Seeking Plaintiff’s Attorney
avatar

Plaintiff’s Attorney

I am looking for a plaintiff’s attorney to represent me on a contingency basis

The case involves a Florida trust that was to be distributed and terminated in 2007 according to the trust document, and still has not been distributed or terminated.

It involves a qualified beneficiary, who is a qualified distributee, who is elderly, chronically ill, HIV positive for 38 years, who has suffered several heart attacks and several bouts of cancer.

Never once has my position as a qualified beneficiary or qualified distributee been disputed or challenged in any court or pleading. Never once has Peter Halle who resides in Washington, DC disputed the fact that Peter Halle is the sole Trustee and has a fiduciary duty towards me.

I have lost not only money and my health, but income and capital appreciation from those monies, and property tax benefits from the loss of the home I had cherished for 13 years.

I have been defrauded for more than 10 years. Peter Halle has also defrauded Medicare and the IRS because of his actions or lack of actions.

State and Federal Law violations include but are not limited to:

Exploitation Of An Elderly Person Or Disabled Person (Fla. Stat. §§825.103 et.seq.);

Perjury;

Fraud;

Mail and Wire Fraud;

Denial of Due Process, 14th Amendment rights;

Tax Fraud;

Violation of the Americans with Disabilities Act;

Breach of Fiduciary Duty.

I have been fighting pro se for many years. I now understand that this is not viable. The justice systems in Broward County and Palm Beach County have treated me unfairly and denied me due process because I didn’t have the money to hire an attorney and decided to represent myself.

I thought the facts of how the Trustee stole a huge amount of money from me was so cut and dried that any honest Judge would quickly find in my favor. I now understand that I need help. Justice is not easily obtained by pro se litigants in South Florida.

I need an attorney that believes in justice, knows how to get this case moved to a venue where the Edward Halle Trust and the thousands of pages of documentation I have can be fairly evaluated by a jury for the first time.

Please let me know if you are a Plaintiff’s Attorney that has any questions, an interest in helping me survive and/or the ability to help me obtain at least a molecule of justice.

Thank you very much for your valuable time.

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.

Judge Michael Gates

Judge Michael Gates

Judge Michael Gates

Jason Halle had a hearing before the Honorable Judge Michael Gates in Broward County Civil Court on February 10, 2016. The Defendants are trying to get the case dismissed. They lied many times to Judge Gates during the hearing, committed alleged perjury and alleged subornation of perjury.

Judge Gates ordered that both sides send proposed orders to his chambers by February 24, 2016. He will make his ruling after that date.

Judge Gates seemed like a gentleman and listened politely to both sides. He smiled at times and made polite responses to the litigants. What a completely different experience this was than Jason Halle had in the Palm Beach Probate Court. Judge French was always yelling at him, telling him to get an attorney. Jason doesn’t remember him ever smiling once.

Judge French’s advice was pretty bizarre, since there are not many attorneys that will take the case of a person that has a grievance in the probate court in Palm Beach County. I have heard this is because they all know of the corruption there and the small odds of getting a fair hearing.

Jason Halle is done in the Palm Beach Probate Court where the attorneys lied repeatedly to Judge David French and as a result collected an attorney fee of $183,811.48, even though their client Peter Halle was in violation of Florida law for more than 8 years and they had lied to a Judge to get the case dismissed. None of the claims were ever adjudged. No opinion was given by the Fourth District Court of Appeal, even after one was requested.

In the Broward County action, Jason Halle alleges that defendants: Peter E. Halle, Carolyn B. Lamm, John G. White III, Michael J. Napoleone, Charles H. Johnson and the Richman Greer Professional Associate engaged in:

Gross negligence/Intentional Misconduct

Tortious Interference with Inheritance

Intentional Infliction of Emotional Distress

Fraud Upon the Court (intrinsic and extrinsic)

Civil Conspiracy/Aiding and Abetting/In-Concert Liability

The Complaint was filed with the Clerk of the Broward Court on October 12, 2015. The Case Number is: CACE-15-017841

Broward Civil Court

Broward Civil Court

Broward Civil Court

The Broward Civil Court

Jason Halle is done in the Palm Beach Probate Court where the attorneys lied to Judge David E. French and as a result they collected a hefty attorney fee of $183,811.48, even though their client Peter Halle was in violation of Florida law for more than 8 years.

There are no consequences for Judge David E. French. Judges have immunity in our society, which means they can cause a person as much harm as they choose without any due recourse in the law for their actions. There are seldom consequences for Judges no matter what they do.

Jason Halle has now filed a lawsuit in Broward County Civil Court before the Honorable Judge Michael L. Gates.

Jason Halle alleges that the defendants: Peter E. Halle, Carolyn B. Lamm, John G. White III, Michael J. Napoleone, Charles H. Johnson and the Richman Greer Professional Associate engaged in:

Gross Negligence/Intentional Misconduct

Tortious Interference with Inheritance

Intentional Infliction of Emotional Distress

Fraud Upon the Court (intrinsic and extrinsic)

Civil Conspiracy/Aiding and Abetting/In-Concert Liability

The Complaint was filed with the Clerk of the Broward Court on October 12, 2015. The Case Number is: CACE-15-017841

Judge French Awards $183,811.48
avatar

Judge David E. French

Judge David E. French Awards

Judge David E. French Awards $183,811.48 to Peter Halle

Click on my photo above to read an article one of Judge David E. French’s buddy’s, Adam M. Myron, a partner of Richman Greer, wrote about his good old friend the Judge. Adam was one of the attorneys that this award was based upon.

I am Jason Halle. I am a qualified beneficiary of the Edward Halle Trust and a qualified distributee as well.

In 1987 Ronald Siegel, an attorney that was practicing law in Boca Raton, Florida, wrote a easy to understand Trust document for my dad, Edward Halle. It clearly stated that upon the death of my mother, Elaine Halle, the trust was to be distributed immediately to the beneficiaries and then terminated.

The trigger for disbursement and termination of the Trust occurred in August of 2007. Peter Halle, the Trustee chose to ignore the instructions of the Trust and refused to make the distributions and terminate the Trust. This was a breach of the Trust as well as a violation of at least a dozen Florida laws. Peter Halle never gave a reasonable explanation regarding his actions.

I hired two attorneys to try to get my brother, Peter Halle, to follow the instructions of the Trust and the laws of Florida. My attorneys were ignored, one of them for a year and a half.

In my opinion Peter Halle was playing with me. I felt he was like a child pulling the wings off a fly. Peter Halle was well aware of my heart condition, previous heart surgery, AIDS, cancer operations, etc.… Peter Halle just seemed to be enjoying my suffering and waiting for me to die so he could keep all the money.

In 2011, I tried find an attorney to help me. It was obvious at this point that going to court was the only option because Peter Halle kept breaking the law and breaching the Trust. Peter Halle was even filing fraudulent tax returns for the Trust, implying that he was making distributions that never in fact happened. This raised my tax liabilities and caused me further harm.

After copying the file many times and delivering it to many attorneys and having many consultations, all of the attorneys I met with refused to represent me or I could not afford them. They were all very positive until I mentioned that my brother’s wife, Carolyn B. Lamm was recently the President of the American Bar Association (2009-2010).

I decided to take the matter to the probate court in West Palm Beach myself, without an attorney. My reasoning was, I am a qualified beneficiary, a qualified distributee and I have a valid Trust document created by Ronald Siegel. Esq. of Boca Raton, Florida.

My brother Peter Halle, a well-established lawyer licensed to practice in Florida and the District of Columbia, was breaking the law, breaching a Florida Trust and had filed a Notice of Trust with the Palm Beach Court in 2007. I figured, what could go wrong?

WOW, everything went wrong. But not at first. The case was assigned to Judge James Martz. Judge Martz seemed to be very impartial and things were going along very well while he was presiding.

Then there was a rotation of Judges. Suddenly Judge David E. French became the Judge in charge of this case. Impartiality seemed to disappear. Judge David E. French always appeared to be angry at me. Many times he told me I should hire an attorney, that probate court was no place for a pro se litigant. This seemed harsh since it was my right to obtain justice from the probate court, with or without an attorney. Since I could not find an attorney to represent me that I could afford, I did not seem to have any other options. Believe me, I tried.

My brother, Peter Halle’s response was to eventually hire ten (10) of top attorneys in Southern Florida to work on the case. They were Alan G. Greer, Charles H. Johnson, Michael J. Napoleone, John “Jay” G. White III, Adam M. Myron, Ethan J. Wall, Joshua I, Spoont, Leslie A. Metz, Marta Stypulkowski, Georgia A. Buckhalter, all from Richman Greer.

I later learned from testimony in court by Michael J. Napoleone that Peter Halle’s wife, Carolyn B. Lamm was good friends with Alan G. Greer. It was because of their special relationship and the fact that Carolyn had been a past President of the American Bar Association (ABA) that Richman Greer was not concerned about not being able to find a fee agreement between any of the parties. By law, as a qualified beneficiary, I should have been provided a fee agreement when attorneys were first hired by the Trust if there had been an agreement as they claimed.

Carolyn B. Lamm used her enormous legal expertise to help her husband Peter Halle violate the Florida laws and breach the Trust. Carolyn, besides being a past President of the American Bar Association (ABA) is also a Florida attorney.

On June 6, 2013, John G. “Jay” White, III and Michael J. Napoleone of Richman Greer stated in a court document that, “Notably, Plaintiff’s motions (my motions) to amend have not arisen as a result of the Court’s dismissal of any of Plaintiff’s prior complaints or claims…”

Then 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, “And this – I don’t know if it’s leverage or what – but the plaintiff 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.”

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 Judge David E. French’s courtroom and the Judge wouldn’t acknowledge it or let it be discussed. It was like having an 8,000 pound elephant in the room that was off limits!

On November 13, 2015, Judge David E. French signed a Final Order allowing Peter Halle, Trustee for the Edward Halle Trust, to reimburse himself from the Trust in the amount of $173,490.48 for the fees he paid to Richman Greer. Then another $6,046.00 to Richman Greer for Trust Administration. The Order also allowed payment of another $4,275.00 to attorney John B. Murray, Esq. So that comes to a total of $183,811.48.

Trust administration? Where was there any Trust administration other then the fraudulent tax returns and a refusal to follow the instructions of the Trust?

There still has been no distribution and termination of the Trust. Florida laws are still being violated by Peter Halle.

My claims had been reasonable. Fraud upon the Court had been committed. My status as qualified beneficiary and qualified distributee had never been challenged. The Edward Halle Trust or any of its instructions had never been challenged.

Judge David E. French stated in his Final Order, “The Court now states what the record accurately reflects: that the results obtained for the Defendant by its attorneys virtually could not have been better.” That is an understatement. They must have said the same thing about O.J. Simson’s attorneys.

If you are an honest person with a serious problem that needs legal resolution in the probate court; if you are not rich; a privileged millionaire; or have powerful contacts in Washington and you find yourself in Judge David E. French’s courtroom, in my opinion you are in very big trouble.

Do you have a valid will or Trust that specifically states who the beneficiaries are? Not important in Judge David E. French’s courtroom.

Are you an attorney that believes the best way to win a lawsuit is to lie to the Judge? This is not a problem in Judge David E. French’s courtroom either. Every time I tried to bring this up I was silenced by Judge French. When I wrote a motion asking for a rehearing due to John “Jay” G. White’s Fraud Upon the Court, he dismissed it without even hearing any arguments.

When I asked Judge David E. French to recuse himself because he was prejudging motions, he refused.

This is my story. It is true and I have the documents to prove everything I’ve said. The opinions stated are my own.

The Florida Bar
avatar

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

Florida Inheritance denied to disabled senior
avatar

Senior Citizen is denied Florida inheritance by legal system

DENIED

DENIED

Disabled Florida senior becomes impoverished due to malicious actions of politically connected Washington, DC and Florida legal experts

Justice, Freedom, equal access to the law. None of these seem to be working for Jason Halle, a disabled senior citizen that resides in Wilton Manors, Florida.

Jason’s father, Edward Halle, knew his son Jason was legally disabled and was struggling with life threatening health issues each day of his life. Edward Halle wanted to be sure his son Jason had comfort and economic security after he and his wife Elaine Halle were gone. The documents that Edward paid his attorney Ronald Siegel of Boca Raton, Florida to create in order to accomplish this turned out to be worthless.

Edward Halle named his older son Peter Halle to act as Trustee. He was proud Peter became an attorney and told Jason this would save on attorney’s fees and would make the process easier for Jason.

But the money Peter Halle was supposed to disburse to Jason never materialized. First there were excuses. Then a promise the money would be disbursed. Then years of Peter Halle ignoring Jason’s requests for his Florida inheritance. This has been going on since 2007.

Peter Halle is now a retired attorney. He was a partner in the famous Washington, DC, law firm Morgan Lewis. His wife is Carolyn Lamm, also a Washington, DC, attorney and a partner at White & Case. Carolyn Lamm is a past President of the American Bar Association and was voted one of Washington’s 100 most powerful women in 2011. Peter and Carolyn Lamm regularly had Senators and Congressmen to their Washington, DC, home and even Hilary Clinton had been a guest.

So why didn’t Peter Halle disburse the money or attend to the many other fiduciary duties that he was required to perform under Florida law? I would guess that when you are as wealthy and powerful as he and his wife Carolyn Lamm are, you start to believe that you are above the law.

In 2011, Peter Halle was still ignoring Jason’s requests for his inheritance. Two letters from attorneys that Jason hired to plead on his behalf had no success. Jason Halle decided he would need to find an attorney to take his brother to court and compel him to follow the laws of the State of Florida. One lawyer wanted a $60,000.00 retainer. All the other lawyers Jason interviewed were not interested in taking the case when they realized how powerful and connected his brother Peter Halle and his wife Carolyn Lamm are.

Jason naively believed that this was an open and shut case and that the law was 100% on his side. Jason filed a Pro Se Complaint (without the aid of an attorney) against his brother in the 15th Circuit Court in and for Palm Beach County, Florida, on November 4, 2011. His brother Peter responded by hiring the Richman Greer law firm of Miami and West Palm Beach, Florida to represent him and fight Jason with every legal trick known to the profession in order to obstruct Jason from obtaining his Florida inheritance. Peter Halle kept ignoring the Florida laws that were designed to protect beneficiaries like his brother Jason. The whole defense of the lawsuit was frivolous and without merit or basis in law or fact.

Charles H. Johnson of the Miami office was hired back in 2008, so Jason could no longer contact his brother directly and had to go through Peter’s attorney. Then Michael J. Napoleone became involved in 2011, to represent Peter Halle in court. Then more attorneys became involved including John G. White, III. A whole law firm began fighting against Jason Halle to stonewall him from receiving his inheritance. I know this all sounds like fiction, but it is not. Court documents will substantiate all of the facts about the legal actions that ensued.

After over three years of Jason Halle spending days at a time in law libraries, writing legal briefs, motions and creating numerous other documents and after numerous court appearances Jason believed he was holding his own. Peter Halle did not appear once in court during the proceedings. Jason even won an appeal Peter’s attorney’s started in the Fourth District Court of Appeal of Florida regarding jurisdiction. Quite an accomplishment for a Pro Se litigant.

Fraud Upon the Court

Then the unthinkable happened. On August 28, 2013, John G. White, III of Richman Greer committed fraud upon the court. That is the legalese way to say he lied to the Judge during the hearing held on that date. As a direct result of those lies, the Honorable David E. French dismissed the case!

They now want Jason Halle to pay the legal fees of the attorneys that lied in court

Now Peter Halle’s attorneys have filed a motion to compel Jason to pay the Richman Greer legal bill of $200,000.00 PLUS. That’s right, the court has dismissed the case and Peter Halle is now trying to stick Jason Halle with the $200,000.00 PLUS legal bill to pay his lawyers that won by lying in court to get the case dismissed. Jason still doesn’t have his Florida inheritance, and by dismissing the case the court has ruled that Peter Halle never has to pay Jason a cent of his inheritance as a result of the lies the Richman Greer attorneys told in court and wrote in legal briefs.

How can a person fight against such wealth, power and lies? Jason is still trying, but no attorney in Florida has offered to help him. No media outlet has offered to help let the public know about the injustice of the Florida legal system. Nobody seems to think it is unusual that the rich and powerful can produce any results they want in a court room.

Edward Halle

Edward Halle, father of Jason Halle and Peter Halle

Richman Greer Fraud Upon the Court
avatar

Richman Greer

John G. White, III Motion

Richman Greer, John G. White, III, Motion

IN THE CIRCUIT COURT FOR THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA

CASE NO. 502011CPOO5095XXXXSB

JASON HALLE,

Plaintiff,

vs.

PETER HALLE,

Defendant.

__________________________ /

PLAINTIFF’S MOTION FOR RELIEF FROM ORDER OF SEPTEMBER 25, 2013

            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,

JASON HALLE, Pro Se

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.

Carolyn Lamm – My sister-in-law
avatar

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

Leave and Read Comments

Read about Peter Halle

Complaint filed against Peter Halle, Jason Halle’s brother.
avatar

Complaint filed against

Peter Halle

Peter Edward Halle

Peter Edward Halle

On November 4, 2011, Jason Halle filed a Complaint against his brother Peter Halle in the Circuit Court of the 15th Judicial Circuit in and for Palm Beach County, Florida. The Complaint alleged, among other things, that Peter Halle an attorney at the law firm of Morgan Lewis in their Washington, D.C. office, breached his fiduciary duties, failed to give an accounting, waste, and gross breach of duty with regard to dealings with his brother concerning the Edward Halle Trust.

Peter Halle is the Trustee of the Edward Halle Trust.  This Complaint never had a responsive pleading. Their has never been a logical explanation of the Trustee’s behavior in this action.

Peter lives in Washington, DC with his wife Carolyn Lamm who works at the law firm of White & Case. She is a past President of the American Bar Association. They have two children.

The progress of this lawsuit can be followed by going to the Comptroller’s office website and then searching for the records using the case number: 2011cp005095