pene! Home Page Request Submitted = ‘ene ‘yen moran an miele? gyevestger —— SORT ANSS tale tt Phe Bal Se ea ‘pe yeuorsmamar yoy as panes het hi eter roe? erage ty tty ttn ppt rf say “ae “RE Lath ee, oie ct News tol care te asec enone nee Preene tar Paty tn eae Tn Re, at ee ea Nas goo tt oso "Sie tsond ero "hoy ee soy Yous comeing oe ocr? ath cua i ey you a consing eet acar?. pe Tra ee econ Poms an nin "tntanano at snaoye Sie Aso, Aton crane 2 ‘BiB ssteaT Secon tree as tee sere tad ps an 8 te Hy i Seas Tel onan men su of oy rene? inaeouesget wes putas12/15/2020 SUPPORTING DOCUMENTATION FOR GRIEVANCE FILED DEC. 10, 2020 BY KEVIN MORAN VS. TEXAS ATTORNEY GENERAL KEN PAXTON By Kevin Moran 6710 Golf Crest Drive Galveston, TX 77551 713.851.4594 Morankevin67 @gmail.com Documentation follows this statement: 1am a Texas citizen, one of millions Ken Paxton has many, many times stated publicly that he “represents.” Paxton has committed misconduct by filing a frivolous lawsuit asking the Supreme Court of the United States to throw out the votes of 20 million people, Republican and Democrat, in four states, essentially to declare the elections conducted by those states invalid. The case for imposing penalties on Paxton is reallysimple: He knew the lawsuit lacked any legal merit when he filed it. In fact, it was common knowledge across the nation and world that it had no chance of being adjudicated by SCOTUS. Legal experts of far greater standing—constitutional law experts with decades of experience far exceeding Paxton’s knowledge or expertise —said the lawsuit was essentially laughable. Paxton ignored the clear truth and pursued the case anyway. In doing so, he wasted my tax dollars and those of other Texans and expended time and energy of his office staff in filing the case. He wasted the time and resources of SCOTUS. He caused actual mental anguish, grief and great discord across the nation. Knowing that the national election had NOT been rigged or stolen, he acted in a way to stoke those baseless conspiracy theories nationwide. Any non-elected attorney who filed a clearly frivolous lawsuit in Texas or federal courts would face disciplinary action. Ken Paxton should face disciplinary action. YDAll the information below supports the valid claim that his lawsuit, which was based in part of allegations that about 70 judges across the nation had declared false, was frivolous and had no chance whatsoever of any success, Among other information, | submit the Pennsylvania Attorney General's response to Paxton's frivolous, fallacy-ridden lawsuit as ground for Paxton’s discipline and/or sanctions by the State Bar of Texas. ‘Supporting information: Pennsylvania's attorney general on Thursday called Texas's bid to invalidate the election results of Pennsylvania and three other battleground siates a “seditious abuse of the judicial process.” ‘The fiery Supreme Court brief from state Attommey General Josh Shapiro (D), which urged the justices to "send a clear and unmistakable signal that such ‘abuse must never be replicated,” came as battle lines hardened in the unprecedented and long-shot legal dispute. FROM PENNSYLVANIA AG’S RESPONSE TO TEXAS LAWSUIT: “At bottom, Texas seeks to invoke this Court’s original jurisdiction to achieve the extraordinary relief of disenfranchising all Pennsylvanians who voted and one- tenth of the voters in the entire Nation. Such relief would, of course, be “drastic and unprecedented, disenfranchising a huge swath of the electorate.” Donald J. ‘Trump for President, Inc., 2020 WL 7012522, at *7. In support of sucha request, Texas brings to the Court only discredited allegations and conspiracy theories that hhave no basis in fact. And Texas asks this Court to contort its original jurisdiction Jurisprudence in an election where millions of people cast ballots under truly extraordinary circumstances, sometimes risking 32 their very health and safety to do so. Accepting Texas's view would do violence to the Constitution and the Framers’ vision, and would plunge this Court into “one of the most intensely @partisan aspects of American political life.” Rucho v. Common Cause, 139 S. Ct. 2484” Please see Pennsylvania response to Paxton’s lawsuit at link below. Part ofits preliminary ‘statement is below. PLEASE SEE ATTACHED STATEMENT OF LAW PROFESSOR AND U.S. REP. JAMIE RASKIN |ntts://www supremecourt.gov/DocketPDF/22/220185 /163367/20201210142206254 Pennsyl -vania%6200 pp920:0%20Bill¢2007%20Complaint%20v.FINAL of FROM THE NEWS YORK TIMES ~ 12/12/2020 “And it meant that Republican leaders now stand for a new notion: that the final decisions of voters can be challenged without a basis in fact if the results are not to the liking of the losing side, running counter to decades of work by the United States to convince developing nations that peaceful transfers of power are key to any freely elected government's credibility. “From a global perspective this certainly looks like many of the cases ‘we've seen around the world where an incumbent tries to hold onto power,” said Michael Abramowitz, president of Freedom House, a ‘Washington-based group that promotes democracy abroad with @support from both parties. NYT 12/12 PRELIMINARY STATEMENT. Since Histon Day. State and Federal courte throughout the country have been Nooded with five Tou lamas aimed at disntranchising large sate sf vtere and undermining the legitimacy of the ole tion The Stat of Texas has now ada ste ice to the ‘acophony of bogus aims Texas necks to invalidate ‘lection n for wats for yielding results with which {in inagrocs, te requst fr this Cour to exer ite tiene ratcton aa hem met eve prefered ‘andi for Presiden i lgaly defensible and io an Stront to principle feonsttionel democry ‘What Texas doing in this procedingis tant ‘Cour to reconsider n mast of uacess cline about brebleme ath the eleton that hive already heen con: "ered and rete, bythe Court and ether eur I. tempts to exploit this Cure sparingly ned rigioa! Juriedetion to reltigatethowe matters But Tes ab Daly lacks standing toring nach claim, which, many ‘vent, are bared by lachon. and are moat meron, ‘shih our other etates run thet letons Nove tht ‘ew grounded in any rosedent fom thin Gout Tenas ‘aor nat esto nee the Cart intrpret the Conti tion so much a depart ‘The cwoading series of compounding defects in ‘Texas ings i oly underscored by the surreal alter. nate realty that thse filings attempt to constrict. ‘That senate ralty includes an abaurd state @‘Mare Eas, DNC Legal Adviser on Voter Suppression: Part ofthe democratic norms acepting election results. And this was not close election, U.S. Rep. Jamie Raskin (D, MO), law professor and member House Judiciary Committe. He sald the GOP campaign to challenge election inthe courts was “ust al feeder to keep the fundraising going. They/re making tens of milios of dollars a week chasing down the politic! apparatus for this, “But as a matter of ow, after dozens of cases have been rejected in every federal and state court that looked at al of these allegations of fraud, this, by far, the most absurd and non-sensical~and indeed Snctionable—case thats been brought yet. ‘There's no standing onthe part ofa group of states to interfere in another state's election process to try ‘wget the Supreme Court to order the electors to-do something. There's obviously no precedent for ‘that but there's no standing because there's no injury to those states. 1’ totally political question, which means it’s non-justiable, which means ean't go to cour. I's up tw states to decide the manner of appointment of electors through ther leghlatures and through thelr ‘own constitutional systems, I's not up tothe Supreme Cour, I's not up to(Texas andthe other 17, states). ‘They te not asserted any valid constitutional claim. There's no cause of atin. They're not saying what ‘rights of there are being violated In any way. And the rele fortis non-existent violation ofthe rights ‘of these state attorneys generals absolutely outlandish. They're talking abcutdisenfranchisng tens of nilion of people under existing electoral systems decided upon by the state legislatures under their power under Article 2. And, they're disenfranchising them WHY? There's no evidence of fra in any of these states. Allof the claims of fraud have been thrown out in every state snd federal court to look ot 1 So their claims realy a hypothetical cai that by allowing, fr example, mote absentee ballots, or by ‘moving to direct mail-in balloting, there might be fraud at some point. Irs acompletely hypothetical claim, the type thatthe Supreme Court just makes mincerneat out of on 2 regular basi There's nothing there. This is ust a politcal command performance by the Fesident. And i's 3 statement about the absolute degradation of the Republican party that theyalllineup lke lemmings and getn line and walk the plank withthe President. U.S. Supreme Court: “The State of Texas's motion.-is deni for lack of standing unde Article Il ofthe Constitution. Texas has not demonstrated a Judielally cognizable Interest inthe manner in which another State conducts its elections” ®Wisconsin Attorney General response tothe Texas lawsult: “Texas asserts that this Court's intervention is necesary to ensure faith inthe election. Sutitishardto Imagine what could possibly undermine falth In democracy more than this Court permiting one state to enlist the Court its attempt to overturn the election results in other stats.” “This lawsuit was seeking to discard the votes of every voter who voted fr president in Wisconsin as wellas three other stats and, instead, have politicians select the winners of our elections. Thats not how democracy works “Everybody knew that ths sult was going to fall. We've been talking for days now about how thé suit has no merit and that we were certain it was going to come out the way itd. We don't normaly do that in cases but this one was so weak that we were confident ofthe result,” sid Wisconsin AG. Josh eu U.S. Sen. Chris Murphy on Senate flor before decison: “Right now, the most serious attempt io ‘overthrow our democracy in the history of this country is underway. Those who are pushing to make Donald Trum president fora second term, no matter the outcome ofthe election, are engaged in 2 treachery against thelr nation.” Cari Racine, D.C. attomey general: “The Court did the right thing today in resoundingly rejecting what is ‘the biggest threat since the Civil War. And now is the time for leaders to, 2x President Lincoln sid, try tobind these wounds and move our country forward.” Adam Schiff: “What it was is essentially an effort to overturn democracy dressed up in shabby legal clothing.”PERTINENT EXCERPTS FROM TEXAS DISCIPLINARY RULES OF PROFESSIONAL CONDUCT 4. Alawyer’s conduct should conform tothe requirements of the law, both n professional service to ents and inthe lawyer's business and personal ffi. lawyer should use the law's procedures only {or legitimate purposes and not to haratsor intimidate others A lawyer should demonstrate respect {forthe legal system and for those who serve, including judges other lawyers and public officals ‘hile itis a lawyer's duty, when necessary, to challenge the rectitude of offical action, ts also 2 lawyer's duty to uphold legal process. Preamble TEXAS DISCIPLINARY RULES OF PROFESSIONAL ‘conpuct [MY COMMENT: Paxton's clear intent, inthe face of the indisputable facts ofthe election’ results, was “toharass or intimidate others’—milions of others, infact. His lawsuit ld not, s the preamble says it should “demonstrate (Pastors) respect for the legal system, including udges, other lawyers and publle officials” Indeed, some have called the lawsuit “an insult tothe Supreme Court.” TEXAS DISCIPLINARY RULES OF PROFESSIONAL CONDUCT {ADVOCATE Rule 3.01. Meritorious Claims and Contentions A lawyer shall not bringer defend @ proceeding, o assert or controvert an isue therein, unless the lawyer reasonably believes that there [sa basis for doing so that isnot frivolous. [MYCOMMENT: Although tis clear that Paxton, ashe filed the lawsuit, new that ithad no merit and would be correct called “frivolous" or worse —when fled, he nonetheless fled the lawsuit. Then, he failed to withdraw the lawsult when dozens of legal nd constitutional experts across thenation publicly sid thatit was frivolous on is Face ‘TEXAS DISCIPLINARY RULES OF PROFESSIONAL CONDUCT 3.Afling or contention is friolous ft contains knowingly fate statements of fact, ts not frivolous, however, merely because the facts have not been ist substantiated fll or because thelauyer expects to develop vital evidence only by discovery.[MY COMMENT: Paxton DID know tat his lawsuit contained “knowingly false statements.” And the “facts he presented HAD been shown in dazens of prior lawsuits across the nation tobe UN- substantiated, Paxton knew he could not develop vital evidence by discovery because anything he might have requested in discovery had already been subject of discovery in other, fled, rejected lawsuits. He ‘id not file ths lawsutn good faith by any stretch ofthe imagination. 4 Alawyer should conform not only to this Rule's prohibition of frvolousfilngs or assertions but also ‘to any more stringent appicable rule of practice or procedure. For example, the duties imposed on @ lawyer by Rule 11 of the Federal Rules of Civil Procedure exceed those set out inthis Rule. A lawyer ‘must prepare all flings subject to Rule 11 in accordance with ts requirements See Rule 3:04). ‘TEXAS DISCIPLINARY RULES OF PROFESSIONAL CONDUCT Factual Representations by a Lawyer 2. An advocate responsible for pleadings and other documents prepared for tigation, but usually ‘not required to have personal knowledge of matters asserted therein, for itation documents ordinarily present assertions bythe client, oF by someone on the client's behalf, and net asertons by the lawyer. ‘Compare Rule 3.03. However, an assertion purporting tobe onthe lawyer's owm knowledge, a in an affidavit by the lawyer or a representation of fact in open court, may properly be made only when the lawyer knows the assertion Is true or believes I tobe true on the bass of reasonably digent Inquiry. There are circumstances where fallue to make a diclosur's the eculvalent ofan affirmative risrepresentation. The obligation prescribed in Rule 1.02c) not to counsel aclient to commit or assist the client in committing a fraud apples in tigation. See the Comments to Rules 1.02() and 8.04(). Misleading Legal Argument 3 Legal argument based on 2 knowingly false representation of aw constitutes dishonesty toward the tribunal. A lawyer isnot required to makea disinterested exposition ofthe aw, but should recognize the existence of pertinent legal authorities. [MY COMMENT: Paxton ether azcertad “acts foley aftr learning throgha “reasonably digent Inq” that they were indeed fase, Re falda lean those “acts” were ae because he fled to. 2p! conduct“ reasonably dligent inquiry.” Scores of more qualified and more bnowledgeable id make a reasonably dligent inquiry when the sult was fled and declared it tobe fivlous but Paxton refused to withdraw the lawsuit.STATE BAR OF TEXAS Office ofthe Clef Disciplinary Counsel January 8, 2021 Kevin Moran 6710 Golferest Drive Galveston, Texas 77551 Re: 202006564 - Kevin Moran - Warren Kenneth Paxton, Jr. Dear Mr, Moran: ‘The Office of the Chief Disciplinary Counsel of the State Bar of Texas has received and ‘examined your grievance against the above-named lawyer. Lawyers licensed to practice law in ‘Texas are subject to discipline only when their conduct violates the Texas Disciplinary Rules of Professional Conduct, When a grievance is received, this office conducts an initial review to determine whether the alleged conduct would be a violation of the ethics rules. Ifthe conduct ‘does not allege a violation, the grievance is classified as un Inquiry and dismissed witha right to ‘appeal the dismissal. Ifthe conduct alleges a violation, the grievance is clasified as a Complaint and investigated Based on the information you provided and a strict interpretation of the Texas Diseiplinary Rules of Professional Conduct as drafted by the Texas Supreme Court, our examination of your erievance has fed us to conclude that it should be classified as an Inquiry. Therefore, your grievance has been dismissed pursuant to rule 2.10 ofthe Texas Rules of Disciplinary Procedure. If you would like further review of your grievance, you may choose one of the following two ‘options: 1, Amend your grievance and re-file it with additional information that will assist us in etcrmining whether the lawyer violated the disciplinary rules. (Examples of additional information that may be helpful include: correspondence/emails between you and your lawyer, fee agreementcontract with your lawyer, the approximate date your lawyer's conduct occurred, etc.) Ik s not necessary to list the disciplinary rules you believe were violated. You have twenty (20) days from your receipt of tis letter to resfile your amended grievance. oR 2. Appesl this decision to dismiss your grievance to the Board of Disciplinary Appeals. ‘You must submit your appeal directly to the Board of Disciplinary Appeals by using the enclosed form. You have thirty (30) days from your receipt of this letter to appeal this decision, P.O. Box 12487, Austin, TX 78711, (512) 427-1350, (877) 983-835, fax: (512) 427-4167In compliance with the Texas Rules of Disciplinary Procedure, the Office of the Chief Disciplinary Counsel maintains confidentiality throughout the grievance process. Ifyou have any ‘questions ahout the dismissal of your grievance, can be reached at (877) 953.5836, Sincerely, D. Smith Assistant Disciplinary Counsel Das Enclosures: BODA Appeal Form Ce: Mr. Warren Kenneth Paston I,02/03/2021 11:26 aM FAX 4co7ea6112 SPEEDYS PRINTING P0001 ne ‘Sond Results a Sending 18 complete: Asaress 15124274130 T Length ova orale ox THE BOARD of DISCIPLINARY APPEALS, APPOINTED BY THE SUPREME COURT of TEXAS, wi soda (812) 4271578 BODA APPEAL FORM ‘202006564 Kevin Moran - Warren Kennsth Paxton, J. ‘Bor No,= 15645200 Dismiss Date: 0182021, WANT TO APPEAL THE DISMISSAL OF THIS GRIEVANCE TO THE BOARD OF DISCIPLINARY APPEALS ("BODA”). QUIERO APELAR EL DESPIDO DE ESTA QUEJA A [MESA DIRECTIVA DE APELACIONES DISCIPLINARIES ("BODA’). Lili Mire aa aa) Sige Fema) Poe emo ino 30 Dae eo 'BODA is an appelate body and wil independently review your complain. tis nota pat of the ‘State Bar of Texas ofthe Office of Chief Discilinary Ceunse. 600s un én de pao y rensard go manor depend 2 guna Ho e para clo Ba do Abogados de Tes (Sta Barc! Tres "ele Ofe del Conse DiepinaroPrrcba. Return this frm, to BODA win 30 days ofthe date you receive this notice. By returing this form, you ae asking BODA to review te dismissal of you gnevance by the State Bar of Texas, ‘Derve este formula 8 BODA den de cs 80 cls de fac en que rei ete avis, A devchor fst forma std pando @ BODA gue ovis al Cespo de su qua pala Bara de Abogedes Go Taxas (Sate Bor of Toss) Do not send any addtional information te BODA. BODA wil obtain a complete copy of your ‘evance from the Stale Bar of Texas. No oni informseinadena! a BODA, 800A obtonré una apa do au agravio a lo Bara do ABogndes ae Texas (State Ba of Tete \We val notity you in wring when your appeal form is received. Le nticremas por esa cvando 0 roca su formula de pela. ‘Kevin Moran 1 Check hee tyou agro recive tre 8710 Gotleret Drive cerreyondence by ema at is dss: Mirve Galveston, TX 77551 Sau snes ecb coresandenci en et por amo secrsano ovata arcs oratavinT@gmek com “Eales a It youhave a new mang o: emall address, please pet here: Sisucreton 0 mad camtiodeos ‘Tre Boarp oF Discipuinary Apprais secures Suan "Arowien bY Ts Sms Coon Ts ala vay. 204 evn Moran 6710 Gofeest Gaetan, 1 77551 FE: Disposition of Appeal Notice Kevin Moran v Warren Kenneth Paxton 202006564; BOOA Case No. 65162 (on May 25,202, the Board of lspinaryAppeas appointed by the Supreme Court Teas consisere your _2ppeal from the csmisal ofthe above grievance by the Ole ofthe Chef Dispnary Counsel ofthe State Bar of Teas. ‘Aer reviewing the gievance a led with the tate Bar Chet Dcpinary Couns ofc and no ther nermation the Board grants the appeal, nding thatthe prievance alleges a possible Wolation ofthe follong Texas Display Rules af Profesional Conduct Fests 3.08;303, ‘The Board of Dcpinary Appese will now return the cise tothe Office ofthe Chie Dsciinary Counee for irvetigaton anda determination whether theres just cause to Believe that he atorney Fas commited profesional risconduct.The fie ofthe Chef Discpinary Counsel wl nosy both partes ofeach stp ofthe proces, ning, “hig the atorney to respond tothe complaint. For information canceing the handing fhe ease Wom ths point {onward plese contact the rginal Oe ofthe Cit Okclinay Counsel charge of yor ese. Information concerning the dcpinar system, the Texas Dispnary Rules of Profesional Conduct and he Texas fles of Disciplinary Procedure are avaliable t www terasbar.com, The Boar's neal Pocedural ules ae valabe3t bod og Very rly yours, Jenny Hodgkins Eseetive Decor & Genera Counce aan ce: Waren Kenneth Paxton ten tha Cie ecipinaey Cunt St Sr of Teas POBox 13287 ‘usin, 178712, (174271350 (979535535 tol ee YO Boe 1246 Ain TTA. 2105—SIRATIASTE FAXSIRAGTHI30 TRBODAORG