CASE NO.: 12-12816-CA-40
a. Bernardo Roman attempted to convince the Tribe's senior
accountant, Jodi Goldenberg to testify falsely at her deposition,
and when she refused, he fired her on the eve of her deposition.
b. Bernardo Roman and "Pepe" Herrera worked in concert, along
with Tribal "Judge" Pete Osceola, to obtain a false sworn
statement from Tribe member Jimmy Bert, purporting to deny the
existence of loans for legal fees.
When we deposed Bert, however, he readily admitted thetruth and revealed Bernardo Roman and "Pepe" Herrera's
attempt to manufacture his false testimony in the prior sworn
By that time, Herrera had secretly provided the sworn
statement to the RWH
lawyers, who representedhis client's adversaries.
Herrera filed the false statement with the Court requesting
affirmative relief based on the false statement.
Herrera, in concert with Bernardo Roman and RWH, filed
the false statement in support of his phony "withdrawal" of
his client's earlier motion to sanction RWH for filing false
perjury allegations against Lewis Tein.
Herrera withheld the sworn statement from the undersigned
until after his client's deposition, despite having provided it
to RWH, the lawyers for his client's adversary.
c. After Tribe Vice-Chairman Jasper Nelson testified about theexistence of loans to Lewis Tein's clients for their legal fees,
Bernardo Roman and others attempted to remove Nelson from his
elected office in an effort to intimidate him and other Tribal
officials and employees from testifying truthfully in the future.
d. The Tribe, through Bernardo Roman, concealed "smoking gun"documents from discovery in this case. Specifically, they knew
about but failed to produce copies of Lewis Tein's invoices for the
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