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Accuser of Christine O'Donnell LIED, charges Complaint to D.C. Bar seeking Disbarrment
The FREEDOMIST ^ | June 13, 2011 | Paul Collier

Posted on 06/14/2011 7:09:20 AM PDT by 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:





















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.


TOPICS: News/Current Events; Politics/Elections; US: Delaware
KEYWORDS: braking; campaignfinance; christineodonnell; complaint; crew; fec
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1 posted on 06/14/2011 7:09:34 AM PDT by Moseley
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To: Moseley
Like O'Donnell's suit against the Intercollegiate Studies Institute, I am sure this will be a highly successful slam dunk.
2 posted on 06/14/2011 7:20:36 AM PDT by wideawake
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To: Moseley

Please summarize in three sentences.


3 posted on 06/14/2011 7:21:44 AM PDT by Labyrinthos
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To: Moseley

Hope she burns for this.

But she is a liberal so will probably get a pat on the back and a complimentary “Good going, girl!”


4 posted on 06/14/2011 7:22:52 AM PDT by Iron Munro (Know your enemy and know yourself and you can fight a hundred battles without disaster - Sun Tzu)
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To: Labyrinthos

Melanie Sloan lied about Christine O’Donnell in order to influence the election, but did so in official legal complaints seeking government action. Melanie Sloan knew she was lying or would have known with the slightest investigation (which an attorney is required to undertake). Melanie Sloan’s lies violated the requirements of the D.C. Bar.


5 posted on 06/14/2011 7:24:56 AM PDT by Moseley (http://www.SupportChristine.com)
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To: Moseley

Christine will lose this suit. I can’t imagine a judge saying, “yes they were mean to you so let’s take away their ability to practice law.” I could be wrong, but this suit is just going to cost Christine money.


6 posted on 06/14/2011 7:25:06 AM PDT by napscoordinator
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To: napscoordinator

Easy come easy go.

Beats actually working for a living. ;)


7 posted on 06/14/2011 7:26:33 AM PDT by allmendream (Tea Party did not send the GOP to D.C. to negotiate the terms of our surrender to socialism.)
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To: Moseley

Still nothing will happen because it was during a campaign. Now had Christine not put herself in the election and she said something slanderous than Christine would have a suit. This is going to nowhere. MAYBE the best that will come out of this is the next time Christine runs for office, her detractors might think twice about saying negative things about her.


8 posted on 06/14/2011 7:27:07 AM PDT by napscoordinator
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To: Moseley

Thanks. It’s about time somebody turns the table on lying Rats by using the truth. I hope this is successful and they don’t get away with it this time.


9 posted on 06/14/2011 7:28:26 AM PDT by DJ MacWoW (America! The wolves are at your door! How will you answer the knock?)
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To: allmendream
Beats actually working for a living. ;)

That, my good man, is the point of this exercise.

10 posted on 06/14/2011 7:30:42 AM PDT by wideawake
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To: napscoordinator; Moseley

naps they didn’t say negative things. They lied. In a legal complaint.


11 posted on 06/14/2011 7:30:55 AM PDT by DJ MacWoW (America! The wolves are at your door! How will you answer the knock?)
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To: napscoordinator
Christine will lose this suit.

This isn't O'Donnells suit. It was filed by Jonathan Moseley.

12 posted on 06/14/2011 7:34:23 AM PDT by DJ MacWoW (America! The wolves are at your door! How will you answer the knock?)
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To: Labyrinthos
Actions have consequences.

Some bad, some good.

We will see.

13 posted on 06/14/2011 7:34:58 AM PDT by jamaksin
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To: DJ MacWoW; Mosely

Thanks for clearing that up.


14 posted on 06/14/2011 7:35:14 AM PDT by napscoordinator
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To: Moseley

Melanie Sloan is emblematic of all the deceit and malice that characterizes the left in one, tidy package. It sounds as if Moseley has done his homework which will hopefully result in at least partially defanging this political tool.

Having said that, I’m not holding my breath.


15 posted on 06/14/2011 7:38:45 AM PDT by bereanway
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To: DJ MacWoW; napscoordinator
It seems to hinge on the technical question of whether O'Donnell was legally a candidate or not at the time in question.

There may be DE case law on this question or they may not - but in New York it is a not a matter of whether you say you are a candidate but whether you have sufficient number of petitions to establish candidacy.

I highly doubt that "purchasing campaign software" or "testing the waters" has any legal value whatever.

Think about it: I could declare myself a candidate every year, declare all kinds of expenses (travel, meals etc.) and never get a single signature or mount a real campaign. Legally there needs to be a minimum standard. Simply filing may not meet it.

16 posted on 06/14/2011 7:40:10 AM PDT by wideawake
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To: Moseley

Poetc. I am so glad to see her go down in flames. It’s taken a long time though. My former Congressman, Curt Weldon, was targeted by CREW. Somewhere, Curt is smiling today if he reads this.


17 posted on 06/14/2011 7:45:56 AM PDT by SueRae (I can see November 2012 from my HOUSE!!!!!!!!)
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To: Moseley

Poetic. I am so glad to see her go down in flames. It’s taken a long time though. My former Congressman, Curt Weldon, was targeted by CREW. Somewhere, Curt is smiling today if he reads this.


18 posted on 06/14/2011 7:46:04 AM PDT by SueRae (I can see November 2012 from my HOUSE!!!!!!!!)
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To: napscoordinator

You’re welcome.


19 posted on 06/14/2011 7:47:38 AM PDT by DJ MacWoW (America! The wolves are at your door! How will you answer the knock?)
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To: wideawake; napscoordinator

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


20 posted on 06/14/2011 7:48:55 AM PDT by DJ MacWoW (America! The wolves are at your door! How will you answer the knock?)
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