Accuser of Christine O'Donnell LIED, charges Complaint to D.C. Bar seeking Disbarrment

The FREEDOMIST ^ | June 13, 2011 | Paul Collier

[Moseley]

http://freedomist.com/2011/06/melanie-sloan-christine-odonnell-attacker-faces-legal-ethics-issues-bar-complaint-filed-by-jonathon-moseley/

Melanie Sloan, Christine O'Donnell attacker, faces Legal Ethics issues- bar complaint filed by Jonathon Moseley

The Freedomist is following the political hack attack attempted by Melanie Sloan (CREW uses Christine O'Donnell complaint as fundraiser- how lies, slander, and libel gets Melanie Sloan funded- Freedom News) and her progressive cronies (Man throws nephew under bus to attack Christine O'Donnell- The David Keegan Story) who seem to have some unnatural fear of Christine O'Donnell, the Delaware Tea Party Senate Candidate who upset the progressive Mike Castle in the GOP primary  (O'Donnell WINS!), only to see  the Delaware State GOP turn against her (Teaparty's Delaware Senate loss pinned on establishment GOP refusal to act- Tea Party News) to assure a progressive victory in the form of Chris Coons (now a proud progressive Senator from the progressive state of Delaware).  We stumbled upon this gem from a Virgina Website that outlines a bar complaint against the progressive Melanie Sloan (One down, one to go- FEC tosses out Christine O'Donnell complaint) for her attempt to use the FEC (Breaking Exclusive: Crew Director uses own Father to levy FEC charges against Christine O'Donnell- Tea Party News ) to silence any opponent to her Soros-funded progressive dream for America:

BAR COMPLAINT Against MELANIE SLOAN
re: Frivolous Charges Against
CHRISTINE O'DONNELL
Spreading Lies By David Keegan

from http://www.defenseforvirginia.com/ODonnell.html

Jonathon Moseley today filed an official complaint with the District of Columbia "Bar" asking that Melanie Sloan be disciplined or disbarred, responding to false charges brought against 2010 Delaware U.S. Senate candidate Christine O'Donnell from D.C. lawyer Melanie Sloan.

Jonathon Moseley commented:  "Melanie Sloan violated numerous D.C. Bar rules and committed perjury in her complaint (sworn to under 18 USC 1001) and in her false public statements about Christine O'Donnell. A lawyer may not make false statements in the course of representing a client, even in non-legal contexts. Here, Melanie Sloan's many false statements were clearly intended to cause governmental resources to be used in furtherance of her clients' private agenda. D.C. Bar rules require a lawyer to promptly inform authorities upon discovering that a previous complaint is false."

Proof that Melanie Sloan's accusations against Christine O'Donnell are false is chronicled in detail in Jon Moseley's Complaint. A copy of the Complaint against Melanie Sloan filed with the D.C. Bar on June 13, 2011, can be downloaded by CLICKING HERE (recommend using the right click button on the mouse and selecting "SAVE AS" option).

Jon Moseley's affidavit regarding admissions made to him by David Keegan can be downloaded by CLICKING HERE (recommend using the right click button on the mouse and selecting "SAVE AS" option).

Moseley further commented: "Melanie Sloan for her client Citizens for Responsibility and Ethics in Washington falsely claims that in 2009 Christine O'Donnell was not a candidate for office, thus questioning the legality of travel and meeting expenses charged to O'Donnell's campaign. However, Sloan knew or could easily have discovered that Christine O'Donnell filed her Statement of Candidacy for the 2010 election on March 20, 2009; told WDEL radio in Delaware on February 13, 2009 that she was putting together a campaign for the 2010 U.S. Senate election; purchased campaign software on January 8, 2009; and in December 2008 posted an ambiguous 'testing the water' encouragement to her supporters about possibly running in 2010. Melanie Sloan violated the rules of the D.C. Bar by calling Christine a criminal when Sloan knew or should have known that Christine was in fact legitimately preparing a U.S. Senate campaign as early as January 2009."

Jonathon Moseley further explained: "Melanie Sloan based her false statements and frivolous complaint on the affidavit of David Keegan. But David Keegan admits he left O'Donnell's campaign in August 2008. David Keegan loaned Christine O'Donnell's campaign $2,300 on July 25, 2008, which was paid back on August 1, 2008. Sloan claims to have interviewed Keegan extensively. Melanie Sloan admits in her own voice that Sloan's accusations concern 2009 and 2010 campaign spending. An attorney could not rationally believe that David Keegan who left in August 2008 could give Melanie Sloan a factual basis for accusations about 2009 and 2010 campaign expenses. During 2008, Christine O'Donnell had a professional accountant, Timothy Koch, an expert in campaign finance, supervising the 2008 campaign. Melanie Sloan should have known that David Keegan would not have loaned Christine's campaign $2,300 in July 2008 if Keegan saw financial irregularities before he left in mid-August 2008. Although Keegan claims he saw spending for meals or shopping in 2008, none of those expenses show up in the campaign's spending in 2008. Sloan should have known that the campaign never actually paid for the expenses that Keegan complains about, and Keegan doesn't know anything about 2009 or 2010."

Jon Moseley also explained: "Melanie Sloan also lied for her clients C.R.E.W. and Delaware voter Leonard Togman accusing Christine of living at 248 Presidential Drive, which Sloan claims was also the campaign headquarters (in paragraph 8 of Sloan's complaint - click here) . However, 248 Presidential Drive is the commercial office of Mid-Atlantic Realty. Nobody lives in Mid-Atlantic Realty's office space. Melanie Sloan obviously did not conduct any investigation into the truth of Sloan's accusations. As an attorney, Sloan knew that Christine's use as the campaign headquarter address as her 'legal residence' does not mean that is where Christine personally lives. If Sloan had investigated before swearing under 18 U.S.C. 1001, she would have known that Christine told the news media at least 18 days before Sloan filed C.R.E.W.'s September 20 complaint that Christine does not actually live at the address she publicly discloses as her 'legal residence.' A 'legal residence' is not a personal residence."

Moseley also commented: "David Keegan's accusations are all the more strange because Keegan was supposed to be raising money for Christine O'Donnell's 2008 U.S. Senate campaign. He complains extensively about the lack of money in the campaign, although Keegan was supposed to go out and raise the money that he complains O'Donnell's campaign lacked."

NO information learned from Christine O"Donnell, her legal team, campaign, or PAC is included, discussed or reflected in Moseley's Complaint or associated documents, except what was publicly and openly disclosed on or before September 20, 2010. To prove guilt by Melanie Sloan, only information that Melanie Sloan either knew or would have known if she had conducted the inquiry required of an attorney is used to establish violations by Sloan. Private information that Melanie Sloan could not have discovered on or before September 20, 2010, would not prove Melanie Sloan's violations of the D.C. Bar's Rules, except to the extent that Melanie Sloan's private interviews with her own witness David Keegan would have alerted Melanie Sloan that Melanie Sloan's claims and statements were then and are now false.

The Complaint against D.C. attorney Melanie Sloan alleges that (a) Sloan made false statements in the course of representing a client in violation of the D.C. Bar's Rule 4.1(a), Rule 3.3(a)(1), Rule 3.3(a)(4) (amplified by Rule 3.9), and Rule 8.4(c), and (b) Melanie Sloan filed frivolous complaints lacking in merit, that is based upon allegations that Melanie Sloan knew to be false in violation of the D.C. Bar's Rule 3.1, Rule 3.3(a)(2), and Rule 8.4(c), and (c) Sloan threatened and sought criminal prosecution to improperly gain advantage in an election, possibly a violation of Rule 8.4(g). Moseley became aware of the violations by Sloan while researching the false accusations against Christine O'Donnell, but ultimately had a professional duty under Virginia's Rule 8.3 to turn over the information to the D.C. Bar.

Jon Moseley was required to file this Complaint by Rule 8.3 of the Virginia Rules of Professional Conduct, which requires attorneys to inform the relevant authority of evidence of likely misconduct. As distasteful as such an 'informant' rule may seem, and perhaps it should be repealed, it is currently the governing authority regulating the legal profession as it now stands.

Jonathon Moseley was the initial Treasurer for Christine O'Donnell's U.S. Senate campaign in Delaware in 2008, and was Christine O'Donnell's campaign manager for her primary in 2008, during which Christine O'Donnell successfully won the Republican nomination for U.S. Senate. O'Donnell and Moseley won the campaign that Moseley ran for O'Donnell in 2008. Moseley developed and wrote a lawsuit for O'Donnell in 2005 and advised Christine O'Donnell's private marketing business as a marketing consultant over several years with regard to writing and reviewing contracts, etc.

Jon Moseley is also serving as Initial Treasurer for a candidate for U.S. Senate in Maryland for the 2012 election and Treasurer for another candidate for U.S. Senate in Pennsylvania for 2012, both of which will soon announce officially.

DUE TO SIZE, the Exhibits attached are broken up into three groups of documents:

First group of Documents:  www.jonmoseley.com/DCBarExhibits1.pdf

Second group of Documents:  www.jonmoseley.com/DCBarExhibits2.pdf

Third group of Documents:  www.jonmoseley.com/DCBarExhibits3.pdf

Melanie Sloan on CBS News, September 17, 2010

Melanie Sloan on on CNN, September 17, 2010

Melanie Sloan on Situation Room with Wolf Blitzer on CNN, September 20, 2010

Melanie Sloan on Anderson Cooper 360 on CNN, September 20, 2010

Melanie Sloan on Anderson Cooper 360 on CNN, September 21, 2010

Melanie Sloan on Rick's List on CNN, September 21, 2010

Melanie Sloan on MSNBC's Ed Schultz program, September 21, 2010

Although sworn before a Notary on June 4, 2011, Jon Moseley's Complaint against Melanie Sloan with the D.C. Bar was not actually filed until June 13, 2011.  The D.C. Bar will most likely take several weeks to review the matter and process it before starting to consider it.  The first step will probably be to forward a copy to Melanie Sloan and ask for her response.  The D.C. Bar will probably not begin to look at the Complaint until receiving Melanie Sloan's response up a month from now.

[stormer]

A product of Princeton and Oxford like Christine O'Donnell shouldn't have any trouble with her veracity. She's a scholar, after all. Oh, wait...

[Moseley]

GONDRING ASKS: "Melanie Sloan for her client Citizens for Responsibility and Ethics in Washington falsely claims that in 2009 Christine O'Donnell was not a candidate for office [...]" Would you please point me to where this claim is made? Thanks!

Click on the links for the TV interviews by Melanie Sloan. She says it many times in her own voice.

[ontap]

Guilty!!!

[kalee]

She sued ISI? For what?

[Gondring]

That’s what Jonathan Moseley does.

He makes frivolous claims and likes to plow a field several times, no matter that is a pile of sand.

But hey, if it’s therapeutic for him....

And maybe he can get a few more checks from contributors' money next campaign season!

[Lancey Howard]

Yikes! Guilty as sin. What a pig.

[Gondring]

It’s Greenville...Greenville Place Apartments.

Sure it’s not Greenville you were thinking of? That’s just down the road from Centerville, I think.

[Gondring]

Thanks...I’ll check them out.

[Labyrinthos]

Now that I understand — Thanks.

[Gondring]

Adn don’t forget how she lied to potential donors to try to get contributions, claiming she’d won 2/3 of counties in Delaware in her previous election—when she was actually trounced soundly in 2/3 and didn’t win any.

[Gondring]

The headquarters was at 1242 Presidential Drive.

However, that is not where Christine ever lived.

She used that address for her voter registration and car registration and to receive her mail. That is a LEGAL RESIDENCE, not her ACTUAL residence. It is a mail drop.

I'm not a lawyer and I don't know details of Delaware, but it seems to me that she's still playing fast and loose with things.

It seems to me that Delaware uses the term "permanent residence" for where voter registration should be. For example, Title 15 § 1704(c)(3) seems to try to confirm this: "Certify that the address at which they are currently registered to vote is their correct address and place of permanent residence." (my emphasis)

So is she falsifying her permanent residence or what?! There seem to be procedures for keeping the voter registration address confidential, so it seems she could have done that legally.

It's amusing to watch the spinning, though.

BTW, I'm all in favor of personal privacy. I just have a problem with her questionable veracity.

[Vendome]

Won’t be getting any from me after what he called my two years ago.

I contributed to Christine’s campaign and hoped she would win, if only to stick it to Mike Castle and his nasty daughter.

I had met them 1997 to get involved in DE Republican and found them pretty acerbic.

[Moseley]

The procedure Christine O’Donnell used is the correct procedure to keep her address confidential.

And, her actual residence is in the same voting precinct.

So she is eligible to vote in that precinct. She resides in the same precinct, but NOT at 1242 Presidential Drive.

And she disclosed this to officials when registering.

[Moseley]

ISI fired CHristine in February 2004 24 minutes after learning that Christine had talked to the Equal Employment Opportunity Commission — which is completely illegal. A company cannot retaliate against an employee for discussing their rights with the EEOC.

Christine O’Donnell’s lawsuit against ISI is posted at:

http://www.supportchristine.com/ODonnellISILawsuitt.pdf

It was discussed extensively at:

http://www.delawarepolitics.net/odonnell-sec-complant-dismissed/

[wideawake]

She sued ISI? For what?

She sued under Equal Employment Opportunity Commission (EEOC) auspices on grounds that she lost her job at ISI because her successor at her job was male and she was therefore fired because she was a woman. She also sued for intentional infliction of emotional distress. She was asking for quite a bit of money as I recall - something like 8 figures.

[wideawake]

This has nothing to do with New York. And these two people lied in a complaint to the FEC which was later tossed out.

Again, it is a legal question of what exactly constitutes candidacy. When the complaint is reviewed, there will be more information.

[DJ MacWoW]

The complaint to the FEC was tossed by the FEC. I think that should be a clue that the complaint had no merit. It remains to be seen if it will be viewed as a lie meant to smear and destroy.

[wideawake]

I'm referring to the complaint to the bar, not the already-dead FEC complaint.

[Moseley]

She sued under Equal Employment Opportunity Commission (EEOC) auspices on grounds that she lost her job at ISI because her successor at her job was male and she was therefore fired because she was a woman

Not correct. Not a bad attempt, but not exactly accurate.

Christine was fired 24 minutes after telling ISI leaders that she had asked the EEOC about her rights as an employee. ISI previously thought she was asking the EEOC about vacation policy. When Christine emailed back that she was asking them NOT about vacation policy but about their disparate treatment, ISI fired her. That is illegal.

BEFORE being let go, Christine asked the EEOC -- and me as well as an attorney at the time -- about ISI having a woman with 15 years experience report to a man just out of college who had no marketing experience other than a little training CHristine herself had given him.

Christine headed a department, but when her male boss went on sabbatical, ISI wanted to make sure that a woman was under the "covering" of a man. So they put a 15 year veteran of marketing under a man who was not qualified for the job.

The Position Description required at least 5 years experience. Doug Schneider had less than 2 years, most of it Christine training him and him packing up books sold for shipment or answering the phones.

So a man who did not meet the qualifications of the position was put into a position he could not qualify for, and a woman with 3 times as much experience as required was ordered to report to a man -- so that no woman would be a leader standing alone. Every woman had to have a man "covering" her in ISI's culture.

After that, the case went to a hearing before the unemployment commission, WHERE CHRISTINE WON, AND ISI LOST. ISI made all the same arguments to the Administrative Law Judge, but lost. So the only hearings that ever happened showed Christine the winner, and ISI's arguments were rejected as not credible.

[DJ MacWoW]

The complaint to the Bar is because of the false FEC complaint.