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AFFIDAVIT FOR BAR COMPLAINT AGAINST MICHON HUGHES

1. I, Tanya Hathaway, submit this complaint as a sworn affidavit. I

hereby declare under penalty of perjury. I am over the age of 21, am competent to

testify, and have personal knowledge of the matters stated herein. I provide this

affidavit to be used in this and any other legal proceeding. I have much more

evidence to offer. I hope you will ask to see it.

CHARGES

CHARGE #1. MICHON MILLER HUGHES FRAUDULENTLY
NOTARIZED THE PETITION FOR DISSOLUTION OF MARRIAGE IN
CASE #FD-2014-1476.
2. On June 4, 2014, the Petition for Dissolution of Marriage was filed in

Case #FD-2014-1476 in the Tulsa County District Court. [Exhibit 1.] It is a false

sworn pleading. The Petition for Dissolution of Marriage is blank where the

signature line for Daniel Gray of the Miller Hughes Law Firm is provided. There

is an affidavit by Winston Frost stating that he was duly sworn, and he stated under

penalty of perjury that the facts and allegations were true and correct. Winston

Frost committed perjury. He was not sworn, and the facts are false. The affidavit

is notarized by Michon Hughes dated June 3, 2014. It is a fraud. Winston Frost

was traveling by car from Springfield, New Hampshire to Hamburg, New York on

June 3, 2014. Winston Frost was not in the presence of Michon Hughes to be

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sworn, and Michon Hughes did not witness his signature as required by law. His

signature was notarized via email. See Exhibit 2; this is an email from the

Oklahoma Secretary of State indicating that this is a violation.

3. Michon Hughes had the Petition for Dissolution of Marriage filed in

the case and has pursued the case based upon an unsigned Petition. Upon

information and belief, this is because attorneys Michon Hughes and Daniel Gray

knew it was a false sworn pleading. Michon Hughes committed fraud upon the

court.

4. See Motion to Strike dated February 10, 2016. [Exhibit 3.] The

Oklahoma Secretary of State Notary Guide defines the Function of a Notary

Public: “A notary public acts as an official witness to the identity of a person who

comes before the notary.” [emphasis added.] This is required by Oklahoma

Statute Title 49 Section 113. The affidavit to the Petition was signed in New

Hampshire or New York and emailed to Tulsa, Oklahoma where Michon Hughes

fraudulently notarized it, falsely claiming the affidavit was signed before her and

sworn to before her.

5. 12 OK Stat § 12-2011 requires that “Every pleading, written motion,

and other paper shall be signed by at least one attorney of record in the individual

name of the attorney….” This statute also says:

“By presenting to the court, whether by signing, filing, submitting, or later
advocating, a pleading, written motion, or other paper, an attorney or

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unrepresented party is certifying that to the best of the person’s knowledge,
information, and belief, formed after an inquiry reasonable under the
circumstances: 1. It is not being presented for any improper or frivolous
purpose, such as to harass or to cause unnecessary delay or needless increase
in the cost of litigation; 2. The claims, defenses and other legal contentions
therein are warranted by existing law or by a nonfrivolous argument for the
extension, modification, or reversal of existing law or the establishment of
new law; 3. The allegations and other factual contentions have evidentiary
support or, if specifically so identified, are likely to have evidentiary support
after a reasonable opportunity for further investigation or discovery; and 4.
The denials of factual contentions are warranted on the evidence or, if
specifically so identified, are reasonably based on a lack of information or
belief.”

“Frivolous means the action or pleading was knowingly asserted in bad faith
or without any rational argument based in law or facts to support the position
of the litigant or to change existing law.”

6. 12 OK Stat § 12-2011 was violated by Michon Hughes, and her

notary was a fraud.

CHARGE #2. MICHON HUGHES FRAUDULENTLY NOTARIZED
“PETITIONER’S APPLICATION FOR TEMPORARY ORDERS.”
7. On July 11, 2014, Michon Hughes filed “Petitioner’s Application for

Temporary Orders” in Case #FD-2014-1476 in the Tulsa County District Court.

[Exhibit 4.] The Application is supposed to have an Attorney’s Verification. A

so-called Attorney’s Verification is provided, but the notary notarizing the

signature of Michon Hughes is none other than Michon Hughes. A notary may not

notarize her own signature. (Oklahoma Statutes Title 49 Section 6.) The notary

section does not contain the required information, which is required to show the

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name of the notary and the date of expiration of the commission. (Ok Stat Title 49

Section 118.) The notary section does not contain the required seal, which shows

the name of the notary. Compare Exhibit 1 to Exhibit 4, and it is obvious that

Michon Hughes was trying to conceal the fact that she was notarizing her own

document. There is no seal, her name isn’t shown, and the date her commission

expires is not shown. Every other notarization of documents filed by Winston

Frost’s attorney in this case has the seal, the name of the notary, and the date the

commission expires. I can’t help but wonder how many fraudulent verifications

exist involving attorney Michon Hughes in other cases.

CHARGE #3. MICHON HUGHES FRAUDULENTLY NOTARIZED A
“RESPONSE AND OBJECTION TO RESPONDENT’S MULTIPLE
COURT FILINGS AND BRIEF ON JURISDICTION.”
8. On March 4, 2016, a “Response and Objection to Respondent’s

Multiple Court Filings and Brief on Jurisdiction” was filed by Michon Hughes in

Case #FD-2014-1476 in the Tulsa County District Court. The attorney’s

verification is illegal. [Exhibit 5.] Michon Hughes signed the filing, and then

Michon Hughes notarized the verification of her own motion “…that the facts

asserted in the above motion can be supported and evidenced at hearing.” A notary

may not notarize her own signature. Oklahoma Statutes Title 12 § Rule 4(b)

requires motions raising fact issues to be verified by a person having knowledge of

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the facts, if possible; otherwise, a verified statement by counsel of what the proof

will show will suffice until a hearing or stipulation can be provided. Neither was

provided, so the filing violates Rule 4(b). (Oklahoma Statutes Title 49 Section 6.)

See Exhibit 2 - email from the Oklahoma Secretary of State.

CHARGE #5. MICHON HUGHES HAS HAD A CONFLICT OF
INTEREST WHILE REPRESENTING WINSTON FROST IN CASE #FD-
2014-1476 IN THE TULSA COUNTY DISTRICT COURT.
9. Michon Hughes represented both Winston Frost and me in real estate

matters. Then she began representing Winston Frost in the divorce in Case #FD-

2014-1476 in the Tulsa County District Court and subsequently continued to

represent both parties in real estate matters. This conflict was identified by me, but

Michon Hughes ignored it.

CHARGE #6. MICHON HUGHES ARGUED FOR WINSTON FROST
AT A HEARING IN NEW HAMPSHIRE WHILE NOT LICENSED TO
PRACTICE IN NEW HAMPSHIRE.
10. On May 6, 2015, a hearing was held by Judge Bruce Cardello in New

Hampshire Circuit Court in Newport, New Hampshire in Case #652-2015-DV-

00020. Michon Hughes appeared telephonically and argued for Winston Frost.

11. Michon Hughes is not licensed to practice in New Hampshire, and she

was not otherwise authorized to represent Winston Frost in a New Hampshire legal

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proceeding. Michon Hughes committed the unauthorized practice of law in New

Hampshire.

12. Michon Hughes should be disbarred. (State ex rel Oklahoma Bar

Association v. Mothershed, 2003 OK 34 (Okla. 03/18/2003.)

CHARGE #7. MICHON HUGHES REPRESENTED WINSTON FROST
IN CALIFORNIA WHILE NOT LICENSED TO PRACTICE IN
CALIFORNIA.
13. In 2015, a Dr. Phil Show was recorded in California featuring

Winston Frost as he was confronted by his ex-wife, ex-fiance, and his wife (me) as

we all charged him with being a liar and a con man. Michon Hughes appeared on

the program with Winston Frost and advised him on legal issues during the

videotaping. [Exhibit 6.]

14. Michon Hughes is not licensed to practice in California. Michon

Hughes committed the unauthorized practice of law in California.

15. Michon Hughes should be disbarred. (State ex rel Oklahoma Bar

Association v. Mothershed, 2003 OK 34 (Okla. 03/18/2003.)

CHARGE #8. MICHON HUGHES DISCLOSED A CONFIDENTIAL
SETTLEMENT OFFER TO THE COURT IN CASE #FD-2014-1476, AND
SHE GAVE THE COURT ABSOLUTELY FALSE INFORMATION ABOUT
IT. [Exhibit 5.]

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16. In an Objection filed in Case #FD-2014-1476, Michon Hughes

claimed: “Respondent has contacted Petitioner’s counsel via mail, claiming to file

police reports for perjury … if counsel does not pay Respondent fifty thousand

dollars ($50,000.00).” [Exhibit 5, Paragraph 8.] I sent a letter to Michon Hughes

dated February 10, 2016. [Exhibit 7 is a copy of this letter with the dollar amounts

redacted.] It stated in boldface type: “The following is provided confidentially in

the interest of attempting to settle this matter only if done at this time. This

information is not to be used in any litigation. This is offered strictly as a

proposed settlement….” There is absolutely nothing in the letter that discusses

filing police reports or charging Michon Hughes or any other attorney or law firm

with fraud or with fraud if they do not pay me $50,000. Michon Hughes

improperly commented on this to the Court, but that violation of the Rules of

Professional Conduct pales in comparison to the bald-faced lie. Oklahoma Rules

of Evidence 12 OK Stat § 12-2408 (2014) provides: “Compromise Offers and

Negotiations (a) Prohibited Uses. Evidence of the following is not admissible —

on behalf of any party — either to prove or disprove the validity or amount of a

disputed claim or to impeach by a prior inconsistent statement or a contradiction:

(1) furnishing, promising, or offering — or accepting, promising to accept, or

offering to accept — a valuable consideration in compromising or attempting to

compromise the claim.”

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17. In this Objection [Exhibit 5], Michon Hughes also told the Court:

“Respondent has contacted Petitioner’s counsel via mail, claiming to file police

reports for… fraud if counsel does not pay Respondent fifty thousand dollars

($50,000.00).” There is absolutely nothing in the letter or any other mail that

discusses filing police reports or charging Michon Hughes or any other attorney or

law firm with fraud or with fraud if they do not pay me $50,000.

18. In this Objection [Exhibit 5], Michon Hughes also told the Court:

“This type of behavior is unacceptable….” There is nothing unacceptable about

attempting to settle a legal matter.

19. In this Objection [Exhibit 5], Michon Hughes also told the Court:

“This type of behavior… amounts to extortion.” The State of Oklahoma defines

extortion: “Extortion is the obtaining of property from another with his consent,

induced by a wrongful use of force or fear, or under color of official right.” (21 OK

Stat § 21-1481 (2014).) Offering to settle a lawsuit is not extortion. But an

attorney wrongfully charging an adversary with criminal acts in a civil case should

result in discipline by the Oklahoma Bar Association.

CHARGE #9. MICHON HUGHES HAS REPEATEDLY HARASSED
TANYA HATHAWAY.
20. Michon Hughes has repeatedly harassed me.

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21. This violates the Oklahoma Rules of Professional Conduct A

Lawyer’s Responsibilities [5].

22. Perhaps the most egregious harassment was when I fainted in the

hallway of the Tulsa County Courthouse on April 7, 2016 and was being prepared

for transport to the hospital by EMTs. Michon Hughes quickly drafted a subpoena

and had sheriff’s deputies serve it on me to compel my return to the courtroom

from my ambulance stretcher. [Exhibit 8.] She was heard telling people in the

courtroom that I was faking it. But Michon Hughes knew about my medical

issues, and I was faking nothing. The EMTs recorded my blood oxygen level at

10. The Normal level of oxygen in the blood measured with a pulse oximeter is

from 95 to 100 percent. Values under 90 percent are considered low. I was at 10.

I was rushed to the hospital. (See

http://www.mayoclinic.org/symptoms/hypoxemia/basics/definition/SYM-

20050930.)

23. In front of the studio audience at the taping of the Dr. Phil Show,

Michon Hughes said to me: “Why don’t you go take your Vyvanse and Xanax.”

This was harassing and extremely improper.

24. At the taping of the Dr. Phil Show, Michon Hughes said I had

$100,000 in the bank. I said I did not. Michon Hughes said ‘I have copies of

statements.” I did not have $100,000, and she did not have statements showing

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that I did. The Bar Association must ask Michon Hughes to produce the bank

statements that she claims to have. When she doesn’t have such a bank statement,

this lie and harassment will be established.

25. Michon Hughes has accused me of committing multiple crimes. I

have never committed a crime.

26. Michon Hughes told the Court in Case #FD-2014-1476 that I sent her

55 emails on February 5, 2015, and she presented it as harassment that had to be

stopped. She did not tell the truth; the emails were photos of flood damage to

the Marital Residence that I was asked to send to her. She also said that, on

average, I emailed her between four and eight times a day demanding she respond

and give her what I wanted. I emailed Michon Hughes between June 28, 2014 and

May 29, 2015; that’s 335 days. An average of four to eight emails per day would

be 1,340 to 2,680 emails. Exhibit 19 is every email that I have sent Michon

Hughes. These show that I sent her a total of 183 emails between June 28, 2014

and May 29, 2015. The content of the emails shows that I did not make any

improper demands. A bogus protective order [Exhibit 29] was obtained against

me, and I was unable to contact my husband in any manner, so all communications

had to be with his attorney, Michon Hughes. 101 emails addressed repairs to the

Marital Residence. 43 contained photos of water damage for insurance

documentation. 26 were legal emails in regard to filings in the case, etc. 14 were

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settlement/resolution discussion emails. 9 addressed Winston Frost’s mail. 7 were

about the co-mingling of Winston Frost’s assets and mine. Exhibit 20 is every

email that I received from Michon Hughes. These show that she sent me a total of

46 emails between July 9, 2014 and March 23, 2015. The content of the emails

shows that I did not make any improper demands.

CHARGE #10. MICHON HUGHES HAS CLAIMED THAT TANYA
HATHAWAY HAS COMMITTED CRIMES IN AN EFFORT TO OBTAIN
LEVERAGE IN A CIVIL CASE.
27. Michon Hughes has falsely and maliciously claimed that I have

committed crimes in an effort to obtain leverage in the divorce Case #FD-2014-

1476 in Tulsa County Court. Michon Hughes charged me with trespassing, mail

fraud, theft, blackmail, extortion, and other crimes.

28. Michon Hughes charged me with the crime of extortion in a charge in

which she manufactures the claim: “Respondent has contacted Petitioner’s counsel

via mail, claiming to file police reports for perjury … if counsel does not pay

Respondent fifty thousand dollars ($50,000.00).” “Respondent has contacted

Petitioner’s counsel via mail, claiming to file police reports for… fraud if counsel

does not pay Respondent fifty thousand dollars ($50,000.00).” “This type of

behavior is unacceptable….” “This type of behavior… amounts to extortion.”

[Exhibit 5, Paragraph 8.]

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29. I sent a letter to Michon Hughes dated February 10, 2016. [Exhibit 7

is a copy of this letter with the dollar amounts redacted.] It stated in boldface type:

“The following is provided confidentially in the interest of attempting to settle

this matter only if done at this time. This information is not to be used in any

litigation. This is offered strictly as a proposed settlement….” There is

absolutely nothing in the letter that discusses filing police reports or charging

Michon Hughes or any other attorney or law firm with fraud or with fraud if they

do not pay me $50,000. Michon Hughes improperly commented on this to the

Court, but that violation of the Rules of Professional Conduct pales in comparison

to the bald-faced lie. Oklahoma Rules of Evidence 12 OK Stat § 12-2408 (2014)

provides: “Compromise Offers and Negotiations (a) Prohibited Uses. Evidence of

the following is not admissible — on behalf of any party — either to prove or

disprove the validity or amount of a disputed claim or to impeach by a prior

inconsistent statement or a contradiction: (1) furnishing, promising, or offering —

or accepting, promising to accept, or offering to accept — a valuable consideration

in compromising or attempting to compromise the claim.”

30. Michon Hughes filed documents in Case #FD-2014-1476 in Tulsa

County Court in which she stated that I committed federal mail theft. She wrote

“This behavior is… a federal crime. 18 U.S. Code § 1708.” [Exhibit 5 -- Page 6,

Paragraph D.]

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31. 18 U.S.C. 1708 provides:

“Whoever steals, takes, or abstracts, or by fraud or deception obtains, or
attempts so to obtain, from or out of any mail, post office, or station thereof,
letter box, mail receptacle, or any mail route or other authorized depository
for mail matter, or from a letter or mail carrier, any letter, postal card,
package, bag, or mail, or abstracts or removes from any such letter, package,
bag, or mail, any article or thing contained therein, or secretes, embezzles, or
destroys any such letter, postal card, package, bag, or mail, or any article or
thing contained therein; or Whoever steals, takes, or abstracts, or by fraud or
deception obtains any letter, postal card, package, bag, or mail, or any article
or thing contained therein which has been left for collection upon or adjacent
to a collection box or other authorized depository of mail matter; or
Whoever buys, receives, or conceals, or unlawfully has in his possession,
any letter, postal card, package, bag, or mail, or any article or thing
contained therein, which has been so stolen, taken, embezzled, or abstracted,
as herein described, knowing the same to have been stolen, taken,
embezzled, or abstracted— Shall be fined under this title or imprisoned not
more than five years, or both.”

32. Michon Hughes charged me with this federal crime knowing that her

charge was false. Exhibit 23 contains emails between Michon Hughes and me in

which the mail was clearly discussed. I did nothing to violate any law regarding

mail, and Michon Hughes knew it.

33. Michon Hughes falsely accused me in civil Case #FD-2014-1476 of

committing the crime of theft.

34. Michon Hughes falsely accused me in civil Case #FD-2014-1476 of

committing the crime of perjury.

35. Michon Hughes falsely accused me of committing the crime of

trespassing. [Exhibit 24.]

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36. Michon Hughes falsely accused me in civil Case #FD-2014-1476 of

committing the crime of filing false police reports. In Paragraph 20 in the

Statement of Facts to the OBJECTION dated March 4, 2016, she wrote:

“Respondent has also filed… a false police report.” I have never filed a false

police report. My police report was accepted by the Tulsa Police Department.

[Exhibit 5 -- Page 6, Paragraph 8.]

37. Michon Hughes falsely accused me in civil Case #FD-2014-1476 of

committing the crime of extortion. [Exhibit 5 -- Page 3, Paragraph 8.] As

discussed above, I never committed extortion. I did attempt to settle, but that is not

extortion. If it is, most attorneys who has ever litigated a case in Oklahoma have

committed extortion.

38. Michon Hughes falsely accused me in civil Case #FD-2014-1476 of

hacking into or illegally accessing her client’s emails. [Exhibit 5 -- Page 6,

Paragraph D.] I never hacked or illegally accessed her client’s emails, and she

knew it. My husband gave me access to his emails in an unsuccessful effort to

show he was not being unfaithful to me.

CHARGE #11. MICHON HUGHES HAS COMMITTED VIOLATIONS
OF OKLAHOMA CRIMINAL STATUTE TITLE 49 SECTION 5.
39. Michon Hughes has committed violations of Oklahoma criminal

statute Title 49 Section 5:

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“If any notary public shall neglect or refuse to attach to the notary’s official
signature the date of expiration of the notary’s commission, the notary shall
be deemed guilty of a misdemeanor, and upon conviction thereof shall be
fined in any sum not exceeding Fifty Dollars ($50.00).”

40. On July 11, 2014, Michon Hughes filed “Petitioner’s Application for

Temporary Orders” in Case #FD-2014-1476 in the Tulsa County District Court.

[Exhibit 4.] It does not contain the required information, which shows the name of

the notary or the date of expiration of the commission. (Ok Stat Title 49 Section

118.) It does not contain the required seal, which shows the name of the notary.

Compare Exhibit 1 to Exhibit 4, and it is obvious that Michon Hughes was trying

to hide the fact that she was notarizing her own document. There is no seal; her

name isn’t shown; and the date her commission expires is not shown.

CHARGE #12. MICHON HUGHES HAS COMMITTED VIOLATIONS
OF OKLAHOMA CRIMINAL STATUTE TITLE 49 SECTION 6.
41. Michon Hughes has committed violations of Oklahoma criminal

statute Title 49 Section 6 – A:

“Notaries public shall have authority within any county in this state to make
the proof and acknowledgement of deeds and other instruments of writing
required to be proved or acknowledged; to administer oaths; to demand
acceptance or payment of foreign or inland bills of exchange and promissory
notes, and protest the same for nonacceptance or nonpayment, as the same
may require, and to exercise such other powers and duties as by law of
nations and commercial usage may be performed by notaries public. A
notary may not notarize his or her own signature.” [emphasis added.]

42. See paragraphs 7 and 8 above.

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CHARGE #13. MICHON HUGHES HAS COMMITTED VIOLATIONS
OF OKLAHOMA CRIMINAL STATUTE 21-491 – PERJURY.
43. 21-491. PERJURY. (a):

“Whoever, in a trial, hearing, investigation, deposition, certification or
declaration, in which the making or subscribing of a statement is required or
authorized by law, makes or subscribes a statement under oath, affirmation
or other legally binding assertion that the statement is true, when in fact the
witness or declarant does not believe that the statement is true or knows that
it is not true or intends thereby to avoid or obstruct the ascertainment of the
truth, is guilty of perjury. It shall be a defense to the charge of perjury as
defined in this section that the statement is true.”

44. Michon Hughes’ filings in this case have constituted perjury.

45. Michon Hughes has committed multiple felonies in court filings that

she has certified to be true when they were not true.

46. I feel there are too many to list for the purposes of this complaint. If

you choose to investigate, as you most certainly should, I will gladly list each

perjured statement, reference the document or hearing where made, and provide

the proof of perjury.

CHARGE #14. MICHON HUGHES HAS COMMITTED FELONIES IN
VIOLATION OF OKLAHOMA CRIMINAL STATUTE 21-453 --
PREPARING FALSE EVIDENCE.
47. The statute says:

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“a. Any person guilty of falsely preparing any book, paper, record,
instrument in writing, or other matter or thing, with intent to produce it, or
allow it to be produced as genuine upon any trial, proceeding or inquiry
whatever, authorized by law, shall be guilty of a felony.”

48. Michon Hughes prepared false evidence when she notarized the

Petition for Dissolution of Marriage by email and stated under oath that she

administered the oath to Winston Frost in her presence. [Exhibit 1.] She had it

filed in Case #FD-2014-1476 in Tulsa County Court and has pursued the entire

case based upon this false evidence.

49. Michon Hughes has also filed a fraudulent Attorney Lien. [Exhibit 9.]

CHARGE #15. UPON INFORMATION AND BELIEF, MICHON
HUGHES HAS COMMITTED VIOLATIONS OF OKLAHOMA
CRIMINAL STATUTE 21-454 -- Destroying evidence.
50. 21-454. Destroying evidence:

“Every person who knowing that any book, paper, record, instrument in
writing, or other matter or thing, is about to be produced in evidence upon
any trial, proceeding, inquiry or investigation whatever, authorized by law,
willfully destroys the same, with intent thereby to prevent the same from
being produced, is guilty of a misdemeanor.”

51. As documents that are known to have been in the possession of

Winston Frost were never produced by Michon Hughes, I believe she destroyed the

evidence.

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CHARGE #16. MICHON HUGHES HAS COMMITTED A FELONY IN
VIOLATION OF OKLAHOMA CRIMINAL STATUTE 21-463.
52. 21-463. Offering forged or false instruments for record:

“Any person who knowingly procures or offers any false or forged
instrument to be filed, registered, or recorded in any public office within this
state, which instrument, if genuine, might be filed or registered or recorded
under any law of this state or of the United States, shall be guilty of a
felony.”

53. Michon Hughes had the forged Petition for Dissolution of Marriage

filed in Case #FD-2014-1476 in Tulsa County Court.

54. Michon Hughes has filed a fraudulent Attorney Lien. [Exhibit 9.]

55. Michon Hughes has allowed a fraudulent document to be used in Case

#FD-2014-1476 in Tulsa County Court claiming I lived in Tulsa, Oklahoma when

her client sought an order of protection against me. [Exhibit 10.] I live at 160

Philbrick Hill Road in Springfield, New Hampshire 03284, not 160 Philbrick Hill

Road in Tulsa, Oklahoma. [Exhibit 11.]

CHARGE #17. MICHON HUGHES HAS COMMITTED FELONIES IN
VIOLATION OF OKLAHOMA CRIMINAL STATUTE 21-451.
56. 21-451. Offering false evidence:

“Any person who, upon any trial, proceedings, inquiry or investigation
whatever, authorized by law, offers in evidence, as genuine, any book,
paper, document, record, or other instrument in writing, knowing the same to
have been forged, or fraudulently altered, shall be guilty of a felony and
shall be punished in the same manner as the forging or false alteration of
such instrument is made punishable by the provisions of this title.”

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57. Michon Hughes had the forged Petition for Dissolution of Marriage

filed in Case #FD-2014-1476 in Tulsa County Court. [Exhibit 1.]

58. Michon Hughes has filed a fraudulent Attorney Lien. [Exhibit 9.]

CHARGE #18. MICHON HUGHES HAS FILED A FRAUDULENT
ATTORNEY LIEN.
59. Michon Hughes has filed a fraudulent Attorney Lien. [Exhibit 9.]

60. Michon Hughes claimed that Winston Frost did not pay her. But

Winston Frost filed a sworn affidavit stating that he did pay her. [Exhibit 12.]

CHARGE #19. MICHON MILLER HAS COMMITTED MANY
VIOLATIONS OF THE OKLAHOMA RULES OF PROFESSIONAL
CONDUCT (“ORPC”) -- PREAMBLE 5 -- A LAWYER’S
RESPONSIBILITIES.
61. ORPC PREAMBLE 5 -- A Lawyer’s Responsibilities:

“A lawyer’s conduct should conform to the requirements of the law, both in
professional service to clients and in the lawyer’s business and personal
affairs. A lawyer should use the law’s procedures only for legitimate
purposes and not to harass or intimidate others.”

62. Michon Hughes is a disgrace to the legal profession. She has ignored

her Responsibilities. She has used Case #FD-2014-1476 to harass and intimidate

me. She filed the action knowing it was frivolous. She had no legitimate purpose

in filing the action. She filed it in an attempt to help Winston Frost steal my

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money and ownership of 160 Philbrick Hill Road, Springfield, New Hampshire

03284.

63. Michon Hughes used the filings and her actions in Case #FD-2014-

1476 to harass and intimidate me.

CHARGE #20. MICHON HUGHES HAS COMMITTED MANY
VIOLATIONS OF THE OKLAHOMA RULES OF PROFESSIONAL
CONDUCT -- RULE 3.1. MERITORIOUS CLAIMS AND CONTENTIONS.
64. ORPC Rule 3.1. Meritorious Claims and Contentions:

“A lawyer shall not bring or defend a proceeding, or assert or controvert an
issue therein, unless there is a basis in law and fact for doing so that is not
frivolous.”

(Comment 1) “The advocate has a duty to use legal procedure for the fullest
benefit of the client’s cause, but also a duty not to abuse legal procedure.”

(Comment 2) “The filing of an action or defense or similar action taken for a
client is not frivolous merely because the facts have not first been fully
substantiated or because the lawyer expects to develop vital evidence only
by discovery. What is required of lawyers, however, is that they inform
themselves about the facts of the clients’ cases and the applicable law and
determine that they can make good faith arguments in support of their
client’s positions. Such action is not frivolous even though the lawyer
believes that the client’s position ultimately will not prevail. The action is
frivolous, however, if the lawyer is unable either to make a good faith
argument on the merits of the action taken or to support the action taken by a
good faith argument for an extension, modification or reversal of existing
law.”

65. Michon Hughes is a disgrace to the legal profession. She has pursued

a frivolous action to inflict serious damage on my life. The Petition for Dissolution

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of Marriage is frivolous. Michon Hughes was obligated to know the facts about

Winston Frost’s residence and domicile for the period required by Oklahoma

statutes before a petition for dissolution of marriage could be pursued in

Oklahoma. Winston Frost did not meet the requirements, so the Petition was

frivolous from the word Go.

66. Michon Hughes then filed many frivolous responses and motions. I

have not listed each one and provided the evidence, but I am happy to do so if the

Oklahoma Bar Association requests.

CHARGE #21. MICHON HUGHES HAS COMMITTED MANY
VIOLATIONS OF THE OKLAHOMA RULES OF PROFESSIONAL
CONDUCT -- RULE 3.3. CANDOR TOWARD TRIBUNAL.
67. ORPC Rule 3.3 (1). Candor Toward Tribunal:

“A lawyer shall not knowingly: (1) make a false statement of fact or law to a
tribunal or fail to correct a false statement of material fact or law previously
made to the tribunal by the lawyer….”

68. Comment 2 to ORPC Rule 3.3 says: “This Rule sets forth the special

duties of lawyers as officers of the court to avoid conduct that undermines the

integrity of the adjudicative process. A lawyer acting as an advocate in an

adjudicative proceeding has an obligation to present the client’s case with

persuasive force. Performance of that duty while maintaining confidences of the

client, however, is qualified by the advocate’s duty of candor to the tribunal.

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Consequently, although a lawyer in an adversary proceeding is not required to

present an impartial exposition of the law or to vouch for the evidence submitted in

a cause, the lawyer must not allow the tribunal to be misled by false statements of

law or fact or evidence that the lawyer knows to be false.”

69. Michon Hughes repeatedly made false statements of fact and law to

the Court. While she has a duty of candor to the tribunal, Michon Hughes has

demonstrated an inability to tell the truth to the Court or anyone. Michon Hughes

allowed the Court to be misled by false statements of law and fact and evidence

that she knew to be false.

70. ORPC Rule 3.3 (2). Candor Toward Tribunal:

“A lawyer shall not knowingly: (2) fail to disclose to the tribunal legal
authority in the controlling jurisdiction known to the lawyer to be directly
adverse to the position of the client and not disclosed by opposing
counsel….”

71. Comment 4 to ORPC Rule 3.3: Legal argument based on a knowingly

false representation of law constitutes dishonesty toward the tribunal. A lawyer is

not required to make a disinterested exposition of the law, but must recognize the

existence of pertinent legal authorities. Furthermore, as stated in paragraph (a)(2),

an advocate has a duty to disclose directly adverse authority in the controlling

jurisdiction which has not been disclosed by the opposing party. The underlying

concept is that legal argument is a discussion seeking to determine the legal

premises properly applicable to the case.

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72. The Record shows that Michon Hughes made legal arguments based

on a knowingly false representation of law. This constitutes dishonesty toward the

tribunal.

73. ORPC Rule 3.3 (3). Candor Toward Tribunal:

“A lawyer shall not knowingly: (3) offer evidence that the lawyer knows to be
false. If a lawyer, the lawyer’s client, or a witness called by the lawyer, has
offered material evidence and the lawyer comes to know of its falsity, the
lawyer shall take reasonable remedial measures, including, if necessary,
disclosure to the tribunal. A lawyer may refuse to offer evidence that the
lawyer reasonably believes is false.”

74. Michon Hughes repeatedly offered evidence that she knew to be false.

75. ORPC Rule 3.3 (4). Candor Toward Tribunal:

“A lawyer shall not knowingly: (4) fail to disclose a fact to a tribunal when
disclosure is necessary to avoid assisting a criminal or fraudulent act by the
client.”

76. Michon Hughes knows that Winston Frost lied repeatedly in affidavits

and at hearings and trial. She did nothing about it, and she violated ORPC Rule 3.3

(4) hundreds of times.

77. Michon Hughes received MANY sworn affidavits, sworn

motions/responses/replies, and hundreds of documents that caused her to come to

know that evidence she presented was false. She did nothing about it, and she

violated ORPC Rule 3.3 (4) hundreds of times.

78. (Comment 5): Paragraph (a)(3) requires that the lawyer refuse to offer

evidence that the lawyer knows to be false, regardless of the client’s wishes. This

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duty is premised on the lawyer’s obligation as an officer of the court to prevent the

trier of fact from being misled by false evidence.

79. (Comment 6): If a lawyer knows that the client intends to testify

falsely or wants the lawyer to introduce false evidence, the lawyer should seek to

persuade the client that the evidence should not be offered. If the persuasion is

ineffective and the lawyer continues to represent the client, the lawyer must refuse

to offer the false evidence. If only a portion of a witness’s testimony will be false,

the lawyer may call the witness to testify but may not elicit or otherwise permit the

witness to present the testimony that the lawyer knows is false.

80. (Comment 8): The prohibition against offering false evidence only

applies if the lawyer knows that the evidence is false. A lawyer’s reasonable belief

that evidence is false does not preclude its presentation to the trier of fact. A

lawyer’s knowledge that evidence is false, however, can be inferred from the

circumstances. See Rule 1.0(f). Thus, although, ordinarily, a lawyer should resolve

doubts about the veracity of testimony or other evidence in favor of the client, the

lawyer cannot ignore known falsehoods.

81. (Comment 12): Lawyers have a special obligation to protect a

tribunal against criminal or fraudulent conduct that undermines the integrity of the

adjudicative process, such as bribing, intimidating or otherwise unlawfully

communicating with a witness, juror, court official or other participant in the

24
proceeding, unlawfully destroying or concealing documents or other evidence or

failing to disclose information to the tribunal when required by law to do so. Thus,

paragraph (b) requires a lawyer to take reasonable remedial measures, including

disclosure if necessary, whenever the lawyer knows that a person, including the

lawyer’s client, intends to engage, is engaging or has engaged in criminal or

fraudulent conduct related to the proceeding.”

82. Michon Hughes is a disgrace to the legal profession. She has lied and

presented fraudulent documents to the court. She has made factual

misrepresentations. She has made misleading and bogus legal arguments. She has

made legal arguments based on a knowingly false representation of law. Her

actions constitute dishonesty toward the tribunal. She has used false evidence with

the court. I provided undeniable proof of the false evidence, but Michon Hughes has

continued to use it.

83. If you investigate Michon Hughes, as you most certainly should, I will

provide a list of each false statement of fact or law made to the tribunal with

evidence to establish that each was false.

CHARGE #24. MICHON HUGHES HAS COMMITTED MANY
VIOLATIONS OF THE OKLAHOMA RULES OF PROFESSIONAL
CONDUCT -- RULE 3.4. FAIRNESS TO OPPOSING PARTY AND COUNSEL.
84. ORPC RULE 3.4. (a):

25
“A lawyer shall not: unlawfully obstruct another party’s access to evidence or
unlawfully alter, destroy or conceal a document or other material having
potential evidentiary value. A lawyer shall not counsel or assist another
person to do any such act….”

85. ORPC RULE 3.4. (b):

86. “A lawyer shall not: (b) falsify evidence, counsel or assist a witness to

testify falsely, or offer an inducement to a witness that is prohibited by law;

87. ORPC RULE 3.4. (c):

88. “A lawyer shall not: (c) knowingly disobey an obligation under the

rules of a tribunal except for an open refusal based on an assertion that no valid

obligation exists;

89. ORPC RULE 3.4. (d):

90. “A lawyer shall not: (d) in pretrial procedure, make a frivolous

discovery request or fail to make reasonably diligent effort to comply with a

legally proper discovery request by an opposing party;

91. ORPC RULE 3.4. (e):

92. “A lawyer shall not: (e) in trial, allude to any matter that the lawyer

does not reasonably believe is relevant or that will not be supported by admissible

evidence, assert personal knowledge of facts in issue except when testifying as a

witness, or state a personal opinion as to the justness of a cause, the credibility of a

witness, the culpability of a civil litigant or the guilt or innocence of an accused; or

93. (Comment 1): The procedure of the adversary system contemplates

26
that the evidence in a case is to be marshalled competitively by the contending

parties. Fair competition in the adversary system is secured by prohibitions against

destruction or concealment of evidence, improperly influencing witnesses,

obstructive tactics in discovery procedure, and the like.

94. (Comment 2): Documents and other items of evidence are often

essential to establish a claim or defense. Subject to evidentiary privileges, the right

of an opposing party, including the government, to obtain evidence through

discovery or subpoena is an important procedural right. The exercise of that right

can be frustrated if relevant material is altered, concealed or destroyed. Applicable

law in many jurisdictions makes it an offense to destroy material for purpose of

impairing its availability in a pending proceeding or one whose commencement

can be foreseen. Falsifying evidence is also generally a criminal offense.”

95. Michon Hughes has obstructed my access to evidence, and she has

unlawfully altered, destroyed, or concealed documents.

CHARGE #25. MICHON HUGHES HAS COMMITTED MANY
VIOLATIONS OF THE OKLAHOMA RULES OF PROFESSIONAL
CONDUCT -- RULE 3.5. MAINTAINING IMPARTIALITY OF TRIBUNAL.

96. ORPC Rule 3.5. Maintaining Impartiality of Tribunal:

97. “A lawyer shall not: (a) seek to influence a judge, juror, prospective

27
juror or other official by means prohibited by law….”

98. “A lawyer shall not: (b) communicate ex parte with such a person

during the proceeding unless authorized to do so by law or court order….”

99. “A lawyer shall not: (c) communicate with a juror or prospective juror

after discharge of the jury if: (1) the communication is prohibited by law or court

order; (2) the juror has made known to the lawyer a desire not to communicate; or

(3) the communication involves misrepresentation, coercion, duress or

harassment….”

100. “A lawyer shall not: (d) engage in conduct intended to disrupt a

tribunal.”

101. (Comment 2): During a proceeding a lawyer may not communicate ex

parte with persons serving in an official capacity in the proceeding, such as judges,

masters or jurors, unless authorized to do so by law or court order.

102. Michon Hughes has worked with Judge J. Anthony Miller to damage

me. She has communicated on an ex parte basis with Judge J. Anthony Miller and

his staff, including Shana Grandstaff. She communicated on an ex parte basis with

Judge J. Anthony Miller before he was assigned to be the judge in the case.

CHARGE #26. MICHON HUGHES HAS COMMITTED MANY
VIOLATIONS OF THE OKLAHOMA RULES OF PROFESSIONAL
CONDUCT -- RULE 4.1 (a) -- TRUTHFULNESS IN STATEMENTS TO

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OTHERS.
103. ORPC Rule 4.1 (a):

“In the course of representing a client a lawyer shall not knowingly… make
a false statement of material fact or law to a third person….”

104. ORPC Rule 4.1 (b):

“ In the course of representing a client a lawyer shall not knowingly… fail to
disclose a material fact to a third person when disclosure is necessary to
avoid assisting a criminal or fraudulent act by a client, unless disclosure is
prohibited by Rule 1.6.”

105. Michon Hughes has lied repeatedly to the Court and to others. She

has suborned the perjury of her client.

CHARGE #27. MICHON HUGHES HAS COMMITTED MANY
VIOLATIONS OF THE OKLAHOMA RULES OF PROFESSIONAL
CONDUCT -- RULE 4.3. DEALING WITH UNREPRESENTED PERSON.
106. ORPC Rule 4.3. Dealing with Unrepresented Person:

“In dealing on behalf of a client with a person who is not represented by
counsel, a lawyer shall not state or imply that the lawyer is
disinterested. When the lawyer knows or reasonably should know that the
unrepresented person misunderstands the lawyer’s role in the matter, the
lawyer shall make reasonable efforts to correct the misunderstanding. The
lawyer shall not give legal advice to an unrepresented person, other than the
advice to secure counsel, if the lawyer knows or reasonably should know
that the interests of such a person are or have a reasonable possibility of
being in conflict with the interests of the client.

107. (Comment 1): An unrepresented person, particularly one not

experienced in dealing with legal matters, might assume that a lawyer is

29
disinterested in loyalties or is a disinterested authority on the law even when the

lawyer represents a client. In order to avoid a misunderstanding, a lawyer will

typically need to identify the lawyer’s client and, where necessary, explain that the

client has interests opposed to those of the unrepresented person. For

misunderstandings that sometimes arise when a lawyer for an organization deals

with an unrepresented constituent, see Rule 1.13(f).

108. (Comment 2): The Rule distinguishes between situations involving

unrepresented persons whose interests may be adverse to those of the lawyer’s

client and those in which the person’s interests are not in conflict with the client’s.

In the former situation, the possibility that the lawyer will compromise the

unrepresented person’s interests is so great that the Rule prohibits the giving of any

advice, apart from the advice to obtain counsel. Whether a lawyer is giving

impermissible advice may depend on the experience and sophistication of the

unrepresented person, as well as the setting in which the behavior and comments

occur. This Rule does not prohibit a lawyer from negotiating the terms of a

transaction or settling a dispute with an unrepresented person. So long as the

lawyer has explained that the lawyer represents an adverse party and is not

representing the person, the lawyer may inform the person of the terms on which

the lawyer’s client will enter into an agreement or settle a matter, prepare

documents that require the person’s signature and explain the lawyer’s own view

30
of the meaning of the document or the lawyer’s view of the underlying legal

obligations.

109. Michon Hughes represented BOTH Winston Frost and me in legal

matters involving real estate.

CHARGE #28. MICHON HUGHES HAS COMMITTED MANY
VIOLATIONS OF THE OKLAHOMA RULES OF PROFESSIONAL
CONDUCT -- RULE 8.3. REPORTING PROFESSIONAL MISCONDUCT.
110. Rule 8.3. Reporting Professional Misconduct:

“(a) A lawyer who knows that another lawyer has committed a violation of
the Rules of Professional Conduct that raises a substantial question as to that
lawyer’s honesty, trustworthiness or fitness as a lawyer in other respects,
shall inform the appropriate professional authority. (b) A lawyer having
knowledge that a judge has committed a violation of applicable rules of
judicial conduct that raises a substantial question as to the judge’s
fitness for office shall inform the appropriate authority.”

111. Michon Hughes has failed to report professional misconduct of Judge

J. Anthony Miller.

CHARGE #29. MICHON HUGHES HAS COMMITTED MANY
VIOLATIONS OF THE OKLAHOMA RULES OF PROFESSIONAL
CONDUCT -- RULE 8.4. MISCONDUCT.
112. ORPC Rule 8.4. Misconduct:

“It is professional misconduct for a lawyer to: (a) violate or attempt to
violate the Rules of Professional Conduct, knowingly assist or induce
another to do so, or do so through the acts of another;

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It is professional misconduct for a lawyer to: “ORPC Rule 8.4 (b) commit a
criminal act that reflects adversely on the lawyer’s honesty, trustworthiness
or fitness as a lawyer in other respects….”

It is professional misconduct for a lawyer to: “ORPC Rule 8.4 (c) engage in
conduct involving dishonesty, fraud, deceit or misrepresentation….”

It is professional misconduct for a lawyer to: “ORPC Rule 8.4 (d) engage in
conduct that is prejudicial to the administration of justice….”

It is professional misconduct for a lawyer to: “ORPC Rule 8.4 (e) state or
imply an ability to influence improperly a government agency or official or
to achieve results by means that violate the Rules of Professional Conduct or
other law….”

It is professional misconduct for a lawyer to: “ORPC Rule 8.4 (f) knowingly
assist a judge or judicial officer in conduct that is a violation of applicable
rules of judicial conduct or other law.”

113. Michon Hughes has committed ALL of this misconduct.

This Court has found violation of Rule 8.4(d) in instances where an attorney
failed to withdraw from cases after he was suspended for misconduct, where
an attorney paid a client to make a false affidavit to the Bar Association, and
where an attorney counseled his client to lie in court about relevant
information needed by the court. State ex rel. Okla. Bar Ass’n v.
Downing, 863 P.2d 1111 (Okla. 1993); State ex rel. Okla. Bar. Ass’n v.
Moss, 682 P.2d 205 (Okla. 1983); and State ex rel. Okla. Bar. Ass’n v.
Hensley, 661 P.2d 527 (Okla. 1983). [emphasis added.]

CHARGE #30. MICHON HUGHES FILED FALSE STATEMENTS WITH
THE OKLAHOMA BAR ASSOCIATION IN A LETTER DATED
FEBRUARY 19, 2015.
114. Michon Hughes lied in her letter to the Oklahoma Bar Association

dated February 19, 2015. [Exhibit 13.] She wrote: “Ms. Hathaway has been calling

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my client’s employer trying to get him fired for months and has now -- solely due

to the continued harassment of the president of the university -- succeeded in her

goal.”

115. I did not call her client’s employer for months trying to get him fired.

The documentation attached as Exhibit 14 proves that (a) Winston Frost resigned

from his position with Oral Roberts University, and (b) was then terminated

without benefits when he violated policies by appearing on the Dr. Phil Show and

promoting his participation on his Facebook page.

116. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “I have filed several motions with the Court to attempt to enjoin

her from using her blackmailing tactics, my instructions at the hearing in January

from Judge Keeley were to file contempt, as he felt ordering Tanya Hathaway to

cease her activities would be duplicitous as they were already covered by the

Automatic Temporary Injunction.” Exhibit 15 is the transcript of the January 2015

hearing. It shows no such instructions from Judge Keeley. Exhibit 16 is the

Docket in the case. It shows no motions seeking injunctions for blackmailing

tactics.

117. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “Judge Keeley instructed me to file contempt on those issues yet I

have not done so because every time I engage, she files something very long and

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ridiculous in return.” Exhibit 15 is the transcript of the January 2015 hearing. It

shows no such instructions from Judge Keeley.

118. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “My client does not have the money to fight her.” Exhibit 12 is

an affidavit from her client saying he paid her in full. He also recently paid

$12,000 in property taxes in New Hampshire, and he employs a New Hampshire

attorney as well as an Oklahoma attorney. He owns real estate in many states. I

am indigent, so I most certainly have not had the money to fight this.

119. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “Mr. Henry entered an appearance, answered the claim, and did

not object to venue or jurisdiction because Tanya’s claims are without merit on that

issue.” Exhibit 17 is a Motion to Dismiss due to Lack of Subject Matter

Jurisdiction. It has absolute merit.

120. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “Shana Grandstaff, the clerk for Judge Keeley, has also been

battling complaints from Ms. Hathaway to her boss at the courthouse.” I made no

complaints to anyone about Shana Grandstaff. Require that Michon Hughes

produce evidence of this.

121. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “Ms. Hathaway filed a false police report against my client

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claiming perjury which was also designed to harass my client.” I have never filed

a false police report. I have never done anything to harass her client.

122. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “Ms. Hathaway created a website called www.journevingto

justice.com designed to slander and defame my client and his employer in an

attempt to further harass my client.” I have never slandered or defamed her client.

I have never harassed her client. I have, however, filed a defamation lawsuit

against her client. [Exhibit 18.]

123. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “She has one goal: to get my client to give her the house for

which he paid cash prior to marrying her that was at that time worth over

$150,000.” I have never had any such goal. My goal has been to protect my

life savings for my children and myself.

124. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “If he does not meet her demands and deed the house to her,

she will continue to harass him, me, and anyone standing in her way.” I never

made any demand that Winston Frost deed the house to me, and Michon

Hughes will be unable to produce any evidence of her claim to the Oklahoma

Bar Association. I have never harassed Michon Hughes or her client. Please

require that she document all alleged harassment. She will be unable to do so.

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125. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “I may file a police report of my own at this point, and we are

considering filing a protective order for harassment of both my client and even

me.” So, here is yet another criminal claim against me by Michon Hughes. I

have done nothing illegal. I most certainly have done nothing to constitute

harassment. Please require that she document all alleged harassment. She will be

unable to do so.

126. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “On February 5, 2015, Ms. Hathaway emailed me 55 times! She,

on average, emails me between four and eight times a day demanding I respond

and give her what she wants.” She did not tell the truth; the emails were photos

of flood damage to the Marital Residence that I was asked to send to her. She

also said that, on average, I emailed her between four and eight times a day

demanding she respond and give her what I wanted. Exhibit 19 is every email that

I have sent Michon Hughes. These show that I sent her a total of 183 emails

between June 28, 2014 and May 29, 2015. The content of the emails shows that I

did not make any improper demands. 101 addressed repairs to the Marital

Residence. 43 contained photos of water damage for insurance documentation. 26

were legal emails in regard to filings in the case, etc. 14 were settlement/resolution

discussion emails. 9 addressed Winston Frost’s mail. 7 were about the co-

36
mingling of Winston Frost’s assets and mine. Exhibit 20 is every email that I

received from Michon Hughes. These show that she sent me a total of 46 emails

between July 9, 2014 and March 23, 2015. The content of the emails shows that I

did not make any improper demands.

127. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “She apparently has some sort of mental health problems. She

married my client in November 2013, and in her words, “kicked him out of the

house” in March of 2014 when he refused to add her name to the title of the

house.” Please require that she document this claim. She will be unable to do so.

In March 2014, I discovered that Winston Frost was being unfaithful. I confronted

him and asked him to leave. It wasn’t until June 2014 that I discovered my name

was not on the Deed with Winston Frost’s name as I had been assured it would be.

I would not have spent over $175,000 on repairs and renovations if I had not been

told that the Marital Residence would be listed in both of our names.

128. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “She married my client in November 2013… She moved into the

house and began renovating it to tum it into a bed and breakfast.” This is

absolutely false. Please require that she document this claim. She will be unable

to do so.

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129. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “She has filed over l 50 pages of pleadings and motions that

ramble and make ridiculous accusations.” I am pro se, and I suffer from situational

adjustment disorder due to litigation with Michon Hughes and her client. Some of

my pleadings filed without any help have rambled. It certainly wasn’t intentional.

But, I have not made “ridiculous accusations.”

130. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “She bullied Shana Grandstaff into filing those for her by email,

rather than making her follow Tulsa County filing guidelines.” I never bulled

Shana Grandstaff or anyone. Please require that she document this claim. She will

be unable to do so. My filings have been mailed to the court in Oklahoma from

my home in New Hampshire. There have been only a couple of times when a

filing was initially accepted by email with the hard copy to follow by regular mail.

I never bullied anyone to obtain that right.

131. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “She needs to be expressly told that she cannot defame and

slander Dr. Frost in an attempt to coerce property out of him.” I have never

defamed or slandered Winston Frost. I have never attempted to coerce

property out of her client. Please require that she document this claim. She will

be unable to do so. Exhibit 21 contains documentation regarding the ownership of

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the Marital Residence.

132. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “My character and reputation are of the highest importance to

me.” Please require that she document this claim. She will be unable to do so. I

believe Michon Hughes is a pathological liar and a disgrace o the legal profession.

133. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “Feel free to share this with Ms. Hathaway. She needs either

mental health help or to go to jail for her harassment and blackmailing tactics.”

Please require that she document this claim. She will be unable to do so. I have

never harassed, and I have never blackmailed.

134. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “I will personally sue her if she continues to harass me as well.” I

have never harassed Michon Hughes. Please require that she document this claim.

She will be unable to do so.

135. Michon Hughes lied in her letter to the Oklahoma Bar Association

when she wrote: “She admitted to receiving a several hundred thousand dollar

settlement distributed in 2013-2014, so any claims that she is indigent or helpless

or a victim in this matter are unfounded. (See the Transcript of January 5, 2015.)”

Please require that she document this claim. She will be unable to do so. I did

receive several hundred thousand dollars in settlement when I was disabled in an

39
automobile accident. From those funds, I paid expenses and repaid money that

was loaned to me since the accident. Virtually all of the remaining funds were

spent on repairs and renovations to the Marital Residence. I was supposed to be

co-owner, and Winston Frost promised to reimburse me for the $178,442.74 that I

spent. A New Hampshire court has issued a Writ of Attachment giving me a

$178,442.74 lien on the Marital Residence. [Exhibit 22.]

CHARGE #31. MICHON HUGHES HAS FILED FALSE SWORN
PLEADINGS.
136. False sworn pleadings were listed on Exhibit A to the Motion for

Contempt dated February 10, 2016. [Exhibit 25.] I will be happy to provide each

of these for your review.

137. Paragraph D in the Response to Motions on Page 7 of the

OBJECTION is false. “…there are no new facts presented in the current

pleadings that Mr. Henry did not have when he filed Respondent’s initial

response pleadings.”

138. Michon Hughes has no idea what Shane Henry had when he filed my

initial response pleadings. There are many facts presented in subsequent pleadings

that Shane Henry did not present.

139. Paragraph 14 in the Statement of Facts to the SECOND

OBJECTION is false: “Petitioner is concerned that such is the strategy of

40
Respondent in addition to the continued threats of sanctions, bar complaints,

and criminal charges against the attorney. Such threatening personal attacks

are an improper abuse of the judicial system.” [Exhibit 26.]

140. I have never attempted to delay matters. My filings have nothing to

do with delay. My filings are made solely for the purpose of defending myself

against a pathological liar and several of what I believe are attorneys acting in a

most unethical manner. I have not threatened sanctions; I have filed motions

seeking sanctions with undisputable evidence attached. [Exhibit 27.] She hasn’t

threatened bar complaints; she has filed one, and this is her second complaint

against Michon Hughes. She hasn’t threatened criminal charges against Michon

Hughes; she has filed with the Court a motion asking the Court to find her guilty of

a crime involving her fraudulent notary. Tanya Hathaway has subsequently

identified more notary fraud by Michon Hughes, and she will be asking the Court

to recommend criminal charges against her for all of this as well as an

investigation into how many other clients have been the recipients of fraudulent

notaries. Tanya Hathaway is concerned for others who have been victimized by

fraudulent notaries.

141. Paragraph 15 in the Statement of Facts to the SECOND

OBJECTION is false: “Petitioner would further state that Respondent has

never alleged to suffer from “panic attacks” until now. She has had various

41
excuses for showing up late to the April 6, 2015, court date, none of which

alleged panic attacks. In fact, Respondent originally lied to her previous

counsel stating that she wasn’t even present in Tulsa on April 6, 2015.

Respondent did not call the Court to let them know she would be late.”

142. I had attempted to communicate my medical condition to the Court.

Winston Frost is well aware that I have panic attacks. I have had only one excuse

for showing up late to the April 6, 2015 hearing; I was suffering from severe

anxiety, panic, and untreated ADD. This was communicated to attorney W. Allen

Vaughn, but he apparently didn’t read the information or consult with me or my

sister. I never lied. My sister called the Court and left a voice mail explaining that

I had health problems. I saw Judge Keeley at the courthouse on April 6, 2015 and

spoke with him.

143. Paragraph F in the Response to Motions on Page 6 of the

SECOND OBJECTION is false: “Motion for Accommodations for Disabilities

and to Reschedule Hearing and Trial Dates: Respondent’s ‘disability’ has not

inhibited Respondent from drafting and filing multiple sham pleadings.”

144. I have never filed a “sham pleading.” “Sham” is defined as

“something false or empty that is purported to be genuine.” My motions are

genuine, and every sworn statement of fact is true. Michon Hughes never provides

any facts or evidence to back up her outlandish statements.

42
145. On April 1, 2016, Michon Hughes filed “Petitioner’s Third Combined

Response and Objection to Respondent’s Multiple Court Filings” (“THIRD

OBJECTION”) is a false sworn pleading. There are hundreds of false statements

in this THIRD OBJECTION, and Michon Hughes knew the statements were false

and/or had a duty to determine whether they were true or false before filing and

failed to do so. The false statements in the THIRD OBJECTION were made

willfully, were done in bad faith, and are oppressive.

146. Paragraph 7 in the Statement of Facts to the THIRD

OBJECTION is false: “Many of the filings contain inadmissible…illegally

obtained documents.” [Exhibit 28.]

147. There is nothing illegal about obtaining evidence that you were given

permission to obtain. There is no such thing as inadmissible evidence in a motion.

148. Paragraph 15 in the Statement of Facts to the THIRD

OBJECTION is false: “Petitioner would further state that Respondent has

never alleged to suffer from “panic attacks” until now. She has had various

excuses for showing up late to the April 6, 2015, court date, none of which

alleged panic attacks. In fact, Respondent originally lied to her previous

counsel stating that she wasn’t even present in Tulsa on April 6, 2015.

Respondent did not call the Court to let them know she would be late.”

43
149. I have attempted to communicate my medical condition to the Court.

Winston Frost is well aware that I have panic attacks. I have had only one excuse

for showing up late to the April 6, 2015 hearing; I was suffering from severe

anxiety, panic, and untreated ADD. This was communicated to attorney W. Allen

Vaughn, but he apparently didn’t read the information or consult with me or my

sister. I never lied. My sister called the Court and left a voice mail explaining that

I had health problems. I saw Judge Keeley at the courthouse on April 6, 2015 and

spoke with him.

CHARGE #33. MICHON HUGHES HAS MADE NUMEROUS FALSE
REPRESENTATIONS TO THE COURT IN CASE #FD-2014-1476 IN
TULSA COUNTY COURT.
150. Michon Hughes has made literally hundreds of false representations to

the Court in Case #FD-2014-1476.

151. I have not taken the hundreds of pages to list all of the false

representations, but there are hundreds. If an investigation is launched, as it should

be, I will list each false statement and provide the evidence that proves each

statement was false.

State ex rel. Okla. Bar Ass’n v. Gassaway, 2008 OK 60, 196 P.3d 495
(Attorney disbarred for misconduct including false representations to
judges); State ex rel. Okla. Bar Ass’n v. Johnston, 1993 OK 91, 863 P.2d
1136 (Attorney suspended for four months for conduct including false
statements to the court); State ex rel. Okla. Bar Ass’n v. Askins, 1993 OK
78, 882 P.2d 1054 (Attorney suspended for two years for preparing and

44
filing false documents); State ex rel. Okla. Bar Ass’n v. Herlihy, 1991 OK
123, 827 P.2d 164 (Attorney disbarred for conversion of client funds and
misrepresentation to the trial court); State ex rel. Okla. Bar Ass’n v.
Stubblefield, 1988 OK 141, 766 P.2d 979 (Attorney suspended for 30 days
for intentionally misrepresenting facts to the court); State ex rel. Okla.
Bar Ass'n v. Moore, 1987 OK 21, 741 P.2d 445 (Attorney disbarred for
forging checks and falsifying official documents); State ex rel. Okla. Bar
Ass’n v. Moss, 1983 OK 104, 682 P.2d 205 (Attorney disbarred for
knowingly submitting false affidavit in an attempt to avoid discipline); State
ex rel. Oklahoma Bar Ass’n v. Hensley, 1983 OK 32, 661 P.2d 527
(Attorney disbarred for affirmative misrepresentation of facts to the
trial court)…. (State v. Wintory, 350 P.3d 131, 2015 OK 25 (Okla.
04/28/2015).)

“In the 1891 case of People ex rel. Atty. Gen. v. Beattie, 137 Ill. 553, 27
N.E. 1096, the Supreme Court of Illinois disbarred a Chicago attorney who
knowingly drew a false complaint for divorce, introduced false testimony as
to plaintiff meeting residence requirements, etc., and prepared and delivered
to his client a supposed decree of divorce upon the basis of which she
remarried before a decree had in fact been entered. See also the 1958 case of
In re King, 7 Utah 2d 258, 322 P.2d 1095. In the case of People ex rel.
Chicago Bar Ass'n, v. Martin, 288 Ill. 615, 124 N.E. 340, 14 A.L.R. 854, an
attorney was disbarred for having knowingly made a false affidavit
concerning his client’s defense. See also In re Taylor, 300 Ky. 448, 189
S.W.2d 403, where the court said an attorney was “guilty of deceit and
assisting to perpetrate a fraud upon the court” by having sat by while his
purported wife sought to prove and dissolve a marriage, which the lawyer
later denied ever existed, etc., etc. See also the case of In re Wright, 69
Nev. 259, 248 P.2d 1080, 1083, wherein the court stated: “It is clear that
subornation of perjury, tampering with witnesses or otherwise practicing
deception upon a court by fraudulent devices is gross misconduct in the
perverting or obstructing of justice and warrants disbarment.” … For the
foregoing reasons, it is determined that the recommendation of the
Oklahoma Bar Association that respondent, William Howard (Pat) O'Bryan,
be disbarred from the practice of law in Oklahoma and his name stricken
from the roll of attorneys of this state be and the same is approved and he is
hereby disbarred and his name ordered so stricken.” (State ex rel Oklahoma
Bar Association v. O'Bryan, 385 P.2d 876, 1963 OK 151 (Okla.
06/18/1963).)

45
“Not only does the proven execution of a false affidavit constitute fraud, it
destroys all probative value of the verification. In re Initiative Petition No.
347, State Question No. 639, 1991 OK 55, ¶48, 813 P.2d 1019.” (In re
Initiative Petition No. 379, 155 P.3d 32, 2006 OK 89 (Okla. 12/12/2006).)

State ex rel. Okla. Bar Ass'n v. Dobbs, 2004 OK 46, 94 P.3d 31 (attorney
who knowingly filed a false affidavit, falsely notarized another affidavit, and
repeatedly lied under oath suspended for two years and one day).

“We can readily envision legal matters so complex and ethical dilemmas so
profound that a client could follow an attorney’s advice, do wrong and still
maintain suit on the basis of not being equally at fault. But perjury is not
complex; and telling the truth poses no dilemma. Even against the backdrop
of a moral relativism that passes for intellectual sophistication in
contemporary America, perjury is wrong. More pointedly, it is a crime.
M.C.L. §750.422; M.S.A. §28.664. A law degree does not add to one’s
awareness that perjury is immoral and illegal, any more than an accounting
degree adds to one’s awareness that tax fraud is immoral and illegal. Id. at
776. This principle of law finds support in other states. In General Car &
Truck Leasing System, Inc. v. Lane & Waterman, 557 N.W. 2d 274 (Iowa
1996), the client signed and submitted a false affidavit, on advice of
counsel, to the Patent and Trademark Office to obtain federal registration of
a service mark. The court found the client and lawyer in pari delicto, even
though the lawyer may have given negligent advice regarding the scope of
the registration. The potentially negligent advice did not change the
deceptive nature of the affidavit. In Blain v. The Doctor’s Co., 222 Cal.
ApP.3d 1048, 272 Cal. Rptr. 250, 261 (1990), the California Court of
Appeals dismissed a physician’s lawsuit against his former lawyer for
advising the doctor to lie at his deposition in a previous malpractice action.
It stated, “Lay persons may be confused about the legality of sham
transactions employed to frustrate creditors. But there is little plausibility
in the claim that one was confused about the legality of lying in the teeth
of the oath just sworn.” Id. at 1062, 258. Also, see Feld & Sons, Inc. v.
Pechner, Dorfman, Wolfee, Rounick & Cabot, 312 P.Super. 125, 458 A.2d
545, 552 (1983) in which the client’s malpractice claim was dismissed. The
lawyers had advised the clients to commit perjury, falsify exhibits and offer
a potential witness a bribe. They were in pari delicto.” (Tillman v. Shofner,
90 P.3d 582, 2004 OK CIV APP 40 (03/25/2004).) [emphasis added.]

46
CHARGE #34. MICHON HUGHES KNOWINGLY FILED A FALSE
COMPLAINT FOR DIVORCE IN CASE #FD-2014-1476 IN TULSA
COUNTY COURT WITH AN UNSIGNED PETITION, A FRAUDULENT
NOTARY, AND WITH FALSE CLAIMS AS TO THE RESIDENCY
REQUIREMENTS.
152. Michon Hughes knowingly filed a false petition for dissolution of

marriage in Case #FD-2014-1476. [Exhibit 1.]

153. Michon Hughes filed an unsigned petition with a fraudulent notary

with the absolutely false claim that her client met the Oklahoma residency

requirements.

154. Based upon Oklahoma cases and cases from other states where

attorneys who knowingly drew a false complaint for divorce and introduced false

testimony as to plaintiff meeting residence requirements were disbarred. Michon

Hughes added a fraudulent notary done via email, and she must be disbarred.

“In the 1891 case of People ex rel. Atty. Gen. v. Beattie, 137 Ill. 553, 27
N.E. 1096, the Supreme Court of Illinois disbarred a Chicago attorney who
knowingly drew a false complaint for divorce, introduced false testimony as
to plaintiff meeting residence requirements, etc., and prepared and delivered
to his client a supposed decree of divorce upon the basis of which she
remarried before a decree had in fact been entered. See also the 1958 case of
In re King, 7 Utah 2d 258, 322 P.2d 1095. In the case of People ex rel.
Chicago Bar Ass’n, v. Martin, 288 Ill. 615, 124 N.E. 340, 14 A.L.R. 854, an
attorney was disbarred for having knowingly made a false affidavit
concerning his client’s defense. See also In re Taylor, 300 Ky. 448, 189
S.W.2d 403, where the court said an attorney was “guilty of deceit and
assisting to perpetrate a fraud upon the court” by having sat by while his
purported wife sought to prove and dissolve a marriage, which the lawyer

47
later denied ever existed, etc., etc. See also the case of In re Wright, 69
Nev. 259, 248 P.2d 1080, 1083, wherein the court stated: ‘It is clear that
subornation of perjury, tampering with witnesses or otherwise practicing
deception upon a court by fraudulent devices is gross misconduct in the
perverting or obstructing of justice and warrants disbarment.’ … For the
foregoing reasons, it is determined that the recommendation of the
Oklahoma Bar Association that respondent, William Howard (Pat) O'Bryan,
be disbarred from the practice of law in Oklahoma and his name stricken
from the roll of attorneys of this state be and the same is approved and he is
hereby disbarred and his name ordered so stricken.” (State ex rel Oklahoma
Bar Association v. O'Bryan, 385 P.2d 876, 1963 OK 151 (Okla.
06/18/1963).)

“Not only does the proven execution of a false affidavit constitute fraud, it
destroys all probative value of the verification. In re Initiative Petition No.
347, State Question No. 639, 1991 OK 55, ¶48, 813 P.2d 1019.” (In re
Initiative Petition No. 379, 155 P.3d 32, 2006 OK 89 (Okla. 12/12/2006).)

See also State ex rel. Okla. Bar Ass’n v. Dobbs, 2004 OK 46, 94 P.3d 31
(attorney who knowingly filed a false affidavit, falsely notarized another
affidavit, and repeatedly lied under oath suspended for two years and one
day).

FURTHER SAITH AFFIANT NOT.

I declare under penalty of perjury that the foregoing is true and correct.

Executed this 3rd day of October 2016.

_________________________
Tanya Hathaway

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VERIFICATION

Personally appeared before me, the undersigned Notary Public duly

authorized to administer oaths, Tanya Hathaway, who after being duly sworn

deposes and states that she is authorized to make this verification on behalf of

herself and that the facts alleged in the foregoing are true and correct based upon

her personal knowledge.

I am of lawful age. I have read the foregoing and understand each of its

allegations. I declare under penalty of perjury that the foregoing is true and correct

based upon my personal knowledge.

This 3rd day of October 2016,

___________________________
Tanya Hathaway

Signed and sworn to before me this 3rd day of
October 2016 by Tanya Hathaway,

____________________________
Notary Public

My commission expires: _______________

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