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:
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.