vase cuzsUIuUU! Ie ~~ Yocument 1d Filed U4-2/-2U23 Page 1 of 7 Q FILED 04-27-2023, Clerk of Circuit Court Winnebago County, Wi STATE OF WISCONSIN CIRCUIT COURT WINNEBAGO COUNF3¥:7000116 STATE OF WISCONSIN MOTION FOR RECUSAL OF JUDGE v. Todd Schaffer Case no. 23CT116 ‘Now Comes Defendant, Todd Schaffer, by his attomeys, Goldin & Lennon, LLC and Attomey Matthew L. Goldin of Oshkosh, Wisconsin, and requests that Judge Scott Woldt recuse himself from taking any action in the above case and that another Winnebago County judge be appointed to hear this case. The basis for this request for recusal is attached in Exhibit “A” which is incorporated herein. A judge is required to disqualify himself if the judge determines that for any reason he cannot be impartial. Brown v. O'Connor, 823 N.W.2d 839 (2012). It is settled that a fair trial in a fair tribunal is a basic requirement of due process. Miller v, Carroll, 392 Wis2d 49, 62 (2020). Dated: April 27, 2023 Respectfully submitted, Goldin & Lennon, LLC Attomeys for Defendant Electronically signed by Attorney Matthew L. Goldin State Bar No. 1000654GOLDIN & LENNON, LE es 125 Church Avenue Oshkosh, WI $4901 Telephone (920) 235-9000 Fax (920) 235-9001 Titioraeys at Law Tegal Assistant Matthew L. Goldin Terry Elizabeth Moe William M. Lennon April 26, 2023 Wisconsin Judicial Commission 10 E. Main Street Suite 700 Madison, W1 $3703 RE: Misconduct of Judge Scott Wold. Winnebago County Circuit Court Branch 2. Dear Sir or Madam: Attached please find my request for a formal investigation regarding conduct of Judge Seott Woldt of Winnebago County. Cireuit Court. Branch -2. Ldo not make this fling without much aforethiought, Tivis is the first time | have ever Filed such a complaint regarding a judge in my 32 years of practice. It pains me to make such a complaint. however. itis required under the present circumstances, Please investigate to ensure the proper exercise of judicial power within our wreat state Please do not hesitate to contact me with eny questions. ‘Thank you for your attention to this mater. Very truly yours. AO fon AE at State Bar no. 1000634 Ene.een iy HOU Ure ee raye ours WISCONSIN JUDICIAL COMMISSION 110 East Main Street, Suite 700 REQUEST FOR INVESTIGATION Madison, WI_53703, (608) 266-7637 L. held (please type or print) adie: §— LAS CP pep vee Name: LLG z Phone: Dayline(” ) 23S-Feigy: evening §_ Uf GEE. | have information of possible misconduct or disability on the part of Let Weld t- ofthe Lil Cour in (Game of judge or court commissioner) Ciihesh Wit sebegar wisconsin. ‘com ity) STATEMENT OF FACTS, 1, When and where did this happen? Noch vine 55 BL oy beh ty ; Date(s): WZ6/23 Time-S Hf, Location Ly Ni AVAL eth, be/ 2. If your information arises out of court cas. please answer these questions 8) What is the name and number of the case? Cose name: __Ac de Case no, b) What kind of case is it? CQeriminal, Ol domestic relations, Q small claims, Oi probate, D eivil, D juvenite, O other (specify): —————3 Vase eveoulwuyrto — UULUIEIIL I Pea U4-z/-2Ues Page 4 of 7 ©) What is your relationship to the ease? plaintiftpetitioner i defendanvrespondent attorney for O witness for, # d) Ifyou were represented by an attorney in this matter at the time of the conduct of the judge or court commissioner, please identify the attomey Name Address: Phone: ( €) Identify any other attorney(s) who represented you or any persor Name ofatomey: — _A/fA- Addresses: Phone: ©) Represented: List documents that help support your information that the judge or court commissioner has ‘engaged in misconduct or has a disability, noting which ones you have attached:ermine reed wage 9 ot / 4 a ea ae ae a Name(s): Hitty Ty basparek ‘wieK adirese 7 Xivole tbrly > Gap ep OS se sucnsa hie Ali Legge Phone: Cy pe ee ie.) 5. Specify below the details of what the judge or court commissioner dil that you think continues misconduct or indicates disability. (Please type or print legibly; attach additional paper if roomy.) Bee Antex. LUNDERSTAND THAT STATE LAW PROVIDES THAT THE JUDICIAL COMMISSION'S PROCEEDINGS ON THIS REQUEST FOR INVESTIGATION ARE CONFIDENTIAL AND THAT I MAY REQUEST THE COMMISSION NOT TO DISCLOSE MY IDENTITY TO THE JUDGE OR COURT COMMISSIONER PRIOR TO THE FILING OF A PETITION OR FORMAL COMPLAINT. WITH THE SUPREME COURT, Q 1 REQUEST THE COMMISSION NOT TO DISCLOSE MY IDENTITY TO THE \S19 PHeU Uae sees Page 6 of 7 Ruby Owl Incident with Judge Scott Woldt — April 2, 2023. J attended a Lawyer get-together at Ruby Owl at 5 pm today April 25, 2023. I had one 13. oz beer and mostly spoke with Judge Siefert. On my way out to leave Judge Woldt was sitting at the other end of the bar with Missy Woldt (spouse). He pulled me over and told me I was dead for allowing Haase to put a sign on my Omro property and that there would be ramifications for support of Haase. He said I now needed to advise my clients of this new situation with the Judge, and that from now on there would be consequences as a result of my allowing the Haase sign, The Judge indicated that these consequences were both to me and my ts. He indicated he would take out his anger and fury on myself and my clients. Then he said I could write him a check for $28,000.00 to pay for the contested judicial campaign and then we'd be square. I told him that would be unethical. | told him it wasn’t personal, but I did not like the way Haase was treated after she lost her election, and to me it was important to have a minority on the bench, and in my opinion there were too few black judges and diversity was important to me, I tried to congratulate him and he wasn't accepting. He told me he was the only disabled judge pointing to his leg. I said I guess so, I really was upset about him telling me there would be consequences for my support of Haase and I considered that as a threat, This conversation was overheard by Attomey Ty Gasparek and other Public Defenders who were in attendance at Ruby Owl. The whole time, Missy Woldt sat at the bar stone faced looking forward and did not say anything, She seemed embarrassed and uncomfortable. This was after Missy unftiended me on Facebook, and then I blocked her entirely. Lam shocked Judge Woldt behaved like this. He told me my actions in placing a sign in Omro would have future consequences for myself and my clients. I even told him I did not publicly endorse Haase nor put signs at the office or home, only in Omro, He said I did it so he would see it there, and that was the only reason. He said if I supported Haase I was responsible for all Haases campaign strategy including all the dirty laundry Haase put forward during her campaign, | assured him I had nothing to do with her campaign strategy and hadn't even seen it. He said [ condoned it all because I supported her, He said I’m 61 years old, what am I ‘suppose to do if I lost an election? I told him I did not understand his anger towards me. Ttold him ‘multiple times I did not understand where he was coming from. My biggest concem is when he said that now I needed to advise my clients that by my appearing before him in the future would have consequences for both myself and my clients.4/25/2023. 7:49 PM | was in BR-2 on 4/12/2023 awaiting a case to be called. At the time, the courtroom was full of students for some sort of field trip. In response to a question, what is the worst part of your job? The judge responded that it was campaigning for office and all the mudslinging from his, opponent. The judge was looking right at me and stated, off the record, but in the courtroombehind the bench with his robe on, that anyone who supported his opponent was fully responsible for all of the mudslinging that occurred during the campaign. I indicated to ADA Adam Levin later (before the Ruby Owl incident) that I thought he was directly speaking to me. I asked Judge Woldt if the comment was directed at me in our Ruby Owl conversation on 4/25/23, and he affirmatively stated yes it was. Judge Woldt was on the bench, in robe, and essentially scolding me for being somehow “disloyal.” Throughout the conversation at Ruby Owl, Woldt appeared threatening that he would utilize his judicial power to punish me, my clients, and my practice for some sort of perceived entitlement to loyalty. 1 was disgusted by his statements, and left Ruby Owl, Upon leaving the tavern, that is when Attomey Ty Gasparek was leaving in kis car, he rolled down the passenger side window, and indicated that he had overheard the exchange between Woldt and myself, and that he would confirm the conversation in the event I intended to report this matter to the Wisconsin Judicial Commission for discipline. MLG ‘The above two page statement is truthful and accurate. yo ws — ffir Mp £4 li Ute e CV ii Gotsin EA yy State Bar no. 1000654