Defendants fail to point out what those alleged errors were, and it is patentlyobvious that the issue advances a material issue because the Court is still laboringunder an Order that was harshly and unfairly biased against Plaintiff, written by aJudge who has finally admitted that she had an ethical conflict and who recusedherself, albeit initially through an underhanded manner, only putting her recusal towritten Order at least three (3) weeks after being called on it by Plaintiff.But while Defendants are making vague assertions about errors allegedly madeby Plaintiff, they miss the fact
despite being warned
that Plaintiff never wasdisbarred. Even casual due diligence would uncover that fact so the Statement issued
in Brian Cullen’s email and republished in this Court that Plaintiff was disbarred is also
Sanctionable in and of itself.
ning now to Defendant’s misrepresentations of Plaintiff’s arguments and
case law they erroneously wrote:
That is once again a false Statement that also belies common sense. Plaintiff hasREPEATEDLY stated and argued this point, using case law but rather than face themusic the Defense counsel have joined together in a pleading to outright lie to thisCourt. Specifically Plaintiff wrote in his Motion to Void/Vacate:
Not that disbarment would constitute any sort of barometer on a NH Attorney’sability to practice law. As we all know, Shaheen & Gordon’s Michael McLaughlin was
not only disbarred but is a convicted felon. Note further that Counsel stated thePlaintiff was interjection extraneous matter into this case, nothing is more extraneousthan a lawyer like Brian Cullen trying to threaten Plaintiff with an old suspension (not:disbarment) order from another Court when he has a recent Contempt Order in thisvery Court. See
Bourne v Town of Madison
, 2005-CV-365 at the end of this documentand as Appendix A.