Freedberg's Attorney

CONFIDENTIAL SETTLEMENT COMMUNICATION (C.R.E. 408)

Mr. Seelman and Mr. Farrall,

Mr. Seelman, I am directing this correspondence to your attention because it contains formal notice of a finalized OARC complaint against Lewis Brisbois attorneys Adam Wiens and Ryan Dunn. Firm management must be apprised of the attached sworn evidence and the resulting ethical exposure.
Mr. Farrall, I am submitting this demand directly to biBERK Claims. Because I am proceeding pro se, I am not bound by the communication restrictions (Colo. RPC 4.2) that govern opposing counsel. I am not required to exclusively navigate through defense attorneys who engage in hostile, obstructive communication and who deliberately withhold material settlement offers from their client's carrier

1. Ignored Offers, Unprofessional Conduct, and Direct Carrier Notice 

Over the past several months, I have provided your firm with multiple good-faith opportunities to resolve this matter. Instead of substantive legal rebuttal, those offers have been met with silence, the deliberate withholding of appearances, and unprofessional, verbally abusive rhetoric designed to deflect from the evidence.
Given Mr. Wiens’s documented history of intercepting communications and dismissing legitimate settlement offers without basis, I am exercising my right to submit this demand directly to the carrier. I formally request that Mr. Wiens or firm management affirmatively confirm by reply email that this correspondence and its attachments have been successfully added to Robert Farrall's claim file. Because of your firm's refusal to address the objective record, Mr. Freedberg is now left completely vulnerable to the attached, newly executed sworn filings.

2. The "Binary Fraud" and Practicing Outside the Law

As detailed in the attached OARC complaint, your firm has stepped outside the bounds of lawful advocacy. You successfully engineered a civil dismissal by claiming Mr. Freedberg was protected by "stipulated expert immunity." Yet, you sat on a written confession to DORA admitting that the foundational expert designation was a "typographical and clerical error." Furthermore, the newly acquired, sworn C.R.E. 902(11) affidavit from Attorney John Gaddis (Exhibit 70) and the Verified Forensic Report (Exhibit 16) legally establish that Mr. Freedberg's introduction into the underlying case was procured through a fabricated procedural history and the subversion of a binding court order.

3. The Omitted May/June Invoices and the June 11th Courthouse Blockade

In procuring your $4,208.50 attorney fee award, your firm selectively omitted the May and June 2025 billing invoices from the 3. The Omitted May/June Invoices and the June 11th Courthouse Blockade In procuring your $4,208.50 attorney fee award, your firm selectively omitted the May and June 2025 billing invoices from the Court's review. When I requested these ledgers to verify the fee request, Mr. Wiens explicitly refused to provide them.

The deliberate suppression of these specific months creates a highly adverse inference. It strongly suggests that those concealed ledgers document Mr. Wiens's physical presence at the courthouse and his active, cross-jurisdictional coordination with Ms. Glassman during the June 11, 2025 domestic hearing. If the hidden June ledgers confirm Mr. Wiens was present in or immediately outside the courtroom helping orchestrate the Rule 41 dismissal weaponizing my ADA accommodations to force a premature rest and shield Mr. Freedberg from cross-examination he ceases to be mere defense counsel. He becomes an active participant in a coordinated fraud upon the tribunal.

This raises a critical coverage and compliance question directly for Mr. Farrall at biBERK: If I have not been permitted to see the unredacted May and June invoices, and the reviewing judge was not permitted to see them, has biBERK seen them? More importantly, did biBERK pay Lewis Brisbois for billing entries that were deliberately concealed from a Colorado District Court because they would have exposed active participation in the suppression of evidence? I invite biBERK to independently audit these specific ledgers.

4. Global Resolution Offer & Financial Demand
I am offering an opportunity for a global walk-away that concludes Mr. Freedberg's involvement, stops the exposure of the underlying forensic data, and neutralizes your firm's regulatory and malpractice exposure.

• In exchange for a one-time settlement payment of $250,000.00*, I will:
• Execute a global release of all civil claims against Mr. Freedberg, Mr. Six, and Lewis Brisbois;
• Formally withdraw my DORA complaints against Mr. Freedberg and Mr. Six;
• Refrain from filing the attached OARC complaint against Mr. Wiens and Mr. Dunn; and
• Stipulate to the vacatur of the $4,208.50 fee award.

I am not setting an arbitrary calendar deadline for your response. However, please be advised that I am currently awaiting the final executed signatures on the sworn C.R.E. 902(11) affidavits from Attorney John Gaddis and the Court-appointed Joint Expert, Mr. Jeremy Harkness that both have agreed to.

Please find attached a formal PDF copy of this demand for your firm's internal records and compliance files.

Mr. Seelman or Mr. Farrall, I would appreciate a call and your responses to the attached document by Midday Monday. 

Respectfully,

Charles R. BellPlaintiff, Pro Se (ADA Accommodations on File)