This motion incorporates by reference Plaintiff's Mothers' Day Notice of Bad Faith at Docket #__ and the entire motion is set forth in the next three sentence syllogism:
First, it is obvious that the Franconia Defendants had the Troy Watts ethics complaint because of the Certified U.S. Mail receipts and town fax headers.
Second, no self-respecting police chief or municipality would destroy such a series of documents, nor would they fail to forward copies of them to counsel as requested by Attorney Watts.
Third, that means that Chief Montminy's Affidavit was a lie and it means that Attorney Mullen helped him lie in violation of Rule 3.3 Candor toward the tribunal.
Wherefore Defendant and Counsel ought be compelled to Show Cause as to why they are not in Civil and/or Criminal Contempt of Court. I the undersigned litigant am only slightly schooled in the vagaries of Civil and Criminal Contempt but it appears Criminal because it threatens the authority and dignity of the court. See generally State v. Nott, Lebanon District Court No. 2002-301.
Obviously lying to the Court is a contemptible offense and one can be disbarred for facilitating that sort of conduct. See generally In re Young's case, 154 N.H. 359; 913 A.2d 727; 2006 N.H. LEXIS 172, Rehearing denied by Young's Case, 2007 N.H. LEXIS 15 (N.H., Jan. 16, 2007).
In response, he made intentionally false misrepresentations regarding her assault claim, in a letter sent to her new counsel and in an objection made to the trial court.
That’s no different from what apparently happened in the case at bar, unless Attorney Mullen swears that he never saw the Complaint, but even then his clients are liable for contempt because they would have withheld the information from counsel and lied to the Court because they would never destroy documents that important.
Respectfully submitted/CK on behalf of KingCast.net
Note: This Motion
PS: I love the smell of napalm in the morning.... smells like... victory!