The following individuals are named because, in my opinion and based on documentary evidence filed across multiple divisions of the 20th Judicial District, they have participated in or enabled conduct that constitutes fraud upon the court under Colorado law. Each person listed below has been given repeated opportunities to respond. None have done so. Each remains welcome to submit a verified statement or factual rebuttal for publication, consistent with the guidelines outlined in the site’s legal disclaimer.
Filed Exhibit III less than 48 hours before trial, redacted billing authorship, and used it to imply $91,000 in unpaid fees.
Directed questioning that misled the tribunal about the financial burden of legal fees (“Turn to Exhibit III…”), resulting in a duplicative $15,000 award.
Knowingly withheld disclosure of her role in preparing false filings and failed to correct the record after contradictions were shown in open court.
Filed Exhibit III less than 48 hours before trial, redacted billing authorship, and used it to imply $91,000 in unpaid fees.
Asked Alyson to “turn to Exhibit III” and testified to facts contradicted by her own July 14, 2023 email stating Tool Studios paid all fees.
Filed July 17, 2023 expert reports under Freedberg’s name, in violation of the court’s “one expert, one report” order.
Invoked Rule 50 to prevent cross-examination of subpoenaed expert Freedberg at the June 11, 2025 hearing.
Invoked Rule 50 to prevent cross-examination of subpoenaed expert Freedberg at the June 11, 2025 hearing.
Filed misleading submissions in multiple divisions (5, M, 14) to exploit case backlog and ADA accommodations.
Permitted reports (JJ, OO, DD) to circulate under his name though unsigned, unfiled by him, and never defended in testimony.
Allowed his name to be used on expert reports filed after the disclosure deadline, in violation of C.R.C.P. 26(a)(2)(B).
Permitted reports (JJ, OO, DD) to circulate under his name though unsigned, unfiled by him, and never defended in testimony.
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Refused to clarify authorship or data source despite clear misrepresentations made in his name to multiple tribunals.
Did not fulfill ethical obligation to report professional misconduct once aware of the falsified record.
After being placed on notice that his July 2023 reports (Exhibits JJ and OO) were filed under false pretenses and without authorization, Mr. Freedberg nevertheless permitted a second report (Exhibit DD, April 2025) to be prepared and submitted using his name.
Once the fraud was raised, Mr. Freedberg and his counsel (GRSM) refused to clarify authorship or endorse either report, despite subpoenas and direct requests for confirmation.
Their silence obstructed the court’s ability to verify authenticity, a violation of Colo. RPC 8.3(a) (duty to report professional misconduct) and an ongoing act of fraud by omission.
Knowingly presented herself as personally responsible for over $91,000 in attorney fees despite sworn financial statements showing only $20,886 outstanding and contemporaneous records confirming Tool Studios, LLC paid the fees. This deception misled both the trial and appellate courts into awarding duplicative attorney fees.
Violates Colo. RPC 3.3(a)(1) (false statement to a tribunal) and C.R.C.P. 11 (false factual certification).
Failed to disclose the $10,000 transfer from Tool Studios into her personal account following trial, corresponding to the same invoice her counsel asked the court to compel payment for.
Participated in filing sworn financial statements understating her own income while inflating Petitioner’s income through misclassified S-Corp distributions.
Sed selective disclosure and testimony to portray Petitioner as erratic, uncooperative, and the source of litigation costs despite her own control over company finances and payment of counsel.
This behavior constituted intentional judicial gaslighting, weaponizing perception to distort the court’s understanding of fact and motive.
Violates C.R.C.P. 16.2(e)(10) (duty of full and fair disclosure in domestic cases) and Colo. RPC 8.4(d) (conduct prejudicial to the administration of justice).
Encouraged friends and community members to attend proceedings and present themselves as neutral supporters, despite being briefed on a false narrative of abuse and misconduct.
This act amplified reputational harm and contributed to undue influence on the tribunal through external pressure and mischaracterization.
Violates Colo. RPC 3.5(a) (improper influence on tribunal) and supports the pattern of fraud upon the court.
Encouraged friends and community members to attend proceedings and present themselves as neutral supporters, despite being briefed on a false narrative of abuse and misconduct.
This act amplified reputational harm and contributed to undue influence on the tribunal through external pressure and mischaracterization.
Violates Colo. RPC 3.5(a) (improper influence on tribunal) and supports the pattern of fraud upon the court.
Did not fulfill duty to report professional misconduct of opposing counsel or client under Colo. RPC 8.3 and 3.3 once aware of the falsified filings.
Did not fulfill duty to report professional misconduct of opposing counsel or client under Colo. RPC 8.3 and 3.3 once aware of the falsified filings.
Gordon Rees Scully Mansukhani
William Dewey - wdewey@grsm.com
John Palmeri - jpalmeri@grsm.com
Mills Halstead Zaloudek, LLC
Micheal Mills - mfm@mhzlegal.com
Goff & Goff
Katie Goff - Katie@goff-law.com
Harris Family Law
Katy O. Ellis - kellis@harrisfamilylaw.com
Ben Collett - collettlaw@gmail.com
Strickler Catlin, LLC
Lee Strickler - strickler@coloradolaw
Lewis Brisbois Bisgaard & Smith LLP
Filed a limited appearance and objection on behalf of expert Jay E. Freedberg simultaneously, avoiding the required conferral under C.R.C.P. 121 §1-15(8). Refused multiple good-faith requests before and after the June 11, 2025 hearing to confirm representation or expert availability, concealing the relationship and participation in proceedings where Rule 50 was used to block cross-examination.
Did not fulfill duty to report professional misconduct of opposing counsel or client under Colo. RPC 8.3 and 3.3 once aware of the falsified filings.
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