Professional Documents
Culture Documents
Affidavit For Bar Complaint Against Michon Hughes
Affidavit For Bar Complaint Against Michon Hughes
Affidavit For Bar Complaint Against Michon Hughes
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
CHARGES
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
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
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
Public: “A notary public acts as an official witness to the identity of a person who
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
and other paper shall be signed by at least one attorney of record in the individual
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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.”
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
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
Multiple Court Filings and Brief on Jurisdiction” was filed by Michon Hughes in
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)
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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.)
matters. Then she began representing Winston Frost in the divorce in Case #FD-
represent both parties in real estate matters. This conflict was identified by me, but
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.
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
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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
dated February 10, 2016. [Exhibit 7 is a copy of this letter with the dollar amounts
the interest of attempting to settle this matter only if done at this time. This
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
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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:
19. In this Objection [Exhibit 5], Michon Hughes also told the Court:
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
attorney wrongfully charging an adversary with criminal acts in a civil case should
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21. This violates the Oklahoma Rules of Professional Conduct A
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
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.
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.”
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,
26. Michon Hughes told the Court in Case #FD-2014-1476 that I sent her
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
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
1476 in Tulsa County Court. Michon Hughes charged me with trespassing, mail
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
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
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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:
this matter only if done at this time. This information is not to be used in any
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
Court, but that violation of the Rules of Professional Conduct pales in comparison
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:
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
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36. Michon Hughes falsely accused me in civil Case #FD-2014-1476 of
“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.
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.
Paragraph D.] I never hacked or illegally accessed her client’s emails, and she
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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
[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.
“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.]
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CHARGE #13. MICHON HUGHES HAS COMMITTED VIOLATIONS
OF OKLAHOMA CRIMINAL STATUTE 21-491 – PERJURY.
43. 21-491. PERJURY. (a):
45. Michon Hughes has committed multiple felonies in court filings that
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
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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
49. Michon Hughes has also filed a fraudulent Attorney Lien. [Exhibit 9.]
“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.”
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:
53. Michon Hughes had the forged Petition for Dissolution of Marriage
54. Michon Hughes has filed a fraudulent Attorney Lien. [Exhibit 9.]
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
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57. Michon Hughes had the forged Petition for Dissolution of Marriage
58. 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.]
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-
(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.”
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
Oklahoma. Winston Frost did not meet the requirements, so the Petition was
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
“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
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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
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
“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….”
not required to make a disinterested exposition of the law, but must recognize the
jurisdiction which has not been disclosed by the opposing party. The underlying
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72. The Record shows that Michon Hughes made legal arguments based
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.
“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
know that evidence she presented was false. She did nothing about it, and she
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
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
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
tribunal against criminal or fraudulent conduct that undermines the integrity of the
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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,
disclosure if necessary, whenever the lawyer knows that a person, including the
82. Michon Hughes is a disgrace to the legal profession. She has lied and
misrepresentations. She has made misleading and bogus legal arguments. She has
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
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
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“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….”
86. “A lawyer shall not: (b) falsify evidence, counsel or assist a witness to
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;
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
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that the evidence in a case is to be marshalled competitively by the contending
94. (Comment 2): Documents and other items of evidence are often
95. Michon Hughes has obstructed my access to evidence, and she has
97. “A lawyer shall not: (a) seek to influence a judge, juror, prospective
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juror or other official by means prohibited by law….”
98. “A lawyer shall not: (b) communicate ex parte with such a person
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
harassment….”
tribunal.”
parte with persons serving in an official capacity in the proceeding, such as judges,
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.
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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….”
105. Michon Hughes has lied repeatedly to the Court and to others. She
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disinterested in loyalties or is a disinterested authority on the law even when the
typically need to identify the lawyer’s client and, where necessary, explain that the
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
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
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
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of the meaning of the document or the lawyer’s view of the underlying legal
obligations.
“(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.”
J. Anthony Miller.
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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.”
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.]
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
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
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
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
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
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
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
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
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
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
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
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-
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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
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.
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.
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
property out of her client. Please require that she document this claim. She will
38
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
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.
135. Michon Hughes lied in her letter to the Oklahoma Bar Association
when she wrote: “She admitted to receiving a several hundred thousand dollar
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
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
co-owner, and Winston Frost promised to reimburse me for the $178,442.74 that I
Contempt dated February 10, 2016. [Exhibit 25.] I will be happy to provide each
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
40
Respondent in addition to the continued threats of sanctions, bar complaints,
and criminal charges against the attorney. Such threatening personal attacks
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
identified more notary fraud by Michon Hughes, and she will be asking the Court
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.
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
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.”
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
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
and to Reschedule Hearing and Trial Dates: Respondent’s ‘disability’ has not
genuine, and every sworn statement of fact is true. Michon Hughes never provides
42
145. On April 1, 2016, Michon Hughes filed “Petitioner’s Third Combined
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
147. There is nothing illegal about obtaining evidence that you were given
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
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
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
151. I have not taken the hundreds of pages to list all of the false
be, I will list each false statement and provide the evidence that proves each
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
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
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).
I declare under penalty of perjury that the foregoing is true and correct.
_________________________
Tanya Hathaway
48
VERIFICATION
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
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
___________________________
Tanya Hathaway
____________________________
Notary Public
49