Ms.

Henderson,

It’s Michael Volpe and I submitted a complaint against Tulsa Special District Judge J. Anthony Miller; that
complaint turned into the file number, COC-18-61.

I am providing this addendum along with two exhibits:

1) Exhibit 1: Letter from Taylor Henderson to Michael Volpe

2) Exhibit 2: The Provocateur March 12, 2018 article New Hampshire Woman Takes on Oklahoma.

After speaking with you, I was told I could submit an addendum to my complaint to consider further
evidence.

It appears that I did not mention in my initial complain that Miller went to law school with WTF, the
litigant who received the New Hampshire house which is at issue here. Furthermore, in the beginning of
the process, Miller acted as a mediator and he lied when he was confronted with it by Hathaway.

Miller refused to recuse himself, over Hathaway’s vociferous objections.

I know that the Oklahoma Code of Judicial Conduct http://www.deontologie-

judiciaire.umontreal.ca/fr/magistrature/documents/oklahoma-code-of-judicial-conduct.pdf

requires a judge to “Avoid Impropriety and the Appearance of Impropriety in All of the Judge's
Activities.”

Yet, Miller blatantly violated this canon: not only did he go to law school with a litigant, but he wore two
hats in the process.

In your letter, you claimed you could not find violations of the Oklahoma Code on Judicial Conduct; well
now, you have a blatant one.

Furthermore, in your Council’s April 14 letter to me, Ms. Henderson notes that the “allegations are of
great concern.”

Since this is new information and you’re already “greatly” concerned, hopefully this blatant violation of
the canon takes on more urgency.

That said, it appears from the evidence I’ve already provided that you should have already found
numerous violations of judicial canons.

For instance, the Oklahoma code states, “A judge should perform judicial duties without bias or
prejudice. A judge should not, in the performance of judicial duties, by words or conduct manifest bias
or prejudice, including but not limited to bias or prejudice based upon race, sex, religion, national origin,
disability, age, sexual orientation or socioeconomic status,”

In my original complaint, I noted that Miller blatantly violated Hathaway’s rights under the Americans
with Disabilities Act. He refused to allow her a “next friend” even though she has ADHD. This directly led
to a panic attack, which he ignored, finally relenting to allow her fifteen minutes to gather herself. She
then suffered another panic attack, was summoned into court with his subpoena.
Hathaway then took trazadone, to control her breathing, but a drug which would effectively knock her
out. When she told him this back in court, he struck it from the record, forced her to continue, and she
remembers little.

That’s a blatant bias against someone who is disabled as defined by the ADA. That you all didn’t see it
speaks either to your incompetence corruption or both.

Furthermore, another judicial canon states, “A judge should be patient, dignified and courteous to
litigants, jurors, witnesses, lawyers and others with whom he the judge deals in official capacity, and
should require similar conduct of lawyers, and of his staff, court officials and others subject to the
judge's direction and control.”

How did Miller exhibit any of these if he caused a panic attack, ignored it, even issued a subpoena to
force the woman back into court: that, according to the Council, is “Patient, dignified, and courteous.”

I think Ms. Hathaway, and anyone with a soul, would disagree.

When I confronted you, Ms. Henderson, with this, you stuck to the so-called company line that your
three member panel reviewed the evidence and found no violations.

As I told you then, I don’t believe you. You are lying to me and I’ve proven it.

You are lying to a member of the press. I will make everyone one on the Council notorious if you do not
fix this immediately and grant Miller the punishment he deserves.

There are many more violations of your code committed by Miller.

For instance, he engaged in blatant forum shopping, doing it while ignoring the law. He stated that the
law required WTF to live in Oklahoma for at least six months prior to filing the petition. WTF admitted
that he had no Oklahoma residence on the day he filed. The case should have ended there. This is
deciding a New Hampshire house.

He ignored it and made the case continue.

Combined with his blatant violations Hathaway’s rights under the ADA and blatantly ignoring his own
conflicts of interests, it’s no longer merely the appearance of impropriety but it is impropriety.

That’s not allowed under your code, so the question remains why couldn’t you find it?

Finally, Judge Miller granted Hughes year long motion “nunc pro tunc.” He did it on the eve of trial. Nunc
pro tunc is supposed to go back and fix something. What was to be fixed? Why do it on the eve of trial?
Do you understand that by doing this he rendered a decision and then held the trial the next day, not
bothering to inform Hathaway until much later, when she figured it out on her own?

That’s impropriety as well, blatant and Orwellian.

You can still fix this, but you’ll have to exhibit some humanity rather than cowardice.
Exhibit !
Exhibit 2

New Hampshire Woman Takes on Oklahoma

 By Michael Volpe and Tanya Hathaway
A lawyer forcefully negotiated with a pro se litigant while she was having a panic attack.

That shocking interaction was caught on tape during a 2015 divorce hearing in Tulsa County,
Oklahoma between John Doe and Tanya Hathaway.

Michon Hughes, now of Clinton C. Hastings and Michon Hastings Hughes, Doe’s attorney, presented a
settlement offer to Hathaway, who was representing herself, while Hathaway was in the middle of a
panic attack.

Later in the same hearing, the Special Judge, J. Anthony Miller, proceeded with the hearing, even
after being told by Hathaway that she’d taken a prescription drug to help halt the attack which made
her unable to contribute to her defense.

The disturbing set of events is part of a near four-year divorce process for a six-month marriage.

(Tanya Hathaway)

A Six-Month Marriage

John Doe and Tanya Hathaway met online and after a short courtship they married on November 27,
2013.
At the time, Hathaway lived in a home she built in 2001 in Newbury, New Hampshire, with her two
sons. Hathaway and Doe decided to buy in a home in nearby Springfield, New Hampshire.

While the money to purchase the house came from Doe, the purchase and sale agreement was in both
their names, and Hathaway paid at least that much for repairs they’d planned to make upon buying the
property.
 Right before the closing, Doe told Hathaway that he needed to keep her off the deed for taxes
purposes but would put her back on shortly after they got married; Doe, however, never put Hathaway
on the deed.

The house closed in September 2013.

Several weeks after the property closed, Hathaway, Doe, and her two sons spent the day moving
personal effects and furniture from her Newbury home.
They were to spend their first night in the marital home. And they did.

Doe remembers it differently saying in an email: “After I took title from the accommodator, she
(Hathaway) moved into the house without my permission before we were married.” Doe said in an
email, but he did not explain where he and his new wife were living, if not in this property.

In a letter to his mother, he also presented the home as his and Hathaway’s: “The plan is simple
there is no need to carry 3 houses. Tanya is selling hers and will get out from underneath the bills and
mortgage on her own. I am not helping her on any of her expenses on that. She will stay in Philbrick
(the disputed property) for now and keep it winterized.”
Doe spent the semester working at Oral Roberts University in Oklahoma and commuted back and forth.

Unbeknownst to Hathaway, Doe was carrying on inappropriate in an relationship with at least one
other woman before and during the marriage.

On March 19, 2014, upon discovering evidence of betraying their marriage, Hathaway asked Doe to
leave.
They reconciled shortly after and Doe sold his Oklahoma home in May, but the marriage fell apart for
good in late June.

Leads to a Four-Year Divorce

On July 3, 2014, with process servers in hot pursuit to serve him with divorce, Doe served Hathaway
for divorce in Oklahoma.

Hathaway’s immediately filed in New Hampshire- but he fled, nowhere to be found and couldn't be
properly serve him.

in New Hampshire the law would have treated their home as marital property and even split is
presumed, while in Oklahoma the home would have been treated as his because he bought it before
the marriage.

Doe seemed to know this when he emailed Hathaway’s sister suggesting they just sell the house and
split the money. That was until he realized that hand served divorce papers were not allowed in New
Hampshire. Doe had hired Michon Hughes, a powerful figure in Tulsa’s legal community; Hughes and
Doe had worked together on mock trials while he taught at Oral Roberts University.Doe is a lawyer.

Many attorneys refused to take Hathaway’s case after it unfolded; as a result, Hathaway was forced
to represent herself for much of the affair, and when she had representation, the attorney generally
worked against her
interests.
 The Bogus Notary

The initial petition filed by Hughes on Doe’s behalf appears to not have properly been notarized. The
lawsuit was notarized by Hughes, not a third party, and it later came out that the petition had been
emailed back and forth between Doe and Hughes, and as such, she hadn’t witnessed his signature.

Grey was an attorney working for Hughes firm at the time; he acted as a go-between emailing the
document back and forth from Doe to Hughes with Hughes notarizing the document which was emailed
to her.

All three- Doe, Grey, and Hughes- are attorneys and presumably would have known that a notary
must witness the signature.

(Michon Hughes)

Grey has since moved to his own firm and did not respond to an email for comment. When this was
argued in front of Judge Miller, Hughes claimed that notarizing in this way is normal, accused
Hathaway of doing the same thing, and claimed a 2013 law allowed her to do this.

Hathaway denied notarizing this way, and Hughes provided no evidence to back up this assertion;
Hughes never provided this purported law allowing such a notary.

I could not find such a law in Oklahoma or any other state; Hughes did not respond to a voicemail for
comment.

Notarizing the initial lawsuit in this way would not only constitute a fraud upon the court but since
Hathaway had filed a petition for divorce in New Hampshire, but hadn’t yet served Doe, this would
mean Doe’s legal team cheated to get the case in the state they wanted.
 The Order of Protection

In April 2015, Hathaway was served at her New Hampshire home with an order of protection
(OOP); Doe claimed Hathaway was harassing his friends and family, along with other transgressions.

The OOP claimed Hathaway lived in Oklahoma; Michon Hughes would later say that this was a
scrivener’s error, legal term for a typo.

“You know that was a scrivener’s error,” Hughes said.

“No, that was deception,” Hathaway responded.

If it was a scrivener’s error, it’s never been corrected and it’s a convenient typo because it suggested
that Hathaway lived near Doe when they lived more than a thousand miles from each other. (Doe was
living in Oklahoma in 2015.)

At the OOP hearing, Doe accused Hathaway of stalking, theft, harassing his family and employer, and
costing him his job; Hathaway had to travel to Oklahoma- she has made approximately ten trips for this
case- and was prepared to counter each charge- she had a warm birthday card from Doe’s sister who
Hathaway had purportedly stalked- but she had the first of several panic attacks, failed to make the
hearing and the order was entered by default. Doe never provided any witness statements to satisfy
the claims.

As a result, Hathaway was ordered to stay at least five hundred feet away from him, not to reference
him on social media, a blog she started and to his then employer; in the blog she noted that she’s a
domestic violence survivor, a certified volunteer crisis counselor, and advocate for domestic violence
survivors; the picture painted by the OOP was the opposite of who she was.

The only other time in her life she had suffered panic attacks was when she was a domestic violence
victim in her twenties.

Dirty Laundry on Dr. Phil

A family member of Hathaway’s suggested that the whole bizarre episode was perfect for Dr. Phil.

Months after getting an OOP, which forbade Hathaway from being within five hundred feet of Doe,
they shared the same Dr. Phil stage voluntarily.

Also on the broadcast were Doe ex-wife, Kelly, and his ex-fiancée, Julie.

“(Doe) is a user, and a thief, and a liar,” said Julie on the broadcast, a show entitled “The College
Professor and His Many Women.”
Doe “portrayed himself as a man of god but he’s really demon possessed.” Julie also said.

Julie went on to say that the two were engaged on August 11, 2011, also after a short courtship, but
then Doe ended it suddenly with a text message and kicked her out of the house.

“When Doe kicked me out, I felt so unbelievably betrayed,’ Julie said.

 It came out in the broadcast that Doe came cross country with his daughter- presenting himself as
unattached- to see Hathaway while Julie was still living with him.

“One time when I was nine years old, he actually took me to meet with one of his lovers,” his ex-
step-daughter Marissa said, describing how brazenly Doe cheated on her mom.

Kelly said before they divorced Doe pressured her to give him $300,000 for a property she said they
purchased with her money. Doe also manipulated two properties in the divorce.

“All three of these women have one thing in common,” Hughes said, “they wanted more of
Doe property wise than he was willing to give.”

At that moment, all three women adamantly spoke up to challenge the assertion.

Of Hathaway, Doe said that the home at issue was an investment property; he accused Hathaway of
being a gold digger, of also having affairs, and hiding her past as a dancer.

Hathaway adamantly denied all the charges and said she never hid that she’d been a dancer.

He was painted as a serial philanderer; shortly after the show aired, he was terminated from his job at
Oral Roberts University.
Doe remained defiant, stating in an email: “There are no children, no abuse issues, you should see
the irony that a less than 6 month marriage has resulted in a Dr. Phil Episode.”

Subject Matter Jurisdiction

Proper implementation of subject matter jurisdiction prevents judge or forum shopping.

A court must have some sort of stake in a case before it can hear it: That’s subject matter
jurisdiction.

Their marital home was in New Hampshire, Doe claimed their marital home as his primary property,
and he’d already sold his Oklahoma home; as such, Hathaway argued, Oklahoma had not established
subject matter jurisdiction.

In an email to me, Doe said: “My domicile was Oklahoma and I had a contract to teach for the 2014-
2015 school year in Tulsa,” and as such, argued that Oklahoma did have subject matter jurisdiction.

At a hearing held in in April 2016, nearly two years after the divorce was filed, in front of Tulsa
County Special District Judge J. Anthony Miller, Doe admitted that he had lived at the New Hampshire
property, signed up for a Post Office box in December 2013 where he stated he had a permanent
address in New Hampshire, the marriage license listed New Hampshire as their legal address, and
renewed his driver’s license in New Hampshire on June 27, 2014.

Judge Miller, during an argument with Doe's attorney, noted the importance of this evidence: “I don’t
understand why a driver’s licenses would not be admissible to go to evidence of where a person’s
residence is in a hearing on subject matter jurisdiction.”

Doe provided a storage locker receipt in Oklahoma as evidence he lived in the state.
 (Orwellian Judge J. Anthony Miller)
This video summarizes the events...

Judicial Estoppel

Hughes also argued that the case should move forward based on a legal technicality called judicial
estoppel, which “prevents a party from asserting a position in one legal proceeding that directly
contradicts a position taken by that same party in an earlier proceeding.” According to the Cornell Law
Review.
Hughes argued because Hathaway had come to Oklahoma to challenge the lawsuit, this implicitly
gave the state jurisdiction.

Without subject matter jurisdiction, judicial estoppel is moot. After all, litigants need to prove
domicile- meaning being a lawful permanent resident in a particular jurisdiction - before filing a
lawsuit, and if all Doe provided was a storage locker receipt, he’d done nothing to show subject matter
jurisdiction.

Neither estoppel nor anything else applies if it is achieved by fraud, but Judge Miller- who forced
Hathaway to travel to Oklahoma for every hearing- ruled that estoppel applied.

The next day, after Hathaway filed an emergency motion for reconsideration, Judge Miller
augmented his ruling, saying that not only did estoppel apply but subject matter jurisdiction as well.
 “I apparently, I left the impression and I want to correct it, that the only basis for my ruling
yesterday was on the basis of judicial estoppel. It’s my intention to indicate that after hearing those
many hours of testimony, the facts support that this court has subject matter jurisdiction,” Judge
Miller stated at this hearing, “He was a resident based on the factual record presented.”

While he said there was subject matter jurisdiction at this hearing, he never provided an explanation
to back up this assertion, moving on to another subject after making this proclamation during the
hearing.

The Conflicts of Judge J. Anthony Miller

Judge J. Anthony Miller appears to have been duty bound to recuse himself from the case. First, he
was an informal mediator during a mediation session held on January 5, 2015.

He denied that he had been the informal mediator when asked to recuse himself, but Hathaway
remembered him from the session; Judge Miller was the second judge on the case; Judge James Keeley
presided over the case when Judge Miller was the informal mediator.

Bill Windsor tracked down the document proving this.

“On January 5, 2015, a so-called ‘mediation’ was held by (Doe's) attorney, Michon Hughes, with
Tanya Hathaway, and with a Tulsa judge/mediator. The ‘mediator’ was not the judge in the case. The
meeting was allegedly an attempt for a quick resolution. The ‘mediator’ gained personal knowledge of
disputed evidentiary facts concerning the proceeding. When Tanya Hathaway attempted to speak
during the informal conference, the ‘mediator’ yelled at Tanya Hathaway to ‘SHUT UP.’ In April 2016,
Tanya Hathaway learned that the ‘mediator’ was Judge J. Anthony Miller.” According to a blog post
about the case from 2016.
Judge Miller denied an emergency motion to disqualify himself from the case filed on July 5, 2016,
where these arguments were made.

The Trial

The day after the subject matter jurisdiction hearing a divorce trial was held.

Hathaway initially made a motion to the court for an accommodation- a request she’d made before-
under the Americans with Disabilities Act (ADA).

Hathaway was diagnosed with adjustment disorder, which is a series of symptoms like anxiety and
panic attacks resulting from a stressful life event.

She has attention deficit disorder (ADD), but because of the anxiety and panic attacks, her doctors
removed her ADD medication which exacerbated the panic attacks.

As a result, she told Miller it was impossible for her to concentrate, and she was unable to properly
catalogue: emails, receipts for improvements on the home, cash payments, and other documents.
 She asked for a next friend- a person who assists another person who is under disability- to help
catalogue her documents; Judge Miller denied this accommodation while refusing to accept her
medical records as evidence.

Since it was the legal abuse which caused her adjustment disorder, Judge Miller had a reason not to
recognize her disability; after all, he caused it.

Judge Miller then put off a citation he’d made against Doe for direct contempt for perjury, saying the
issue would be taken up after the trial; as such, Doe could testify while being accused of lying under
oath.

Among other things, Doe claimed Hathaway withheld his mail and that only she could forward the
mail at the PO Box, when in reality, he had total control of that mailbox.

The direct contempt citation disappeared from the docket on the central system called, Oklahoma
State Court Network (OSCN) and the jury trial, which Judge Miller ordered in his citation, was never
held.

The Tulsa County Clerk of Court confirmed it’s not in their system but had no explanation why. The
Clerk’s office said if a copy was submitted to them it would be entered into the system which I’ve
done.

Approximately fifteen minutes into the hearing, Hathaway excused herself and went into the hallway;
she was on the verge of a panic attack.

In the hallway, the panic attack continued, but Hughes was unimpressed, initially telling Judge Miller
that Hathaway was faking it before following Hathaway into the hallway and presenting a deal.

“We know you’re going to appeal and this is going to drag on,” Hughes said while Hathaway was in
the hallway trying to control her breathing.

“I’m having a panic attack and the only way to stop it now is to take meds that would knock me out
and then I can’t even be there,” Hathaway responded still trying to control her breathing.

Hughes, who then acknowledged she’d also had panic attacks, responded, “$25,000, I think we’ve all
agreed you put in at least that much. If we sell the property there will be at least that much.”

“I want this over with because I can’t live with him trying to take everything through the lies,”
Hathaway responded still trying to control her breathing.

Carol Channing, the communications director of the Oklahoma Bar Association, did not respond when
asked if this move violated any ethical standards.

This was one of over one hundred items filed by Hathaway in a bar complaint against Hughes; after a
year, the bar responded by saying there was nothing to investigate.

Back in the courtroom, Hathaway said, “I’m having a panic attack and if I don’t take the medication I
will have to go to the hospital and if I take medication, I won’t be able to stay awake and think
clearly.”

Upon hearing this, Judge Miller adjourned the trial for fifteen minutes for Hathaway to collect
herself.

During the break, an emergency medical technician (EMT) treated her with oxygen; while being
treated by the EMTs, she was served with a subpoena, and told to return or lose by default.
 Hathaway took a trazadone-prescribed by her doctor- to control her panic attacks; it was the first
time she had taken trazadone- a drug which causes dizziness, drowsiness, and light-headedness.

When Hathaway informed the court, she had taken the drug, her statement was stricken from the
record and Miller ordered the proceedings to continue.

Hathaway finished the trial that day, but remembers very little.

A call to Judge Miller’s chambers was also left unreturned.

Hathaway filed a grievance with the Oklahoma Board of JudicialStandards against Judge Mller-but
they declined to take any action; they declined to comment to me, citing privacy.

(Oklahoma Bar rejecting Hathaway's complaint against Miller)

This video summarizes the shocking set of events...

The Decision:

According to the docket, prior to the trial, Judge Miller was to hear Hathaway’s motion to vacate a
defaulted order for summary judgment along with defaulted temporary orders.

The summary judgment gave Doe sole possession of the house.

These orders were entered by default at a hearing in April 2015; Hathaway didn’t make the hearing
because while leaving her hotel which was across the street from the courthouse she suffered another
panic attack.

She filed a motion to vacate before she left Oklahoma in April 2015- higher courts frown upon default
judgments if the defaulted party has a good reason- and her motion was on the docket for a year and
to be heard before the other matters- the subject matter jurisdiction and the divorce trial.
 Rather than hearing Hathaway’s motions to vacate, Judge Millermade a nunc pro tunc ruling- a legal
term which means to retroactively act on an earlier matter- which mirrored the summary judgment:
Doe got sole possession of the house.

As such, rather than granting Hathaway a right to be heard, he gave Doe what he asked for without
giving her a chance to oppose it. "
I never intended to hurt her, throw her out, or do anything to harm her and the boys." Doe said to
Hathaway's sister in an email from September 2014, but that's exactly what will happen if this ruling is
upheld.

Curiously, Hughes, on April 6, 2016, entered her appearance on Doe’s behalf also nunc pro tunc.

Hathaway has appealed; her latest appeal to the Oklahoma Supreme court stated: “EMERGENCY
APPEAL AND MOTION TO REQUEST THIS MOTION AND BE ACCEPTED AND REQUEST FOR AN IMPARTIAL
INVESTIGATION THROUGH A HIGHER COURT AND OVERTURN ANY AND ALL FINDINGS BY AND THROUGH
TULSA COUNTY COURT AND ALL INVOLVED IN THE CORRUPTION IN THIS MATTER BEFORE THE COURT.”

The appeal has sat at the Oklahoma Supreme Court for approximately a year without a resolution.

There are more than fifty entries on the Oklahoma Supreme Court docket for this case; the case in
Judge Miller’s court has more than one hundred entries. There are hundreds in the District Court, some
that Hathaway claims have been removed, many not available, and plenty “sealed”.

“For a six months marriage the cost in time has been exorbitant” Doe said during the hearing, “We
didn’t have joint bank accounts, we didn’t have joint savings accounts, the property in her name
remained in her name, the property in my name remained in my name and there was no reason it
should have gone on this long,”

On March 9, 2018, the Oklahoma Appeal's Court Division III affirmed the Orwellian decision, but
Tanya has one last desperate hope at the Oklahoma Supreme Court.

Injustice in Oklahoma EXPOSED:

From that experience, Hathaway started Injustice in Oklahoma EXPOSED; her story is one of tens of
thousands of stories of corruption at all levels of government in Oklahoma, she said. She has also
expanded that forum and is a regular host on TS Radio “TNT Tanya Talks”and has also been asked to
speak at the annual Whistle-blower’s Summit in Washington DC this summer and is dedicated to making
a difference with other dedicated advocates like herself.