Come show support at Probate Hearing
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FOR IMMEDIATE RELEASE

The next Probate Hearing is scheduled for April 8, 2015, at 8:45 am at the South County Courthouse, 200 West Atlantic Avenue, Delray Beach, FL 33444, Courtroom #2, Honorable David E. French presiding. Please turn out to show your support.

 Disabled Florida senior becomes impoverished due to Fraud Upon the Court by Richman Greer Attorneys John G. White, III, and Michael J. Napoleone

By Jason Halle
April 2, 2015

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, who is trying to collect his Florida inheritance left by his father, Edward Halle.

Jason’s father, 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 seem 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 disperse 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 finally exhausted his legal resources.

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 almost two years of Jason 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. That’s right, the court has dismissed the case and Peter Halle is now trying to stick Jason Halle with the $200,000.00 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 and middle class people have no rights.

Edward Halle, father of Jason Halle and Peter Halle

You can find out more from Jason Halle’s website www.jasonhalle.com

Contact

Jason Halle
209 NW 21st Court, Wilton Manors, FL 33311
Voice: (954) 654-8150
Fax: (954) 653-1513
jason@jasonhalle.com

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Strike Peter Halle’s Sanctions
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Motion to Strike Sanctions

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A motion was made to strike sanctions due to false statements made by Richman Greer Attorneys.

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 JASON HALLE’S MOTIOIN TO STRIKE PARAGRAPHS 1, 2, 3, 4 AND 10 OF DEFENDANT’S MOTION FOR SANCTIONS FILED ON JANUARY 7, 2015

Plaintiff, Jason Halle, pursuant to Rule 1.140(f) of Florida Rules of Civil Procedure, hereby moves this Court to strike paragraphs 1, 2, 3, 4, and 10 of Defendant Peter Halle’s Motion for Sanctions. In support Plaintiff states as follows:

  1. In ¶ 1 of the Defendant’s motion he fabricates that, “Since that initial filing, Plaintiff amended his complaint five times and attempted to amend a sixth time.”
  2. The Plaintiff has only amended his complaint successfully three times during this action as confirmed by the docket and the court’s orders. They are as follows:
    1. On February 22, 2012, the original complaint was amended with the First Amended Complaint by entitlement.
    2. On May 30, 2012, the Defendant stipulated to the entry of an agreed order on plaintiff’s motion to obtain leave of court to amend his First Amended Complaint and file his Third Amended Complaint. (Exhibit A) On June 4, 2012, the Honorable James Martz signed the agreed upon order. (Exhibit B)
    3. The Defendant prepared an agreed order on plaintiff’s motion to obtain leave of court to amend his Third Amended Complaint and file his Fourth Amended Complaint. On April 16, 2013, the Honorable David E. French sign the agreed upon order. (Exhibit C)
  3. No other amendments were allowed by or filed with this Honorable Court.
  4. It is total fabrication that the Plaintiff amended his complaint five times. It is not supported by the docket or the orders of the Honorable Court in this case. It follows that the Plaintiff could not have attempted to amend his complaint for a sixth time as the Defense states, since he only had successfully amended his complaint three times. These false and inflated numbers of amendments claimed by the Defense in ¶ 1 should be stricken as the statements are untrue and designed to be impertinent, inflame the court and prejudice the Plaintiff.
  5. In ¶ 2 the Defense claims, “The trial court orally stated that it was dismissing the complaint with prejudice because Plaintiff had numerous chances to try and state a cause of action and he repeatedly failed to do so”. There was a court reporter at his hearing. There is no reference to the court having made such a statement on the record. There are no motions to dismiss that were granted that would suggest this was true. This totally false statement is a fabrication and is designed to inflame the court and prejudice the Plaintiff. The Defendant’s claim is totally unsubstantiated and should be stricken from the motion.
  6. Again, in ¶3 of the Defendant’s motion he fabricates that the Plaintiff sought to amend his Complaint for a sixth time. Please refer to Plaintiff’s ¶’s 1-4 above. This is another totally false statement fabricated and designed to inflame the court and prejudice the Plaintiff. The Defendant’s claim is again totally unsubstantiated and should be stricken from the motion.
  7. In ¶ 4 Defendant states that, “In his appeal, Plaintiff sought to divert the appellate court’s attention from his pleading deficiencies by baselessly attacking Defendant Peter Halle’s counsel, John G. “Jay” White, III, with unfounded claims that Mr. White mislead this court at the hearing on the motion to dismiss”.
  8. This is untrue and as one can clearly see in the transcript of the hearing, White fraudulently told the Court, “…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 D, page 11, lines 14-18)
  9. The Plaintiff did not baselessly attack Mr. White as the Defense claims. As the transcript confirms, Mr. White clearly did try to mislead the court with fabricated, untrue statements. ¶ 4 should be stricken as it is not true, it is impertinent and is designed to inflame the court and prejudice the Plaintiff.
  10. The Defendant again gives impertinent information in ¶ 10 that is designed to inflame the court and prejudice the Plaintiff by stating, “This Court then determined that a dismissal with prejudice was appropriate, especially in light of the fact that repeated opportunities afforded Plaintiff to amend his complaint to state a cause of action.” It is not even clear exactly what the Defense counsel is trying to state here.
  11. Only Mr. White stated at the hearing that there had been dismissals for failure to state a cause of action. The only person in a Trial Court that has the authority to determine if a complaint fails to state a cause of action is the judge at a hearing on a motion to dismiss. There had not been one dismissal granted by a trial court judge as confirmed by the docket or one dismissal amendment afforded the Plaintiff after his first dismissal for failure to state a cause of action. This is also confirmed by the docket.
  12. Paragraph 10 needs to be stricken because it is unclear, untrue, impertinent, and designed to inflame the court and prejudice the Plaintiff.

WHEREFORE, Plaintiff respectfully requests that this Court strike ¶’s 1, 2, 3, 4 and 10 of Defendant Peter Halle’s Motion for Sanctions, because they are impertinent, not true and they are designed to inflame the court and prejudice the Plaintiff.

And for such further relief as this 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.

Richman Greer Fraud Upon the Court
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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.

Edward Halle
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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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