Fraud upon the court

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Fraud upon the court

Fraud upon the courtFraud upon the courtFraud upon the court
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Facts vs. Deception

 When the record is this complex, stories get twisted.

Below are five of the most common claims made by opposing counsel — and the verified facts that contradict them.

Each theme draws directly from court filings, trial transcripts, and exhibits already in the public record.

Who Really Caused the Cost to Escalate

 The more they concealed, the more I had to prove.


From the outside, they blamed me for dragging the case out. The record says the opposite.


Every major cost increase traces back to misconduct by opposing counsel not delay, but concealment. When Glassman and Milfeld began working with undisclosed experts and withholding unredacted records, the case slowed because it had to. The extra motions, objections, and disclosures weren’t resistance; they were cleanup.


  • May–June 2023: Glassman secretly coordinated with Freedberg and Six Consulting while billing under the pretense of joint-expert compliance.
     
  • June 16 2023: They filed the false witness disclosure naming Freedberg as my expert, forcing months of procedural correction.
     
  • July 17 2023: They served Exhibits JJ and OO “for service only,” introducing new income figures ($197,200) that were never authenticated under C.R.E. 702.
     
  • August 21 2023: Exhibit III - a heavily redacted billing invoice  was filed less than 48 hours before trial, hiding who created those reports and when.
     

Each event triggered necessary motions, not obstruction. The hours and filings that followed were the cost of uncovering what should never have been hidden.


Even after trial, the cycle repeated. Exhibit DD reintroduced the same falsified numbers in 2025, and when I sought to cross-examine Freedberg, Glassman invoked Rule 50 to block it  a jury rule, misapplied to a bench hearing.


The truth:

They created the confusion, then billed me for responding to it.

The cost didn’t rise because I fought it rose because they cheated.

Burden of Debt

They framed obligation as generosity.


While Alyson claimed financial hardship, her legal fees were paid almost entirely from Tool Studios’ business accounts corporate funds belonging to the company, not to her personally. Exhibit III and trial testimony confirm that Tool Studios covered over $80,000 of her legal expenses, despite her lack of ownership in the business.


The Court was led to believe that these transfers reflected Alyson’s personal debt or sacrifice. In reality, the money came from the same bank accounts that formed the core of the company’s valuation—assets already accounted for in the business value assigned to you.


The Harkness correspondence (April 25, 2023) makes clear that Tool Studios’ worth was determined almost entirely by its asset base, not its income. Harkness explicitly noted that the company’s value was “based on the assets (rather than the income) of the business,” with only a small adjustment for goodwill. That means any cash in Tool Studios’ accounts was part of its business value not marital cash to be re-spent.


By treating those funds as marital property, opposing counsel double-counted the same money: once as business value and again as liquid funds used for Alyson’s benefit. What the Court saw as her burden of debt was actually company capital moved off-books—a false act of generosity built on misrepresentation of ownership and value.

Tool Studios’ “Large Client”

once-in-a-generation client turned into a permanent fiction.


During trial and in Freedberg’s reports (Exhibits JJ and OO), the 2020 Trulieve contract was portrayed as proof that Tool Studios could consistently attract multimillion-dollar clients. That single claim drove the Court’s view of the company’s earning potential and inflated its valuation.


The truth is simple: Trulieve was a one-time spike, not a trend. In my deposition (Exhibit QQ, p. 76 lines 16–19), I stated clearly, “I’ve gotten maybe six or seven clients like that in twenty-one years… I can’t predict that one.” I was referring to steady, long-term clients like TelyRx—not Trulieve.


Freedberg twisted that testimony to suggest those rare events were routine. His Schedule 3 weighted 2020 the Trulieve year equally with other years, tripling reported income and producing a valuation nearly $100,000 higher than the joint expert’s verified figure. Co-counsel Nelissa Milfeld then reinforced that false framing at trial by asking, “How often did you get a client like Trulieve?” implying recurrence where none existed.


The Harkness valuation (Exhibit NN) had already acknowledged that Tool Studios’ worth lay in its assets and systems, not in unpredictable windfalls. But by converting a once-in-a-generation client into a supposed pattern, opposing counsel created a fictional growth model that the Court ultimately adopted.

What they called “evidence of future potential” was actually a manipulated outlier, used to rewrite the company’s history and justify an inflated equalization payment.

Freedberg’s Lies

 An expert who appeared, but never owned his work.


Jay Freedberg’s name was attached to three separate reports—Exhibits JJ, OO, and DD—yet in none of them did he sign, authenticate, or accept responsibility. The reports were introduced as if expert-vetted under C.R.E. 702, but Freedberg never provided the disclosures required by Rule 26(a)(2)(B).


At the August 2023 trial, he took the stand but stopped short of endorsing any analysis or valuation attributed to him. His testimony, captured in Exhibits AA and AAA, confirms that he never adopted those reports or acknowledged authorship. Despite that, the Court relied on his name and numbers when setting income and valuation findings in the Permanent Orders.


Two years later, during the June 11 2025 remand hearing, the pattern repeated. The new report (Exhibit DD) recycled the same fabricated data, but this time Freedberg’s cross-examination was blocked by Rule 50—a rule meant for jury trials, not bench hearings. The misuse of that rule shielded him from any challenge and let the unauthenticated report stand untested.


Across both proceedings, Freedberg functioned not as an expert witness but as a mechanism of disguise. His limited appearances and deliberate non-adoption kept false data in the record while sparing him the accountability that comes with expert testimony. His silence wasn’t neutrality—it was strategy.

Milfeld’s Set-Up

Redaction used as erasure and timing as cover.


The filings showed two lawyers.

The billing shows one running the show, and another inserted when useful.

Exhibit III-UR now confirms that Nelissa Milfeld was active long before the Court knew she had joined the case.

  • March 27 2023: She billed an hour revising a motion under C.R.S. 14-10-127 nearly three months before her formal Entry of Appearance.
     
  • June 2 2023: She met with Carol Glassman “regarding case.”
     
  • June 5–8 2023: She exchanged emails with you, reviewed the Confidential Mediation Statement, and drafted deposition questions totaling more than two hours.
     
  • June 11 2023: She finally drafted and filed her Entry of Appearance.
     
  • June 12–14 2023: She logged a 4.8-hour strategy meeting with Glassman to finish deposition questions and review witness disclosures.
     

Two days later, on June 16 2023, the Co-Petitioner’s Witness Disclosure was filed, falsely naming Jay Freedberg as your expert  the single act that enabled the later falsified reports and the $197,200 income figure .


Her July 6 2023 deposition (Exhibit QQQ) shows she questioned you about that very filing, confirming she either prepared or reviewed it. After that, her time entries vanish. In the redacted version (Exhibit III), her June work is blacked out  removing the only evidence that she stopped before the July 12–17 period when the false numbers were generated.


By March 2025, Milfeld suffered a catastrophic paragliding accident and was hospitalized for eight weeks. Despite six requests to correct the record, Glassman has refused. Milfeld’s name remains on every pleading, giving the Court the illusion that two attorneys continue to manage the case.


The record now reads as deliberate sequencing: Milfeld worked off-record before her appearance, helped draft the June 16 disclosure, questioned you about it on July 6, then disappeared. The later redactions erased both her early, undisclosed work and her later absence.


Redaction here wasn’t about privilege  it was about control of the timeline.


Verified source: Nelissa Milfeld – Paragliding Accident (March 2025)
“The record shows undisclosed participation by counsel constituting substantive representation and billing prior to appearance, contrary to C.R.C.P. 121 §1-1 and Colo. RPC 3.3(a)(1), 5.5, and 8.4(c).”

Silver Bullets

Procedural fraud Summary (pdf)

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One Expert one Report (pdf)

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Silver Bullet False Witness Disclosure (pdf)

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Exhibit III in it's un redacted form (pdf)

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Key evidence

01-A - Biding Order One Expert one Report (pdf)

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01B - Contradiction Two Experts Two reports (Permanent Orders) (pdf)

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01-C. Silver Bullet False Witness Disclosure (pdf)

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01-D - Exhibit III-UR pp. 31–33 (pdf)

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01-D - Rule Book - Case Management Order - 21 Day rule (pdf)

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Mildfred's Redactions (pdf)

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Exhibit III - Redaction (pdf)

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Exhibit III-UR - Un redacted (pdf)

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The High Benchmark of Fraud Upon the Court (pdf)

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Reports

Disclosure Irregularities (pdf)Download
III vs III-UR (pdf)Download
Concealment - Report (pdf)Download
Disclosure Irregularities (pdf)Download
Large Client vs.Once-in-a-Gen (pdf)Download
Deposition Probing (pdf)Download
09. Concelement-Report pdf (pdf)Download
00. Forensic Report (pdf)Download
00. Threat (July 15th offer) Evidence to why this went to trail. (pdf)Download
25. Aug 25th - with draw (pdf)Download

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