeal.

Your message that attorney misconduct is allowed and encouraged in the State of Florida, by the Florida Bar Association that you represent is loud and clear.

Respectfully,

Jason Halle

The Florida Bar
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The Florida Bar

The Florida Bar

The Florida Bar

A bar complaint was filed on November 30, 1014 with The Florida Bar. The Complaint alleged misconduct by Michael J. Napoleone.Click here to review the original complaint.

On December 10, 2015, Maura Canter, Bar Counsel at The Florida Bar in Tallahassee, Florida responded to the complaint. Click here to read her response.

On July 22, 2015, I wrote the following letter to Ms. Maura Canter at The Florida Bar:

VIA US Mail

Ms. Maura Canter, Bar Counsel
Attorney Consumer Assistance Program
The Florida Bar
651 East Jefferson Street
Tallahassee, FL 32399-2300

Re: Mr. Michael J. Napoleone; RFA No: 15-9614

Dear Ms. Maura Canter,

I am in receipt of your letter of December 10, 2014. Thank you for taking your time to respond to my serious concerns on behalf of The Florida Bar.

In your letter to me you stated, “The Florida Bar only has authority to investigate complaints to determine if an attorney has violated the rules governing attorneys and whether disciplinary action is warranted regarding the attorney’s license to practice.”

Ms. Canter, it was never my intention for The Florida Bar to change the outcome of anything that has happened in the Courts in the State of Florida. I know that this is not within the purview of The Florida Bar.

Mr. Michael J. Napoleone has allegedly violated six of the Florida Rules of Professional Conduct which were listed in the Bar Complaint that I filed on November 30, 2014. Under the Florida Bar Standards for Lawyer Sanctions disbarment is appropriate as I outlined in the Complaint.

I hope that the fact that the Defendant Peter Halle is a Florida Attorney, that Mr. Michael J. Napoleone is a Florida Attorney, that the Florida Attorneys at the Florida law firm of Richman Greer that worked on this case were licensed by The Florida Bar, that the Defendant’s wife and Successor Trustee of the Edward Halle Trust is Carolyn B. Lamm, a Florida Attorney and a Past President of the American Bar Association (2009-2010) and that I am a total nobody in the legal profession does not have any bearing on the actions of The Florida Bar.

Powerful people don’t need the protection of The Florida Bar. It is ordinary Florida residents that are being abused by Florida legal professionals licensed by The Florida Bar that are committing misconduct that are in need protection.

My family, friends and readers keep asking me why I don’t complain more vigorously to the Florida Bar about Mr. Michael J. Napoleone’s alleged misconduct. Everybody in Florida seems to believe that The Florida Bar will protect people from attorneys that lie to Judges in a Brief filed with the Appellate Court.

If you feel that Florida attorneys should be allowed to violate the Florida Rules of Professional Conduct that I have outline in my original complaint when involved in a case with a Pro Se litigant, I wish you would explain this to me and my readers so we may better understand how The Florida Bar exercises its investigational process when misconduct is alleged.

All that is necessary is for Mr. Napoleone to produce the court documents that support the statements that there had been multiple dismissals in the case in question before it was dismissed with prejudice. Since no such documents exist, he will not be able to do this and his guilt will be easily ascertained.

This letter is written with the utmost respect and confidence that The Florida Bar will do the next correct thing.

Very Sincerely,

Jason Halle

cc: Michael J. Napoleone

Maura Canter
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Letter to Maura Canter, Bar Counsel

Allegations of misconduct by John G. White, III

Florida Bar Complaint about allegations of misconduct by John G. White, III

A bar complaint was filed on November 22, 1014, alleging misconduct by John G. White, III. Click here to review the original complaint.

On December 9, Maura Canter, Bar Counsel at the Florida Bar in Tallahassee, Florida responded to the complaint. Click here to read her response.

On July 12, 2015, I wrote the following letter to Ms. Maura Canter at the Florida Bar:

VIA US Mail

Ms. Maura Canter, Bar Counsel
Attorney Consumer Assistance Program
The Florida Bar
651 East Jefferson Street
Tallahassee, FL 32399-2300

Re: Mr. George White, III; RFA No: 15-9437

Dear Ms. Maura Canter,

I am in receipt of your letter of December 9, 2014. I appreciate the time and effort you took to respond to my serious concerns.

In your letter to me you stated, “The Florida Bar only has authority to investigate complaints to determine if an attorney has violated the rules governing attorneys and whether disciplinary action is warranted regarding the attorney’s license to practice.”

Maura Canter, I am not asking the Florida Bar to change the outcome of anything that has happened in the Courts in the State of Florida. I know perfectly well that this is not within your mandate.

Mr. John G. White, III has allegedly violated six rules of the Florida Rules of Professional Conduct which were very well articulated in the Bar Complaint that I filed on November 22, 2014.

To think that an attorney licensed by the State of Florida can commit such obvious and serious misconduct on the Trial Court level, and then do it again on the Appellate Court level, especially when his opposition is a Pro Se litigant, is appalling to me and my readers. I certainly hope that the fact that the Defendant Peter Halle is a Florida Attorney, that Mr. John G. White, III is a Florida Attorney, that the Defendant’s wife, Carolyn B. Lamm is a Florida Attorney and is a Past President of the American Bar Association (2009-2010) and that I am a nobody in the legal profession does not have any bearing on the actions of the Florida Bar.

Powerful people don’t need the protection of the Florida Bar. It is ordinary Florida residents that are being abused by Florida legal professionals licensed by the Florida Bar that are committing misconduct that are in need of protection.

My readers keep asking me why I don’t complain to the Florida Bar about Mr. John G. White, III’s alleged misconduct. Everybody in Florida seems to believe that the Florida Bar will protect them from dishonest attorneys that lie to Judges and in Briefs to the Appellate Court.

If you feel that Florida attorneys should be allowed to violate the Florida Rules of Professional Conduct that I have outline in my original complaint when involved in a case with a Pro Se litigant, I wish you would explain this for me and my readers so we may better understand.

All you would have to do, is request that Mr. White produce the court documents that support his statements that there had been multiple dismissals in the case in question before it was dismissed with prejudice. He will not be able to do this, since no such documents exist.

This letter is written with the utmost respect and confidence that the Florida Bar will reconsider and do the correct thing.

Very Sincerely,

Jason Halle

cc: John G. White, III

Micheal J. Napoleone of Richman Greer Bar Complaint

Michael J. Napoleone

Richman Greer

Bar Complaint Filed on November 30, 2014

Micheal J. Napoleone of Richman Greer

Micheal J. Napoleone of Richman Greer

Michael J. Napoleone Bar Complaint – November 30, 2014

Mr. Michael J. Napoleone, a shareholder of the Richman Greer Law firm, was an attorney for the Defense in the matter of Jason Halle v. Peter Halle, L. T. Case No. 502011CP005095XXXXSB, and the Fourth District Court of Appeal Case No. 4DCA13-3796.

Mr. Napoleone’s misconduct and perjury was a result of trying to cover up the misconduct and perjury of his partner, Mr. John George White, III, also a shareholder of the Richman Greer Law firm, and also an attorney for the Defendant. He also was trying to win the case without regard for Rule 4-3.3 of the Florida Rules of Professional Conduct: Candor Toward the Tribunal.

Mr. White gave false and perjurious testimony during a hearing held on August 28, 2013. This hearing resulted in the Honorable David E. French of the 15th Judicial Circuit of Florida Dismissing a Complaint with Prejudice and causing me, the Plaintiff in this action, serious injury.

Mr. White testified before the Court on that day, “…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 A, page 11, lines 14-18)

Mr. 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…”

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.” Mr. White let his false and fabricated testimony stand and have its full impact on the court.

Only a trial court judge can dismiss a complaint by issuing an order granting a motion to dismiss and no such orders were ever issued in this case before the Hearing on August 28, 2013.

On January 6, 2014, in an Initial Brief for the Fourth District Court of Appeal of Florida, I stated “During the hearing on August 28, 2013, Mr. White, the counsel for the Appellee openly and blatantly lied before the Honorable Court. He falsely claimed that the Appellant, ‘keeps filing these lawsuits, they keep getting dismissed, chewing up, 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 8, last paragraph)

“In fact, only one lawsuit was ever filed with this or any other court. No complaint that was ever filed with the leave of the lower court was ever dismissed for any reason except at the hearing on August 28, 2013.” (Exhibit B, page 9, ¶1)

“I replied to Mr. Whites lies, ‘This is the first motion to dismiss (based solely on lack of cause of action) that this Court has ever heard. He (Mr. White) says this is the fourth. It is not the fourth….’” (Exhibit B, page 9, ¶2)

On February 21, 2014, Mr. Napoleone and Mr. White filed Appellee’s Answer Brief. They responded to my Initial Brief by stating, “Appellant’s Initial Brief seeks to divert attention from his repeated failure to state a cause of action after many opportunities to do so, by attacking Peter Halle’s counsel, John G. “Jay” White, III by claiming Mr. White ‘blatantly lied before the Honorable Court.’ (IB.8) Appellant cites to Mr. White’s representation that Appellant ‘keeps filing lawsuits, they keep getting dismissed,….’ As part of his request for a dismissal with prejudice. Mr. White did not ‘lie,’ as Appellant alleges in his ad hominem attack.” (Exhibit C, page 8, ¶1)

Mr. Napoleone and Mr. White continued in their brief with erroneous and false explanations of how five separate complaints were dismissed. Yet Mr. Napoleone and Mr. White did not cite multiple orders granting motions to dismiss before August 28, 2013. The reason for this is because no such orders exist. Mr. Napoleone and Mr. White successfully confused the court by suggesting that they, the opposing counsels, had the legal authority to dismiss complaints and the trial court judge was no longer needed in the legal process to decide if a complaint has not stated a cause of action or should be dismissed.

Mr. Napoleone was lead counsel on this case and he knew that there had been no dismissals in this case before the hearing on August, 28, 2013. Yet he gave false information and perjured himself in the Answer Brief to maintain the deceptive illusion that there had been previous dismissals as Mr. White had testified.

Mr. Napoleone was well aware of the fact that he was providing the court with further false and perjurious information about Mr. White’s false testimony at the hearing on August 28, 2013. He made no attempt to take reasonable remedial measures including, if necessary, disclosure to the tribunal as required by the Florida Rules of Professional Conduct. (Exhibit D)

Mr. Napoleone is in violation of the following Florida Rules of Professional Conduct:

  1. Rule 4-3.3(a)(1) False Evidence; Duty to Disclose. A lawyer shall not knowingly: make a false statement of fact or law to a tribunal or fail to correct a false statement of material fact or law previously made to the tribunal by the lawyer;
  1. Rule 4-3.3(a)(4) A lawyer shall not knowingly: offer evidence that the lawyer knows to be false. A lawyer may not offer testimony that the lawyer knows to be false in the form of a narrative unless so ordered by the tribunal. If a lawyer, the lawyer’s client, or a witness called by the lawyer has offered material evidence and the lawyer comes to know of its falsity, the lawyer shall take reasonable remedial measures including, if necessary, disclosure to the tribunal. A lawyer may refuse to offer evidence that the lawyer reasonably believes is false.
  1. Rule 4-8.4(a) Prohibits the lawyer from violating the rules of Professional Conduct or knowingly assisting another to do so.
  1. Rule 4-8.4(b) Prohibits a lawyer from committing a criminal act that reflects adversely on the lawyer’s honesty, trustworthiness, or fitness as a lawyer
  1. Rule 4-8.4(c) Prohibits a lawyer from engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation.
  1. Rule 4-8.4(d) Prohibits a lawyer from engaging in conduct that is prejudicial to the administration of justice.

Mr. Napoleone has caused serious injury due to his false testimony, perjury and by not making any effort to remedy the situation of the serious injury he had caused me.

Mr. Napoleone’s intention was to mislead the court without regard for the potential injury that could reasonably be foreseen at the time as a result of his misconduct.

Under the Florida Bar Standards for Lawyer Sanctions disbarment is appropriate under 5.11(f) and 6.11(a-b).

The false and perjurious testimony was very prejudicial and damaging.

After the Florida Bar has had an opportunity to investigate this complaint, I ask that the findings be forwarded to the appropriate District Attorney for criminal prosecution under the Florida Statutes §837.07(1)(3) which classifies perjury in official proceedings as a felony of the third degree.

The Florida Statutes §837.07(1-2), Recantation as a defense, does not apply as Mr. Napoleone does not meet either of the requirements of the statute.

This is the body of a public record on file at The Florida Bar, 651 East Jefferson Street, Tallahassee, Florida 32399-2300

 

John G. White, III, Bar Complaint
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John G. White, III

Richman Greer Shareholder

Bar Complaint filed on November 22, 2014

John. G. White, III, Richman Greer shareholder

John G. White, III, Richman Greer shareholder

Bar Complaint – November 22, 2014

Mr. John George White, III, a shareholder of the Richman Greer Law firm, and attorney for the Defendant, gave false and purjurious testimony during a hearing held on August 28, 2013. This hearing resulted in the Honorable David E. French of the 15th Judicial Circuit of Florida Dismissing a Complaint with Prejudice and causing me, the Plaintiff in this action, serious injury.

Mr. White testified before the Court on that day, “…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 A, page 11, lines 14-18)

Mr. 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…”

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.”

Mr. White did not take this opportunity to change, modify or further explain his false and purjurious testimony. He let it stand and have its full impact on the court.

This is a very simple situation. Only a trial court judge can dismiss a complaint by issuing an order granting a motion to dismiss.

If Mr. White can provide the orders from the court that show complaints had been dismissed prior to October 28, 2013, then he is not guilty of giving false and purjurious testimony to the court. But, Mr. White will not be able to produce court orders showing that multiple orders were granted involving motions to dismiss before October 28, 2013, because they don’t exist.

Mr. White cannot use the defense that he did not know his testimony was false and purjurious. How could any attorney be so completely unprepared and not have knowledge of the basic facts when going into a hearing? In addition, I have many documents that show Richman Greer knew Mr. White’s testimony was false and purjurious, yet no one from Richman Greer or Mr. White himself, took reasonable remedial measures to disclose the fact to any tribunal as required by the Florida Rules of Professional Conduct.

As per the Florida Bar’s instructions, I have not included the many documents that show Richman Greer was aware of Mr. White’s false and purjurious testimony but they are available upon request.

Mr. White is in violation of the following Florida Rules of Professional Conduct:

  1. Rule 4-3.3(a)(4) Prohibits a lawyer from offering testimony that the lawyer knows to be false. The lawyer shall take reasonable remedial measures including, if necessary, disclosure to the tribunal.
  1. Rule 4-3.4(b) Prohibits a lawyer from fabricating evidence.
  1. Rule 4-8.4(a) Prohibits the lawyer from violating the rules of Professional Conduct or knowingly assisting another to do so.
  1. Rule 4-8.4(b) Prohibits a lawyer from committing a criminal act that reflects adversely on the lawyer’s honesty, trustworthiness, or fitness as a lawyer
  1. Rule 4-8.4(c) Prohibits a lawyer from engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation.
  1. Rule 4-8.4(d) Prohibits a lawyer from engaging in conduct that is prejudicial to the administration of justice.

If Mr. White cannot produce the court orders that would substantiate his testimony, then he was not giving true testimony but instead was fabricating the existence of evidence that does not exist.

Mr. White has caused serious injury due to his false testimony, perjury and by not making any effort to remedy the situation or the serious injury he has caused me, the Plaintiff.

Mr. White’s intention was to mislead the court without regard for the potential injury that could reasonably be foreseen at the time as a result of his misconduct.

Under the Florida Bar Standards for Lawyer Sanctions disbarment is appropriate under 5.11(f) and 6.11(a-b).

This fabricated and perjurious testimony was very prejudicial and damaging.

After the Florida Bar has had an opportunity to investigate this complaint, I ask that the findings be forwarded to the appropriate District Attorney for criminal prosecution under the Florida Statutes §837.07(1)(3) which classifies perjury in official proceedings as a felony of the third degree.

The Florida Statutes §837.07(1-2), Recantation as a defense, does not apply as Mr. White does not meet either of the requirements of the statute.

This is the body of a public record on file at The Florida Bar, 651 East Jefferson Street, Tallahassee, Florida 32399-2300

Carolyn Lamm – My sister-in-law
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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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