08-3187 Volume Appendix15.pdf - Medical Supply Chain

made by the respondent that would have resulted in the loss of the petitioner’s
property.
68. The danger now is that the respondent will again take additional actions
to secure a dismissal through fraud of the petitioner’s remaining state law
breach of contract, breach of fiduciary duty, tortuous interference and trade
secret claims to conceal misconduct the respondent witnessed and did not report
or participated in and otherwise act out of an interest in the outcome of the
litigation.
E. Respondent’s Previous Misuse of the Kansas District Court Clerk’s Office
69. The respondent permitted judicial law clerks to make use of the Office of
the Kansas Clerk of the Court to attempt to manufacture a further ethics complaint
against the petitioner’s counsel to deprive the petitioner of representation.
70. This was done because the petitioner witnessed the state disciplinary
proceedings were failing to charge the petitioner’s counsel with anything but the
conduct the Kansas Rules of Professional Ethics clearly required.
71. The second concern was that the respondent’s magistrate who had used an
unrelated case before another Kansas District Court Judge involving the
petitioner’s counsel had made a mistake at law in targeting the petitioner.
72. The petitioner’s antitrust and racketeering complaint averred the conduct
that ultimately resulted in depriving the petitioner of counsel including the
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08-3187 Medical Supply Chain vs. Neoforma Volume XV 5716