BAR COMPLAINT Against MELANIE SLOAN
re: frivolous charges against
Spreading Lies of David Keegan
Please note that Jon Moseley has concluded his work for Christine O'Donnell and is not currently employed by Christine O'Donnell nor affiliated with her PAC or campaign, and does not speak for Christine O'Donnell. Christine O'Donnell may not be held responsible for anything said or done by Jonathon Moseley.
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Fairfax, Virginia, June 4, 2011: BREAKING NEWS:
WHY was the complaint against Christine O'Donnell dismissed? Audio clips from a news interview with David Keegan, Christine O'Donnell's chief accuser, revealed that the accusations were nothing more than speculation. (Click here.) Keegan was only guessing. Keegan wanted an investigation. But he did not actually have any evidence or information of any wrong-doing by Christine O'Donnell.
On June 4, 2011, Jonathon Moseley exposed false charges brought against 2010 Delaware U.S. Senate candidate Christine O'Donnell by D.C. lawyer Melanie Sloan of C.R.E.W. Moseley filed a complaint against Sloan with the District of Columbia "Bar" asking that Melanie Sloan be disciplined or disbarred.
Jon Moseley was required to file this Complaint by Rule 8.3 of the Virginia Rules of Professional Conduct, which requires attorneys to inform the relevant authority of evidence of likely misconduct. As distasteful as such an 'informant' rule may seem, and perhaps it should be repealed, it is currently the governing authority regulating the legal profession as it now stands.
This Bar Complaint was not requested by Christine O'Donnell's lawyers, and indeed Christine's lawyers did not want to take positive action. Jonathon Moseley accomlished this victory over the left entirely on his own.
The June 4, 2011, Complaint against Melanie Sloan of C.R.E.W. alleges that when falsely accusing Christine O'Donnell of using campaign funds for personal use (a) Sloan made false statements in the course of representing a client in violation of the D.C. Bar's Rule 4.1(a), Rule 3.3(a)(1), Rule 3.3(a)(4) (amplified by Rule 3.9), and Rule 8.4(c), and (b) Sloan filed frivolous complaints lacking in merit, that is based upon allegations that Melanie Sloan knew to be false in violation of the D.C. Bar's Rule 3.1, Rule 3.3(a)(2), and Rule 8.4(c), and (c) Sloan threatened and sought criminal prosecution to improperly gain advantage in an election, possibly a violation of Rule 8.4(g). Moseley became aware of the violations by Sloan while researching the false accusations against Christine O'Donnell, but ultimately had a professional duty under Virginia's Rule 8.3 to turn over the information to the D.C. Bar.
On July 17, 2011, Jon Moseley added the following explanation: "The reason I got involved in responding to these accusations was when I discovered in August and September 2010 that my resignation as Treasurer was being used to suggest that somehow I was aware of something wrong with Christine O’Donnell’s campaign or Christine O’Donnell’s use of campaign funds. I was – in effect – being mis-used as an involuntary ‘witness’ against Christine O’Donnell by my own resignation being misrepresented. It took me a while to figure this out, because my name was not used, but by description Christine O’Donnell was criticized for one Treasurer (male) resigning after only 5 weeks. Only by mapping out the FEC records did it become clear that critics of my friend Christine were referring to me and falsely attempting to draft me into service as an unwilling ‘witness’ against Christine. I knew that implication was a false and unfair smear against Christine O'Donnell. So I felt morally obligated to clarify that I knew and know of absolutely nothing improper that Christine O'Donnell has ever done at any time. As Christine O'Donnell's campaign manager for her 2008 primary (convention contest), I considered challenging her critics from 2008 to a debate. I therefore became more and more involved in refuting these allegations."
Proof that Melanie Sloan's accusations against Christine O'Donnell are false is chronicled in detail in Jon Moseley's June 4, 2011, Complaint against Melanie Sloan of C.R.E.W. filed with the D.C. Bar on June 13, 2011, can be downloaded by CLICKING HERE (recommend using the right click button on the mouse and selecting "SAVE AS" option).
Jon Moseley's affidavit regarding admissions made to him by David Keegan can be downloaded by CLICKING HERE (recommend using the right click button on the mouse and selecting "SAVE AS" option).
NO information learned from Christine O"Donnell, her legal team, campaign, or PAC is included, discussed or reflected in Moseley's Complaint or associated documents, except what was publicly and openly disclosed on or before September 20, 2010. To prove guilt by Melanie Sloan, only information that Melanie Sloan either knew or would have known if she had conducted the inquiry required of an attorney is used to establish violations by Sloan. Private information that Melanie Sloan could not have discovered on or before September 20, 2010, would not prove Melanie Sloan's violations of the D.C. Bar's Rules, except to the extent that Melanie Sloan's private interviews with her own witness David Keegan would have alerted Melanie Sloan that Melanie Sloan's claims and statements were then and are now false.
Jonathon Moseley provided the following comment in addition: "Melanie Sloan of C.R.E.W. violated numerous D.C. Bar rules and committed perjury in her complaint (sworn to under 18 USC 1001) and in her false public statements about Christine O'Donnell supposedly using campaign funds for personal use. A lawyer may not make false statements in the course of representing a client, even in non-legal contexts. Here, Melanie Sloan's many false statements were clearly intended to cause governmental resources to be used in furtherance of her clients' private agenda. D.C. Bar rules require a lawyer to promptly inform authorities upon discovering that a previous complaint is false."
Moseley further commented: "Melanie Sloan for her client Citizens for Responsibility and Ethics in Washington falsely claims that in 2009 Christine O'Donnell was not a candidate for office, thus questioning the legality of travel and meeting expenses charged to O'Donnell's campaign. However, Sloan knew or could easily have discovered that Christine O'Donnell filed her Statement of Candidacy for the 2010 election on March 20, 2009; told WDEL radio in Delaware on February 13, 2009 that she was putting together a campaign for the 2010 U.S. Senate election; purchased campaign software on January 8, 2009; and in December 2008 posted an ambiguous 'testing the water' encouragement to her supporters about possibly running in 2010. Melanie Sloan of C.R.E.W. violated the rules of the D.C. Bar by calling Christine a criminal when Sloan knew or should have known that Christine was in fact legitimately preparing a U.S. Senate campaign as early as January 2009."
Jonathon Moseley further explained: "Melanie Sloan based her false statements and frivolous complaint on the affidavit of David Keegan. But David Keegan admits he left O'Donnell's campaign in August 2008. David Keegan loaned Christine O'Donnell's campaign $2,300 on July 25, 2008, which was paid back on August 1, 2008. Sloan claims to have interviewed Keegan extensively. Melanie Sloan of C.R.E.W. admits in her own voice that Sloan's accusations concern 2009 and 2010 campaign spending. An attorney could not rationally believe that David Keegan who left in August 2008 could give Melanie Sloan of C.R.E.W. a factual basis for accusations about 2009 and 2010 campaign expenses. During 2008, Christine O'Donnell had a professional accountant, Timothy Koch, an expert in campaign finance, supervising the 2008 campaign. Melanie Sloan should have known that David Keegan would not have loaned Christine's campaign $2,300 in July 2008 if Keegan saw financial irregularities before he left in mid-August 2008. Although Keegan claims he saw spending for meals or shopping in 2008, none of those expenses show up in the campaign's spending in 2008. Sloan should have known that the campaign never actually paid for the expenses that Keegan complains about, and Keegan doesn't know anything about 2009 or 2010."
Jon Moseley also explained: "Melanie Sloan also lied for her clients C.R.E.W. and Delaware voter Leonard Togman accusing Christine of living at 248 Presidential Drive, which Sloan claims was also the campaign headquarters (in PARAGRAPHS 8 and 12 of Sloan's complaint - click here). However, 248 Presidential Drive is the commercial office of Mid-Atlantic Realty. Nobody lives in Mid-Atlantic Realty's office space. Melanie Sloan of C.R.E.W. obviously did not conduct any investigation into the truth of Sloan's accusations. As an attorney, Sloan knew that Christine's use as the campaign headquarter address as her 'legal residence' does not mean that is where Christine personally lives. If Sloan had investigated before swearing under 18 U.S.C. 1001, she would have known that Christine told the news media at least 18 days before Sloan filed C.R.E.W.'s September 20 complaint that Christine does not actually live at the address she publicly discloses as her 'legal residence.' A 'legal residence' is not a personal residence."
CNN visited Christine O'Donnell's in September and saw how it was not Christine O'Donnell's residence.
Click Here to watch the video from CNN in September showing the inside of the townhouse used as Christine O'Donnell's campaign headquarters. YOU TUBE VERSION OR: Download the video directly here ("right click" the mouse on the link and choose "save as" option to save to disk for best results)
Moseley also commented: "David Keegan's accusations are all the more strange because Keegan was supposed to be raising money for Christine O'Donnell's 2008 U.S. Senate campaign. He complains extensively about the lack of money in the campaign, although Keegan was supposed to go out and raise the money that he complains O'Donnell's campaign lacked."
Jonathon Moseley was the initial Treasurer for Christine O'Donnell's U.S. Senate campaign in Delaware in 2008, and was Christine O'Donnell's campaign manager for her primary in 2008, during which Christine O'Donnell successfully won the Republican nomination for U.S. Senate. O'Donnell and Moseley won the campaign that Moseley ran for O'Donnell in 2008. Moseley developed and wrote a lawsuit for O'Donnell in 2005 and advised Christine O'Donnell's private marketing business as a marketing consultant over several years with regard to writing and reviewing contracts, etc.
Jon Moseley is also serving as Initial Treasurer for a candidate for U.S. Senate in Maryland for the 2012 election and Treasurer for another candidate for U.S. Senate in Pennsylvania for 2012, both of which will soon announce officially.
Should Christine O'Donnell's money be wasted on lawyers for public litigation of old campaign debts and claims?
DUE TO SIZE, the Exhibits attached are broken up into three groups of documents:
First group of Documents: www.jonmoseley.com/DCBarExhibits1.pdf
Second group of Documents: www.jonmoseley.com/DCBarExhibits2.pdf
Third group of Documents: www.jonmoseley.com/DCBarExhibits3.pdf
Melanie Sloan of C.R.E.W. on CBS News, September 17, 2010
Melanie Sloan of C.R.E.W. on CNN, September 17, 2010
Melanie Sloan of C.R.E.W. on Situation Room with Wolf Blitzer on CNN, September 20, 2010
Melanie Sloan of C.R.E.W. on Anderson Cooper 360 on CNN, September 20, 2010
Melanie Sloan of C.R.E.W. on Anderson Cooper 360 on CNN, September 21, 2010
Melanie Sloan of C.R.E.W. on Rick's List on CNN, September 21, 2010
Melanie Sloan of C.R.E.W. on MSNBC's Ed Schultz program, September 21, 2010
Melanie Sloan of C.R.E.W. on Thom Hartmann Show, September 23, 2010
Although sworn before a Notary on June 4, 2011, Jon Moseley's Complaint against Melanie Sloan with the D.C. Bar was not actually filed until June 13, 2011. The D.C. Bar will most likely take several weeks to review the matter and process it before starting to consider it. The first step will probably be to forward a copy to Melanie Sloan and ask for her response. The D.C. Bar will probably not begin to look at the Complaint until receiving Melanie Sloan's response up a month from now.
Note: To try to prevent Jonathon Moseley from setting the record straight, liberals falsely claimed that Moseley called President Barack Obama a "Secret Muslim." Read it for yourself: Did Jon Moseley really say Obama is a Secret Muslim?
You can read the 2009 blog post for yourself: 2009 Article by Jon Moseley on Obama's Muslim Childhood and Incomplete Conversion to Christianity
Jon Moseley wrote in 2009:
"However, Barack Obama professes to have converted to Christianity approximately 20 years ago in Trinity United Church of Christ in Chicago, under the leadership of Rev. Jeremiah Wright, Jr. It is certainly common for Americans to change religions, and well-accepted. Many insist that a person's claim to be a Christian should
never be questioned. The very idea of doubting a person's professed choice of religion is offensive to many. Many of various religions demand that if Obama claims to be a Christian, his declaration cannot be questioned."
"However, many other Christians place great importance on the authenticity of conversion, citing the many warnings of Jesus about people who will believe they are followers of Jesus, but on Judgement Day Jesus will tell even those who performed miracles in Jesus' name "I never knew you, depart from me, you who practice lawlessness." Matthew 7:23.
"They warn that a clear understanding of who Jesus is and what salvation means is vitally important. Without a clear understanding, a person may falsely believe they are a Christian, leading to personal tragedy. Also, Jesus spent a great deal of His Ministry challenging the depth and reality of people's
relationship with God.