OARC Fillings: Understanding the Impacts of Fraud upon the Court

Opposing counsel falsely claimed in their court filings that Charles Bell had retained forensic accountant Jay Freedberg as his rebuttal expert in a June 16, 2023 disclosure. This assertion was untrue: Bell never hired Freedberg, and had no knowledge of this filing until much later, raising concerns about potential expert witness fraud. Furthermore, this situation may warrant an OARC Complaint.

This false disclosure created the appearance of expert neutrality, which enabled Co-Petitioner to introduce unsigned, unauthenticated reports as part of the court filings, concealing their improper origin and raising concerns about expert witness fraud related to the OARC Complaint.

June 16, 2023, court filings include the Witness Disclosure (Exhibit 5) and Expert Exhibits JJ and OO (Exhibits 8 & 9). These documents highlight potential expert witness fraud and reveal contradictions in the witness CV and timeline (Exhibit 6), which may be relevant to the ongoing OARC Complaint.

C.R.C.P. 26(a)(2), C.R.E. 702, Colo. RPC 3.3(a)(1), 3.4(c), and 8.4(c) are essential guidelines to consider when preparing court filings, especially in cases involving expert witness fraud and OARC Complaint procedures.

The parties had agreed—and the court ordered—that only one joint expert and one expert report would be allowed in the court filings. No second expert could appear without prior approval. However, after that order, Co-Petitioner introduced a second expert (Freedberg) without permission, citing JJ, OO, and later Exhibit DD, despite these not being formally admitted through proper expert procedures, raising concerns about potential expert witness fraud related to the OARC Complaint.

This maneuver violated the agreed-upon trial structure and misled the Court, as it involved unauthorized expert witness fraud. The court filings included these unauthorized expert reports, which were used to inflate income and support attorney fee claims, leading to an OARC Complaint.

On January 31, 2023, the Joint Expert Order was issued (Exhibit 1), alongside the JJ and OO court filings documented in Exhibits 8 and 9. Additionally, Exhibit DD was filed but never authenticated (Exhibit 13), which is pertinent in the context of the ongoing OARC Complaint regarding expert witness fraud. Furthermore, the hearing conducted on June 11, 2025, is detailed in Exhibit 14.

Violations of trial stipulation, expert witness fraud, and issues related to court filings can arise under C.R.C.P. 16.2(e) and C.R.E. 702, potentially leading to an OARC Complaint.

Just 48 hours before trial, Co-Petitioner submitted Exhibit III, a heavily redacted billing invoice, which raises concerns similar to those found in expert witness fraud cases. This document was never admitted into evidence or tested under voir dire, yet it was later used to justify $15,000 in fees (which were later reversed on appeal) and to suggest work by Freedberg. The redactions concealed key authorship and coordination during the critical period of July 12–17, 2023. Notably, the unredacted billing records (Exhibit III-UR) only cover activity through June 30, 2023, leaving entries for July and August missing, which may be relevant to the OARC Complaint.

The concealment of billing authorship in the court filings prevented the Petitioner from uncovering the identity of the actual report authors and rebutting income fabrication during trial. These omissions corrupted the evidence record and raised concerns about expert witness fraud, which were reflected in the OARC Complaint.

Exhibit III – Redacted Trial Invoice (Exhibit 10), a key element in the court filings related to the ongoing investigation into expert witness fraud. Exhibit III-UR – Partial unredacted version (Exhibit 12) provides further insights, while Exhibit 23 – Visual reconstruction of missing billing entries is crucial for understanding the OARC Complaint.

C.R.C.P. 26(e), C.R.C.P. 121 § 1-12, Colo. RPC 3.4(a), 3.3(a)(1), 8.4(c) are all critical references when addressing court filings, particularly in cases involving expert witness fraud or when preparing an OARC Complaint.