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- 2019-09-19, email at 13:58 AM (https://grodnermiller.blogspot.com/2019/09/re-fwd-grodner-v-grodner-13-cvd-398.html)
- False statement:
- In response to my question "Do you have any rationale for your objection?" he wrote "Do you mean other than the lack of a rational, believable, meritorious excuse for seeking additional time?"
- Explanation
- Mr. Miller knew that I received extension for valid reasons, such as having ADHD. See mention it in my 20 September 2019 Motion with COA: https://www.ncappellatecourts.org/show-file.php?document_id=254310
- 2019-09-17, hearing in front of Judge Paul Hardison (see official recording: https://grodnerdivorce.blogspot.com/2019/09/court-hearing-officia'l-recording-of.html)
- False Statement:
- "[Mr. Grodner] has not responded in any way" to Mr. Miller's Objections.
(audio: at 9:32:10am) - Explanation:
- I sent email to Mr. Miller responding to his Objections on 16 September 2019 via email, then forwarded it to Judge Hardison, and actually filed that email: https://grodnerdivorce.blogspot.com/2019/09/filed-email-communication-to-judge.html. So in a way Judge Hardison should have corrected Mr. Miller for this lie but Judge Hardison did not seem aware that he received email from me and that it was filed.
- ============================
- False Statement:
- "I have not received a copy of the transcript from Mr. Grodner as part of the record or from court reporter in any fashion" (audio: at 9:36:36am) "[Mr. Grodner] continues to talk about some kind of email knowing that I told him not to email me and so his emails are not service of anything (...) So I don't know what he is talking about, what I should have. I represent to the court that I have not seen verbatim transcript, he did not serve the verbatim transcript." (audio: at 9:37:17am)
- Explanation
- Mr. Miller received an email from court reporter telling him that the transcript is ready and that he should contact court reporter to get it - it is at the bottom of filed email to Judge Hardison: https://grodnerdivorce.blogspot.com/2019/09/filed-email-communication-to-judge.html. Later during the hearing Mr. Miller actually filed as evidence the email that he received but also misrepresented its content because it says that he should contact court reporter to get it and certificate of service says that he actually got it, so it is his responsibility to contact court reporter.
- ============================
- Misleading the court - in that discussion Mr. Miller is representing to the court that I am somehow supposed to serve him with the transcript.
- ============================
- Misleading Statement:
- "There is nothing that authorize [Mr. Grodner] to serve me by email." (audio: at 9:42:52am)
- Explanation:
- Mr. Miller tried to respond to accusation that he made false statement that he does not have to communicate with me by email but when the Court of Appeals Stayed part of Gatekeeper Order then 16 December 2016 Order was in effect I could communicate with me ONLY via email. So this is between a lie and misleading statement but it is hard to deny that Mr. Miller knows how he is trying to mislead the Judge.
- 2019-09-03, Plaintiff-Appellee's Objections to the Proposed Record on Appeal; and, Plaintiff-Appellee's Request for Judicial Settlement (http://grodnerdivorce.blogspot.com/2019/09/court-document-plaintiff-appellees.html) - see response via email (https://grodnerdivorce.blogspot.com/2019/09/filed-email-communication-to-judge.html)
- Legally improper request / false statement in hopes Judge will believe him
- In paragraphs (1), (2), and (3) Mr Miller improperly asks for exclusion of documents on the basis that they are "unnecessary for an understanding of the issue"
- Explanation:
- This request is directly in violation of NC Rules of Appellate Procedure Rule 11(c)
- Mr. Miller knew what he was doing because after I pointed this out to him in an email then during hearing he in completely reversed himself and said that actually Judge's role is limited.
- =======================
- False Statement
- "(6) The verbatim transcript designated by appellant has not been delivered to the appellee's counsel, has not been included with the proposed record served in this appeal, and it has not yet been settled as part of the record"
- Explanation
- Mr. Miller received an email on 28 August 2019 and during hearing on 17 September 2019 introduced it as his exhibit 1, thus proving his own lie in a motion. https://grodnerdivorce.blogspot.com/2019/09/filed-email-communication-to-judge.html
- Here is exhibit 1 posted: https://grodnerdivorce.blogspot.com/2019/09/court-hearing-official-recording-of.html
- 2019-03-15, email at 11:17:00 AM (http://grodnermiller.blogspot.com/2019/03/re-fwd-demand-letter-of-apology-from-mr.html)
- Misleading statement (REPEATED):
- "I have invited you to make your complaint in the proper forum and we can litigate it there."
- Explanation
- Mr. Miller meant "proper forum" to be NC Bar but for my relief, which is to remove him, the proper forum cannot be NC Bar because it only has jurisdiction over law licenses, not whether attorney can appear in front of a particular tribunal. NCRPC Rule 1.16(C) in pertinent part states: "A lawyer must comply with applicable law requiring notice to or permission of a tribunal when terminating a representation." (https://www.ncbar.gov/for-lawyers/ethics/rules-of-professional-conduct/rule-116-declining-or-terminating-representation/)
- Consquence
- Judges refuse to examine whether Mr. Miller commits misconduct by believing his false statement that I have to go to NC Bar to get my relief.
- 2019-03-10, email at 07:23:00 PM, statements in proposed Order (http://grodnerdivorce.blogspot.com/2019/03/official-document-proposed-order-send.html)
- ==================
- False statements:
- (Jeffrey L. Miller proposed by FINDING OF FACT (55)) (...) "Other than the Defendant's persistent personal statement that Mr. Miller was a liar, the Defendant presented no evidence to support his statements or claims or to support to any entitlement to any form of relief. The exhibits presented by Defendant do not prove that Mr. Miller made any false representations or statements to this or any other Court. (...) There is no evidence Mr. Miller lied to anyone or had ex parte contact with Judge Teague. The evidence indicates that the Court finds Mr. Miller did not lie or make misrepresentations to the Court and he did not have ex parte contact with Judge Teague."
- Explanation
- See the following exchange of Andrew Grodner and Judge Hardison, [page 65 line 23] - [page 66 line 11] (https://grodnerdivorce.blogspot.com/2019/03/court-hearing-3719-transcript-version.html):
- MR. GRODNER: So, if I can just for the record make a statement that this (inaudible) that this Court is aware that Mr. Miller is lying and ---
- THE COURT: No, sir, you can’t make that statement because you cannot speak for the Court. So you cannot make that statement.
- MR. GRODNER: I have presented evidence that Mr. Miller is lying and this Court is allowing the hearing to proceed even with the evidence of Mr. Lit – Wit – Miller ---
- THE COURT: Excuse me, sir. You - you can’t make that statement. You can only understand that this Court has denied your motion to continue and you can appeal it to the North Carolina Court of Appeals. And we’re now proceeding with Rule 59 motion. Let’s proceed.
- See 15 March 2019 Rule 8C-1.201 / 1A-1.58 Motion (http://grodnerdivorce.blogspot.com/2019/03/court-document-filed-rule-8c-1201-1a.html)
- ==================
- To be done
- 2019-03-10, email at 07:23:00 PM (https://grodnermiller.blogspot.com/2019/03/grdner-order-for-judge-hardison.html).
- False statements:
- "I have not agreed or consented to receive any email communication from Mr. Grodner. Any belief he may have had that there was some authority for him to email me against my wishes was dismissed by Judge Hardison on 7 March 2019. Judge Hardison told him directly, and ordered, that he shall not communicate with me by email. If he has a response, he is subject to a gatekeeping order which requires an attorney's certification. In any event, he should not communicate with me by any means other than in a mailing through the US Mail."
- Explanation
- Basically until the Order is signed and filed then it is NOT ENTERED and it is not law. Thus, Mr. Miller was deceitful in suggesting that somehow him sending the draft of the Order is binding on me in any way. See email to Mr. Miller on 2019-03-11 at 12:40:00 AM (https://grodnermiller.blogspot.com/2019/03/fwd-grdner-order-for-judge-hardison.html)
- As of writing of Mr. Miller's email the 13 December 2016 was in effect by mandating me to ONLY use email in communication with Mr. Miller, no exceptions. (http://grodnerdivorce.blogspot.com/2016/12/court-document-order-to-withdraw-teresa.html)
- ==================
- To be done
- 2019-03-07, hearing in front of Judge Paul Hardison (see official recording: http://grodnerdivorce.blogspot.com/2019/03/court-hearing-3719-full.html and transcript: http://grodnerdivorce.blogspot.com/2019/03/court-hearing-3719-transcript-version.html)
- ============================
- False Statement:
- "I’m here to stand by everything that I’ve said in e-mails; everything I’ve said to anybody about the case; everything I’ve said to Mr. Grodner in any way." (audio: 54:39) (transcript page 35 lines 1-4)
- Explanation:
- Mr. Miller confirms that he stands by all the lies he said in Exhibits 1-6 that were introduced earlier by Andrew Grodner under oath (transcript from page 22 line 20 to page 29 lines 6)
- 2019-01-11 Mr. Miller's Objection; Motion to Strike; Motion to Summarily Deny and Dismiss; Motion for Attorney Fees and Sanctions; Motion for Pre-filing Restraint and Gatekeeper Order https://grodnerdivorce.blogspot.com/2019/01/court-document-objection-motion-to_11.html
- To be done but discussed in part during 7 March 2019 hearing: http://grodnerdivorce.blogspot.com/2019/03/court-hearing-3719-full.html
- I was effectively denied the right to respond: https://grodnerdivorce.blogspot.com/2019/03/court-hearing-audio-excerpt-pitt-dc05.html
- 2019-01-09 Mr. Miller's Objection; Motion to Quash; Motion for Protective Order; Motion for Attorney Fees: https://grodnerdivorce.blogspot.com/2019/01/court-document-objection-motion-to.html
- To be done but discussed in part during 7 March 2019 hearing: http://grodnerdivorce.blogspot.com/2019/03/court-hearing-3719-full.html
- 2019-01-09 and ongoing: multiple false statements made in his emails regarding ex parte communication with Ms. Hartzog as part of preparation and filing of the 8 January 2019 Order to Recuse Judge Braddy
- ============================
- False statement in email on 2019-03-19 at 02:18:00 PM (http://grodnermiller.blogspot.com/2019/03/re-fwd-fwd-grodner-v-grodner-pitt.html):
- "for your record, I did not have ex parte contact with Judge Teague, and I did not direct or otherwise participate in any such contact with Judge Teague."
- Explanation in email on 2019-03-19 at 08:07:00 PM (http://grodnermiller.blogspot.com/2019/03/fwd-fwd-fwd-fwd-grodner-v-grodner-pitt.html)
- In the same thread of emails Mr. Miller says "I did not have ex parte contact with Judge Teague" and "I simply responded to her email." No matter what the truth is, both of those statements cannot be true
- ============================
- False Statement during 2019-03-07 hearing in front of Judge Paul Hardison (see official recording: http://grodnerdivorce.blogspot.com/2019/03/court-hearing-3719-full.html and transcript: http://grodnerdivorce.blogspot.com/2019/03/court-hearing-3719-transcript-version.html)
- "I’m here to stand by everything that I’ve said in e-mails; everything I’ve said to anybody about the case; everything I’ve said to Mr. Grodner in any way." (audio: 54:39) (transcript page 35 lines 1-4)
- Explanation:
- Mr. Miller confirms that he stands by all the lies he said in Exhibits 1-6 that were introduced earlier by Andrew Grodner under oath (transcript from page 22 line 20 to page 29 lines 6)
- ============================
- False statements between 2019-01-09 and 2019-02-01:
- 6x statements in emails, evidence introduced during 7 March 2019 hearing and presented on the page: http://grodnerdivorce.blogspot.com/2019/03/court-hearing-3719-full.html
- Explanation:
- Exhibits 7 and 8 are the proof, presented during hearing (http://grodnerdivorce.blogspot.com/2019/03/court-hearing-3719-full.html)
- Response from Mr. Miller:
- During 7 March 2019 Mr. Miller had no response after the evidence of him saying falsehoods was presented. He did not object to introducing any evidence.
- 2019-01-07, hearing in front of Judge Lee Teague (see official recording/transcript: http://grodnerdivorce.blogspot.com/2019/01/court-hearing-hearing-on-courts-motion.html) resulting from Judge Braddy's 4 December 2018 Motion to Recuse (https://grodnerdivorce.blogspot.com/2018/12/court-document-emails-request.html)
- False statement
- "So, if-if-if the idea is everybody’s gonna be recused here, I just want the record to be clear that it is not as a result of anything my client or I have done" (page 7 lines 7-10)
- Explanation
- The question of Mr. Miller's conduct was actually supposed to be litigated at that hearing because in one my emails from 16 November 2018, at 7:31 AM (https://grodnermiller.blogspot.com/2018/11/grodner-v-grodner-13-cvd-398-intention.html) cited by Judge Braddy in his own 4 December 2018 Motion to Recuse (https://grodnerdivorce.blogspot.com/2018/12/court-document-emails-request.html), I wrote "if Judge Braddy continues to recite lies that Mr. Miller is saying without thinking then there is no point of presenting a legal argument in front of him." So the entire hearing was PRECISELY about what Mr. Miller did and his deliberate misrepresentations to the court.
- In fact, during the same hearing Mr. Miller states: "[Defendant] alleged that (...) I’ve lied to the Court and the Court accepts my lies as the truth" (page 10 lines 1-4)
- 2019-01-02 Mr. Miller's Objection; Motion to Quash; Motion for Attorney Fees; Motion for Rule 11 Sanctions (https://grodnerdivorce.blogspot.com/2019/01/court-document-objection-motion-to_2.html)
- See some false statements described 4 January 2019 Affidavit of Andrzej Grodner in Response: https://grodnerdivorce.blogspot.com/2019/01/affidavit.html
- 2018-11-28 Mr. Miller's Motion to Modify (https://grodnerdivorce.blogspot.com/2018/11/court-document-motion-to-modify-and.html)
- See some false statements described in my 11 December 2018 Verified Response to Motion to Modify (https://grodnerdivorce.blogspot.com/2018/12/court-document-verifed-response-to.html)
- 2018-11-14 hearing in front of Judge Braddy (https://grodnerdivorce.blogspot.com/2018/11/court-hearing-20181114.html)
- See at least three false statements described in my 27 December 2019 Verified Rule 59 Motion: https://grodnerdivorce.blogspot.com/2018/12/court-document-verified-rule-59-motion.html
- 2018-10-11 to ongoing: direct communication with Andrew Grodner email to text/email:
- False statements 2018-10-11:
- "Any further communications with me should be in writing in the form of a letter or formal court document." (http://grodnermiller.blogspot.com/2018/10/re.html)
- "I am delivering your text messages to law enforcement. I am also reminding you to stop texting or e-mailing me" (2018-10-11_12.49.email.to.text.from.Miller.png)
- Explanation
- See 12 October 2018 Motion to Remove Opposing Counsel (https://grodnerdivorce.blogspot.com/2018/10/court-document-motion-to-remove.html) and 2 November 2018 Motion for Summary Judgment (https://grodnerdivorce.blogspot.com/2018/11/court-document-motion-for-summary.html)
- Consequence
- Mr. Miller's client is violating Custody Order daily.
- === (TO DO - false statements in Motions & Responses with Court of Appeals)
- 2018-01-08 at 2:08PM, Appellee's Brief filed by Jeffrey L. Miller in COA17-570 (https://grodnerdivorce.blogspot.com/2018/01/coa17-570-plaintiff-appellees-brief.html)
- ===================
- False statement
- "Appellant includes many ad hominem and other personal statements in the record and in his Brief concerning Plaintiff's attorney (even allegations of criminal misconduct - See R p 96) which are untrue and unrelated to any legal issue for decision by this Court. Counsel will not respond to or otherwise include arguments on those matters in the Appellee's Brief, though there is evidence to refute each of the Defendant's false statements and accusations." (footnote 3 on page 6)
- Explanation
- There are no ad hominen attacks in the Appellant's Brief and there does not exist evidence to refute Appellant's statements about Jeffrey L. Miller.
- ==================
- False statement
- "Defendant is not prohibited from traveling abroad or from the use of his passport. He simply must give notice of such travel in a manner that assures the minor child and the plaintiff-custodial parent are protected." (page 22 lines 3-5)
- Explanation
- 9 January 2015 Child Custody Order only requires the Defendant to "The defendant shall surrender his passport(s) to the Clerk and he will have to make an application to this court in the event he has any travel plans that require a passport." (http://grodnerdivorce.blogspot.com/2015/01/permanent-child-custody-order.html) There are no specific requirements.
- See pages 10-11 in Appellant's Reply Brief (17-570): http://grodnerdivorce.blogspot.com/2018/01/coa17-570-appellant-reply-brief.html, and pages X-X in Appellant's Amended Reply Brief (17-813) [to do]
- (todo) 2017-?-?? motion and hearing about stay of due to appeal. "Motion suggesting ... ""
- 2016-12-14 hearing in front of Judge Braddy (https://grodnerdivorce.blogspot.com/2016/12/court-hearing-hearing-on-amended-motion.html)
- False Statement
- "The Court has authority under the state law that the federal courts recognize that the, uh, uh, State Department recognizes, to place limits on parents with regards to travel with their children."
- Explanation: See part part from 7 August 2018 Opinion (https://grodnerdivorce.blogspot.com/2018/08/coa17-570-and-coa17-813-opinion-7.html)
- "exercising jurisdiction over the property of a foreign sovereign nation is not within the jurisdiction of state courts."
- Consequence: I cannot travel abroad.
- (todo) 201?-?-?? hearing in front of Judge Braddy, about mental record, Miller said that he did not review but he earlier admitted that he did. Also lied that there was ever seal. Judge Braddy also lied that he sealed it.
- (todo) 2014-8-26 hearing in front of Judge Braddy, custody matter, about mental record of Plaintiff. Miller said that record is irrelevant and that he sees nothing importnant in it.
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