Judge Rules
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Judge David E. French Courtroom in Delray Beach, Florida

Judge David E. French Courtroom in Delray Beach, Florida

The hearing on June 16, 2015, went exactly the way Judge French had prejudged it would during the hearing on April 8, 2015.

My motion for relief was denied. My attempt to question the Richman Greer attorneys about the lies that were told in Court on August 28, 2013, was not allowed despite the law stating that in allegations of Fraud Upon the Court there should be an evidentiary hearing to determine the truth.

If Judge David E. French had allowed such a hearing or granted the motion for relief both John G. White, III and Michael J. Napoleone from the law firm of Richman Greer could have been brought up on charges of misconduct. Judge David E. French was not going to let that happen to his colleagues.

So, in fact it did boil down to how much of my brother’s attorney’s fees I would have to pay.

I kept telling Judge David E. French, My father left me a quarter of a million dollars, I came to this court for help to collect it. This court has never denied that my brother owed me a quarter of a million dollars or that he has broken a dozen Florida laws and been in Breach of Trust for eight years.

Judge David E. French admitted that this was all true.

Judge David E. French was not moved. Just as he had prejudged on April 8, 2015, all he cared about was determining how much my brother’s attorneys would collect for getting the case dismissed despite the fact that there was no reasonable explanation as to why the case was really dismissed. It certainly was not in accordance with the way I read the case laws of Florida.

The positive things that came out of the hearing:

  1. Judge David E. French ruled the attorneys from Richman Greer could not collect fees for their work on the appellate portions of this case.
  1. The request by my brother’s attorneys that I be personally liable for all the fees because they claimed this case was frivolous and without merit was denied.

There also has been no resolution in this case that requires my brother, Peter Halle, a Florida attorney, to stop violating Florida laws or to distribute any of the money my father left to me.

Back Story

Hearings – June 16, 2015
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A Hearing before Judge David E. French

was held on

Tuesday, June 16, 2015 at 2:00 p.m.

Hearing on June 16, 2015

Hearing on June 16, 2015, before Honorable Judge David E. French

The hearing before Judge David E. French was held on:

Tuesday June 16, 1015, at 2:00 p.m.

South County Courthouse, 200 West Atlantic Avenue, Courtroom 2

Delray Beach, Florida 33444.

There already had been Orders that stated that there will be NO consequences for Peter Halle, a Florida Attorney, that has violated about a dozen Florida Statutes (laws) and has been in breach of Trust for about eight years.

The Appeal Court has decided that there has been no prejudice involved in that ruling even though I still don’t have my inheritance and the ruling allows my brother Peter to keep the money. All of the attorneys involved just keep focusing on the fees they are getting and that they have protected one of their own.

The bias against this Pro Se litigant is immense. This whole court action seems to have degenerated into how to save the Defendant, a Florida Attorney who was in Breach of Trust for eight years and who had violated a dozen Florida Statutes. The goal being that he have no negative consequences for his unlawful actions.

Then the next objective of the Court was not to allow any evidentiary testimony that would confirm that John G. White, III of Richman Greer law firm in West Palm Beach and Miami was guilty of misconduct for committing Fraud upon the Court. More Florida attorneys escaping negative consequences of their actions.

Now the victim, Jason Halle, is being told that according to Judge French’s ruling the Defendant Peter Halle can keep the money and Jason will have to pay one half of the Defendant’s legal fees!

Judge David E. French agrees that the Court never found that Peter Halle was not in Breach of the Trust. He also agreed that the Court never found that Peter Halle was not in violation of the many Florida Statutes in the Complaint.

Judge French never stated that John G. White, III of Richman Greer in West Palm Beach and Miami had not committed Fraud Upon the Court.

Judge French knew that Jason Halle is gay, has been HIV+ for 36 years, has a heart condition, is a cancer survivor three times and ran out of money while trying to get his brother to disburse his inheritance according to the terms of the Trust Document.

It seems to make sense why Judge David E. French is bias towards all of the Florida attorneys involved. He knows them. The Defendant’s wife, Carolyn B. Lamm, is a past President of the American Bar Association (2009 – 2010). They are all members of the same powerful club that reaches all the way back to Washington, DC.

I have always paid my taxes and tried to do the right and honest things in my life. I am naive, because I do not understand were all of the negative bias towards me is coming from. I expected justice from the Palm Beach Circuit Court.

All of the motions had been prejudged at a previous hearing. A Motion to Recuse had been Denied. A Petition for Writ of Prohibition had been denied. Everything ended up going down exactly as Judge David E. French had previously prejudged.

Is this a situation about powerful organizations protecting their own? Rich, powerful, politically connected lawyers and a gay, HIV+, Jewish, senior citizen with limited resources.

Everyone should be interested. If the courts are willing to do this to me, you can be sure they will be willing to do this to you.

 

The Back Story

Richman Greer Attorney tries to influence Judge
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John G. White of Richman Greer is trying to influence Judge French

John G. White of Richman Greer is trying to influence Judge French

A letter that I wrote to Judge David E. French yesterday pretty much sums up what Mr. John G. White, III of Richman Greer is attempting to accomplish.

There is still a Petition for Writ of Prohibition in the Appellate Court that has not been decided.

Mr. White seems anxious to try to push things forward quickly before any ruling from the Appellate Court so that he will not lose a Judge that is prejudging motions in his favor.

Here is the letter I wrote:

Dear Judge French,

This morning Mr. John G. White, III of Richman Greer sent you a letter asking you to sign a proposed Order Scheduling a Special Set Hearing on “all pending motions” for Tuesday, June 16, 2015 at 2:00 p.m. reserving two hours for same. (Copy Enclosed)

Mr. White neglected to inform you that on May 31, 2015, he was served with a Motion to Stay Further Proceedings in the Lower Tribunal. (Copy enclosed)

Mr. White further neglected to inform you that I had sent him an email on May 31, 2015, informing him about the UMC hearing on June 16, 2015, and that according to your suspension calendar you would not be available the week before. (Copy enclosed)

The hearing at your UMC has already been noticed and the Notice has been filed. (Copy enclosed)

In the proposed Order sent to you by Mr. White, it would make it impossible for me to comply with the requirements for submission of all relevant pleadings, etc… to be in your Court 7 days prior to the hearing.

I am not in agreement with Mr. White’s proposed Order and believe it would be in violation of the Florida Rules of Appellate Procedure.

Thank you very much.

Very respectfully,

Jason Halle, Pro Se

Judge David E. French Will Not Recuse Himself
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Judge David E. French

Judge David E. French will not recuse himself

On April 28, 2015, Judge David E. French mailed me an Order Denying Petitioner’s Motion to Disqualify Judge David E. French. The order was dated on April 22, 2015, despite the fact that it sat in his chambers for 6 days before he mailed it.

Copy of Envelope

Copy of Order

Back Story

Photo and Bio of Judge French

Now it will be necessary to file a Petition for Writ of Prohibition with the Fourth District Court of Appeal.

No one on this planet other than me seems to find any of this unusual. It just seems to be business as usual in the 15th Circuit Court in Palm Beach County.

 

 

Judge David E. French
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Hearing before Judge David E. French

Click here for bio of Judge David E. French

For bio of Judge David E. French click on graphic.

On April 8, 2015, I went to another hearing before Judge David E. French. I had the impression that Judge French was ranting at me while being very cozy with the opposing counsel.

In the hall outside the courtroom after the hearing, a person came up to me. They did not identify themselves. The person said to me, “I just want to let you know that it is obvious that at your next hearing Judge French is going to deny any motions you have for relief and grant all the motions your brother has for attorneys’ fees and sanctions.”

I thanked the person for their observations. Then I asked why they though this would happen?

“It’s obvious the opposing counsel is his buddy and the judge is prejudiced against you. What did you do to him?”

“I’m Jewish, gay, HIV positive, a cancer survivor and have a bad heart condition. All I have been doing is trying to obtain the inheritance that my dad left me eight years ago. My brother is a Florida attorney and the Trustee of my dad’s estate. My brother has already spent more than $200,000.00 in legal fees. I had to let my attorney go because I could not afford to pay her anymore and I have been forced to represent myself. I have no idea which of these things has Judge French so prejudiced against me.”

The stranger concluded by saying, “I just wanted to give you the opinion of someone that is not invested in your situation. You will get absolutely nothing in Judge David E. French’s courtroom. He has already made up his mind about everything.”

This was wonderful input, even though it is not what I wanted to hear. I went home and thought about it.

Yesterday on April 14, 2015, I filed the following motion with the Court:

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.
__________________________ /

MOTION FOR DISQUALIFICATION OR RECUSAL

Plaintiff, Jason Halle, files this motion/affidavit/application pursuant to Rule 2.330 of the Rules of Judicial Administration, specifically Rule 2.330(d)(1) that the party fears that he or she will not receive a fair trial or hearing because of specifically described prejudice or bias of the judge. This motion/affidavit/application is also pursuant to Florida Statutes § 38.10, Disqualification of judge for prejudice; application; affidavits, etc. This motion/affidavit/application is also pursuant to Canon 3 E of the Florida Code of Judicial Conduct:

  1. My name is Jason Halle, I am over the age of eighteen and competent to issue this declaration. I am the Plaintiff in this action and make this declaration based upon my personal knowledge.
  2. I am a Pro Se litigant and certify that this motion/affidavit/application is made in good faith.
  3. In the transcript of the hearing held before the Honorable David E. French on April 8, 2015, (Exhibit 1), Judge French said on page 8, line 19, “Then he’s (the Defendant) going to be entitled to attorney’s fees. Now, the only issue is how much. That’s what the hearing is about.”
  4. Judge French has already prejudged the relief from his Order of May 31, 2013, that prohibits the Edward Halle Trust from paying attorney’s fees or litigation costs unless and until such relief is granted by the Court. (Exhibit A of     Exhibit 2).
  5. On February 11, 2015, the Plaintiff served his Response to Defendant Peter Halle’s Motion to Permit Payment of Attorney’s Fees and Costs from the Edward Halle Trust Assets. In his Response the Plaintiff cites case law that the Defense attorneys have waived their entitlement to attorneys’ fees under Florida Law. (Exhibit 2)
  6. Judge French has already prejudged the motions having to do with attorneys’ fees and punitive sanctions requested in the Defendant’s motions concerning attorneys’ fees.
  7. In fact there are a total of seven motions pending before the Court:
    1. Plaintiff’s Motion for Relief from Order of September 25, 2013
    2. Plaintiff’s Motion to Strike Paragraphs 1, 2, 3, 4, and 10 of Defendant’s Motion for Sanctions
    3. Plaintiff’s Motion to Strike Paragraph 10 of Defendant’s Motion to Permit Payment of Attorney’s Fees and Costs
    4. Defendant’s Motion for Fees and Costs
    5. Defendant’s Motion to Permit Payment of Attorney’s Fees and Costs
    6. Defendant’s Motion for Sanctions
    7. Plaintiff’s Motion for Sanctions on Defendant Peter Halle’s Motion to Permit Payment of Attorney’s Fees and Costs
  8. Judge French continues on page 8, line 24 of the transcript (Exhibit A), “Your motion – you have a motion for relief for what?”
  9. On page 9, line 1, Mr. Halle (Plaintiff) responded, “Based upon the fact that Mr. White made fraudulent statements and committed fraud upon the Court which influenced your decision during that hearing.”
  10. Judge French then said, “Well, we don’t reargue things that have already been – it’s called res judicata, okay? We don’t reargue the motions. I have already made a determination.”
  11. Judge French has prejudged Plaintiff’s Motion for Relief from Order of September 25, 2013. (Exhibit 3) This motion is still pending before the Court.
  12. The law of the case, res judicata and collateral estoppel are not relevant in this situation because the facts in this motion are different from the facts in the original Hearing and the subsequent appeal that was per curiam affirmed. This was a conflict PCA with no written opinion. Which facts the Appellate Court ruled upon are unknown and do not include the facts in Plaintiff’s motion. This would make the application of res judicata inappropriate and not viable.
  13. It is clear from Judge French’s statements that he has already prejudged the pending motions before the Court.
  14. It is clear that Judge French has a strong bias against the Plaintiff and a strong positive bias for the Defendant.
  15. It is clear that there is substantial prejudice against the Pro Se Plaintiff.
  16. The Plaintiff has reasonable fear that he will not receive a fair hearing.

Respectfully submitted,

JASON HALLE, Pro Se
jason@jasonhalle.com
April 14, 2015

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.

More about the Lawsuit

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

###

 

Strike Peter Halle’s Sanctions
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Motion to Strike Sanctions

Click for Richman Greer Bio

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.

Florida Inheritance denied to disabled senior
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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

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