California Bar Complaint Against Miles Ehrlich

California Hear Ye! Hear Ye!

On May 9, 2005, prior to his resign­ing from the Department of Justice, Miles Frederick Ehrlich obtained infor­ma­tion regard­ing crim­i­nal activ­ity engaged in by Marcia Hatch (a/k/a Marcia Bruggeman, Marsha Hatch and Marsha Bruggeman of Heller Ehrman–  she’s cur­rently a “part­ner” with Gunderson Dettmer),  her hus­band, Seamus Hatch and Mr. Hatch’s busi­ness part­ner—Michael Bock (a/k/a Douglas Bock, Michael Bock and Mike Bock) of Littleton, Colorado, among oth­ers, from Jon Goodwin.  According to Goodwin’s com­plaint the nature of the crim­i­nal activ­ity he reported to Ehrlich included: nar­cotics traf­fick­ing, con­spir­acy to laun­der money, iden­tity theft, theft of elec­tronic infor­ma­tion, fraud and bribery of judi­cial offi­cials.

Subsequent to leav­ing the US Attorney’s San Francisco office, Ehrlich estab­lished a pri­vate crim­i­nal defense law prac­tice (Ramsey Ehrlich) in Berkeley, California and there­after began pro­vid­ing advice to Marcia Hatch and Seamus Hatch to assist them to avoid inves­ti­ga­tion and pros­e­cu­tion for the ille­gal acts Goodwin informed Ehrlich about while he was employed by the US Attorney’s office as a fed­eral pros­e­cu­tor. The fore­go­ing indi­vid­u­als have employed tac­tics of extor­tion intim­i­da­tion, threat­en­ing and mis­lead­ing behav­ior in order to dis­suade, pre­vent and under­mine Goodwin’s attempts to com­mu­ni­cate with law enforce­ment offi­cials regard­ing the crim­i­nal activ­i­ties he orig­i­nally reported to Miles Ehrlich.

The fol­low­ing com­plaint was filed with the California Bar a/k/a Cal Bar regard­ing for­mer Assistant U.S. Attorney Miles Ehrlich of Ramsey Ehrlich con­cern­ing his rep­re­sen­ta­tion of Marcia Hatch , as a crim­i­nal defense attorney.

Complaint

Mr. Scott J. Drexel, Chief Trial Counsel
Ms. Lisa Stowe, Complaint Analyst

Audit and Review Office of the Chief Trial Counsel
The State Bar of California
1149 South Hill Street
Los Angeles, California 90015–2299

In Re: Inquiry Number: 07–23109 Respondent: Former Assistant U.S. Attorney Miles Frederick Ehrlich; California Bar Number 237954.

Dear Mr. Drexel and Ms. Stowe:

I received your response to my com­plaint regard­ing for­mer Assistant United States Attorney Miles Frederick Ehrlich who resigned his posi­tion with the Department of Justice (here­inafter referred to as the “DOJ”) some­time dur­ing the Fall of 2005.

You state your response is pred­i­cated on the fact that Mr. Ehrlich didn’t rep­re­sent me and there­fore there is no con­flict of inter­est. That’s not at all dis­pos­i­tive of the issues I evi­denced to the State Bar of California. And given the acts under­ly­ing the com­plaint, com­mit­ted by Miles Ehrlich, his client(s) and their cohorts, are crim­i­nal in nature, very disturbing.

I hereby request that the Audit and Review Office of the Chief Trial Counsel of the State Bar of California review my July 31, 2007 com­plaint in light of the fur­ther infor­ma­tion and analy­sis pro­vided herein.

* * * * *

The Office of the Chief Trial Counsel needs to look at this case from a pedes­trian per­spec­tive. Herewith is a syn­op­sis of the facts:

1. A crime vic­tim and wit­ness reports the iden­ti­ties and crim­i­nal activ­i­ties (includ­ing nar­cotics traf­fick­ing, money laun­der­ing, fraud, brib­ing for­eign judi­cial offi­cials and con­spir­acy) to a fed­eral prosecutor.

2. The fed­eral pros­e­cu­tor appar­ently did not act on the victim’s report.

3. Six months after the victim’s report the fed­eral pros­e­cu­tor resigned from the Department of Justice.

4. Thereafter, the vic­tim dis­cov­ers, coin­ci­den­tally, that the for­mer fed­eral pros­e­cu­tor is rep­re­sent­ing, as a crim­i­nal defense attor­ney, one of the par­ties the vic­tim iden­ti­fied to the for­mer fed­eral pros­e­cu­tor as engaged in the crim­i­nal activ­ity and is pro­vid­ing advice and coun­sel to at least one of sev­eral of the other perpetrators.

5. And that the for­mer fed­eral pros­e­cu­tor is col­lud­ing with oth­ers, wag­ing a cam­paign of intim­i­da­tion against the vic­tim; employ­ing, threats, harass­ment and mis­lead­ing tac­tics to dis­suade and under­mine his attempts to engage law enforce­ment offi­cials enabling his client, her hus­band and their cohorts to evade prosecution.

6. The vic­tim reports the fore­go­ing activ­ity to the State Bar of California. Because a large, influ­en­tial law firm, is in the midst of the case, the State Bar of California attempts to dis­suade the vic­tim from fur­ther­ing his com­plaint by inten­tion­ally mis­in­ter­pret­ing the facts?

* * * * *

The case of Miles Ehrlich’s suc­ces­sive rep­re­sen­ta­tion of adverse inter­ests first in the role of a fed­eral pros­e­cu­tor and there­after as a crim­i­nal defense attor­ney not only “appears” improper, it is improper. Particularly because Miles Ehrlich was in a posi­tion of author­ity (as a gov­ern­ment pros­e­cu­tor and law enforce­ment offi­cial) that enabled him not to pur­sue inves­ti­gat­ing and pros­e­cut­ing the client(s) he’s cur­rently representing.

* * * * *

The crim­i­nal activ­i­ties I reported to Miles Ehrlich (the fed­eral pros­e­cu­tor) directly affect mul­ti­ple vic­tims includ­ing the gov­ern­ment of a for­eign coun­try (India), an ally of the United States. By def­i­n­i­tion, crim­i­nal activ­ity affects soci­ety as a whole, in this case the People of the United States and the State of California. Moreover, a fed­eral pros­e­cu­tor, who’s sworn to up hold the Constitution and the pub­lic trust must not be allowed to engage in rep­re­sent­ing per­sons iden­ti­fied to him as com­mit­ting crim­i­nal acts in con­tra­ven­tion to laws of the United States, after leav­ing gov­ern­ment ser­vice; oth­er­wise, crime vic­tims, wit­nesses and infor­mants will be ret­i­cent to report crim­i­nal activ­ity out of fear (1) they will be retal­i­ated against; and (2) their inter­ests have been sold to the higher bidder.

“As offi­cers of the court with respon­si­bil­i­ties to the admin­is­tra­tion of jus­tice, attor­neys have an oblig­a­tion to be pro­fes­sional with clients, other par­ties and coun­sel, the courts and the pub­lic. This oblig­a­tion includes civil­ity, pro­fes­sional integrity, per­sonal dig­nity, can­dor, dili­gence, respect, cour­tesy, and coop­er­a­tion, all of which are essen­tial to the fair admin­is­tra­tion of jus­tice and con­flict res­o­lu­tion.” See: California Attorney Guidelines for Civility and Professionalism, The State Bar of California, July 20, 2007, p. 3.

The pub­lic trust is at stake.

Miles Ehrlich rep­re­sented the People of the United States of America, which I am one, when he obtained from me sen­si­tive, con­fi­den­tial infor­ma­tion regard­ing crim­i­nal acts com­mit­ted by the indi­vid­u­als and enti­ties I iden­ti­fied to him on May 9, 2005. Which indi­vid­u­als and enti­ties have inter­ests that are mate­ri­ally adverse to the inter­ests of the People of the United States of America, the People of the State of California, and other vic­tims, includ­ing me and the Republic of India, a sov­er­eign nation. Before? After leav­ing his posi­tion, as an Assistant United States Attorney (here­inafter “AUSA”), Miles Ehrlich has pro­vided advice and coun­sel to at least one of the indi­vid­u­als I iden­ti­fied to him, Marcia Ann Bruggeman Hatch. And, as evi­denced in my July 31, 2007 com­plaint, has obvi­ously pro­vided advice and coun­sel to Marcia Bruggeman Hatch’s hus­band, Seamus John Paul Hatch regard­ing the same or sub­stan­tially sim­i­lar mat­ters in which he rep­re­sented the peo­ple of the United States of America as an AUSA.

As a vic­tim and a U.S. cit­i­zen i.e., one of the People of the United States of America, I expect that law enforce­ment author­i­ties and gov­ern­ment pros­e­cu­tors will not assist the very crim­i­nals I iden­ti­fied to them to evade jus­tice and con­tinue to harm the vic­tims of their crim­i­nal behav­ior. Yet this is exactly what Miles Ehrlich has done; hereto­fore with impunity.

Herewith, I’ve pro­vided addi­tional fac­tual infor­ma­tion, iden­ti­fied rel­e­vant law and pro­vided analy­sis and dis­cus­sion regard­ing Miles Ehrlich’s clear breaches of his pro­fes­sional oblig­a­tions and the law.

FACTS

Let’s review the facts I evi­denced to you in my July 31, 2007 Complaint:

1.  On May 9, 2005 while Miles Ehrlich was employed as an AUSA in the U.S. Attorney’s San Francisco office, he obtained highly sen­si­tive, con­fi­den­tial infor­ma­tion from me, including:

(a) details regard­ing crim­i­nal activ­ity, specif­i­cally: nar­cotics traf­fick­ing, con­spir­acy to laun­der money, iden­tity theft, theft of elec­tronic infor­ma­tion, fraud and bribery of judi­cial offi­cers in the Republic of India;

(b) the iden­ti­ties of the enti­ties and indi­vid­u­als var­i­ously involved in the fore­go­ing activ­i­ties, specif­i­cally: Heller Ehrman LLP, Marcia Ann Bruggeman Hatch, Esq. (an employee of Heller Ehrman LLP), a cohort of Marcia Bruggeman Hatch’s, “Scottie” who pur­port­edly heads a nar­cotics traf­fick­ing ring, Seamus John Paul Hatch (a cit­i­zen of the United Kingdom who is Marcia Bruggeman Hatch’s hus­band), Michael Douglas Bock (Seamus Hatch’s ‘busi­ness part­ner’) and Aran Strategic Finance LLC, a com­pany owned by Michael Bock and Seamus Hatch; and

© the gen­eral nature of evi­dence in my pos­ses­sion includ­ing wit­ness affidavits.

The fore­go­ing are here­inafter col­lec­tively referred to as the “May 9, 2005 Criminal Matters.”

2.  I’m a vic­tim of finan­cial and other crimes per­pe­trated by the indi­vid­u­als I iden­ti­fied to Miles Ehrlich on May 9, 2005. Other vic­tims include the People of the United States of America, the People of the State of California, sev­eral indi­vid­u­als and enti­ties as well as the sov­er­eign nation of the Republic of India.

3.  I’m a mate­r­ial fact wit­ness and infor­mant regard­ing the crimes I reported to Miles Ehrlich, a vic­tim of the reported activ­ity and a cit­i­zen of the United States of America i.e., one of “the People.”

4.  Under the direc­tion of Miles Ehrlich and other attor­neys, the per­pe­tra­tors of the crim­i­nal activ­ity I reported to Miles Ehrlich have employed tac­tics of extor­tion, intim­i­da­tion, threat­en­ing and mis­lead­ing behav­ior, in an attempt to dis­suade, pre­vent and under­mine my attempts to com­mu­ni­cate with law enforce­ment offi­cials regard­ing the May 9, 2005 Criminal Matters in order to evade inves­ti­ga­tion and pros­e­cu­tion for their ille­gal acts.

The fore­go­ing occurred both before and after I learned Miles Ehrlich was pro­vid­ing advice and coun­sel to the individual(s) I iden­ti­fied to him. I believe Miles Ehrlich’s client(s) and/or the other per­pe­tra­tors of the crimes I iden­ti­fied to him will, if given the oppor­tu­nity, mur­der me.

5.  When I com­mu­ni­cated with Miles Ehrlich on May 9, 2005 regard­ing the May 9, 2005 Criminal Matters he was admit­ted to prac­tice in Pennsylvania and mul­ti­ple Federal District Courts and Courts of Appeal, includ­ing Federal District Courts in California, in which he actu­ally prac­ticed before being admit­ted to the California Bar on October 27, 2005.

6.  During the Fall of 2005 Miles Ehrlich quit his job as an AUSA var­i­ously rep­re­sent­ing the United States gov­ern­ment and the People of the United States of America.

7.  In early 2006, Miles Ehrlich began oper­at­ing a pri­vate crim­i­nal defense law firm in Berkeley, California.

8.  In November, 2006 I dis­cov­ered, by hap­pen­stance, Miles Ehrlich had under­taken rep­re­sent­ing Marcia Bruggeman Hatch, in the capac­ity of a pri­vate crim­i­nal defense lawyer. Marcia Bruggeman Hatch is one of the indi­vid­u­als I iden­ti­fied to Miles Ehrlich on May 9, 2005 as hav­ing been a pri­mary party involved in the May 9, 2005 Criminal Matters.

9. In December, 2006 I dis­cov­ered, by hap­pen­stance, that Miles Ehrlich was pro­vid­ing advice and coun­sel to Seamus John Paul Hatch and/or Aran Strategic Finance, LLC., in the capac­ity of a pri­vate crim­i­nal lawyer. Seamus Hatch and Aran Strategic Finance, LLC were also par­ties I iden­ti­fied to Miles Ehrlich on May 9, 2005, as hav­ing been pri­mary par­ties engaged in the May 9, 2005 Criminal Matters.

Additional Facts

10.  Prior to resign­ing his posi­tion as an AUSA, Miles Ehrlich was admit­ted to prac­tice, and in fact did prac­tice law, in sev­eral Federal District Courts and Circuit Courts of Appeal, includ­ing Federal courts in California.

11.  “The United States wins its point when­ever jus­tice is done its cit­i­zens in the courts.”2 As an crim­i­nal pros­e­cu­tor, an AUSA, Miles Ehrlich rep­re­sented the People of the United States of America who elect rep­re­sen­ta­tives, pur­suant to the Constitution, to pro­mul­gate leg­is­la­tion to pro­tect their col­lec­tive and indi­vid­ual inter­ests. For fur­ther clar­i­fi­ca­tion on this see 28 C.F.R. §77.2; and “UNITED STATES ATTORNEYS,” herein.  Quotation from for­mer Solicitor General Lehmann is inscribed in the Rotunda of the Justice Department building.

12.  Subsequent to resign­ing from the United States Attorney’s office, Miles Ehrlich has con­tin­ued to prac­tice law in the Federal courts, not as a pros­e­cu­tor, but as a crim­i­nal defense attor­ney. And Miles Ehrlich became sub­ject to laws, reg­u­la­tions and rules gov­ern­ing the activ­i­ties of for­mer Government Employees and Attorneys for the Government.

13.  The indi­vid­ual Marcia Bruggeman Hatch pre­sented, to a com­pany I own an equity inter­est in, to laun­der money derived from ille­gal activ­i­ties allegedly reside(s) in Berkeley, California.

14.  Seamus Hatch, one of the par­ties involved in the May 9, 2005 Criminal Matters who I iden­ti­fied to Miles Ehrlich has a per­sonal rela­tion­ship with Nicole Barrett, an AUSA or for­mer AUSA who worked out of the San Francisco U.S. Attorney’s office.

15.  In a news arti­cle dated November 23, 2005, by Justin Scheck of The Recorder, enti­tled “Two AUSAs to Start New Trial Firm” Miles Ehrlich is quoted, stat­ing that for two years prior to resign­ing his post as an AUSA he’d been con­tem­plat­ing leav­ing and start­ing his own crim­i­nal defense prac­tice with for­mer Assistant U.S. Attorney Ismail Ramsey.

16. As a cit­i­zen of the United States and res­i­dent of California, Miles Ehrlich is sub­ject to both the United States Code and the laws of the State of California.

17. As an attor­ney licensed to prac­tice law in the State of California, Miles Ehrlich is sub­ject to the California Business and Professions Code (here­inafter referred to as the “CB&PC”), Rules of Professional Conduct of the State Bar of California and the California State Bar Act as well as numer­ous other laws, reg­u­la­tions and rules gov­ern­ing or affect­ing the prac­tice of law in California.

Note: I’m in pos­ses­sion of addi­tional evi­dence sup­port­ing my com­plaint and am very con­cerned, that evi­dence could be com­pro­mised if pro­vided directly to the State Bar of California, and not through a law enforce­ment agency with the capa­bil­ity to ana­lyze and pre­serve its pro­ba­tive value.

UNITED STATES ATTORNEYS

Pursuant to the Constitution, the People of the Untied States have del­e­gated to Congress, the leg­isla­tive branch of the United States Government, the respon­si­bil­ity of enact­ing statutes autho­riz­ing: 1) the appoint­ment of United States Attorneys by the President “with the advice and con­sent of the Senate;”3 and 2) grant­ing author­ity to United States Attorneys to inves­ti­gate and pros­e­cute crim­i­nal mat­ters affect­ing the col­lec­tive inter­ests of the People (cit­i­zens) of the United States of America.

“ The United States Attorney serves as the chief law enforce­ment offi­cer in each judi­cial dis­trict and is respon­si­ble for coor­di­nat­ing mul­ti­ple agency inves­ti­ga­tions within that dis­trict.” 4

Assistant United States Attorneys (here­inafter referred to as “AUSAs”) are appointed by the Attorney General pur­suant to 28 U.S.C. Sec. 542 and are respon­si­ble to the Attorney General and USA in their judi­cial dis­trict. Pursuant to statu­tory author­ity, USAs and AUSAs: (i) rep­re­sent the People of the United States of America as crim­i­nal pros­e­cu­tors; (ii) rep­re­sent the Executive Branch of the United States Government in civil lit­i­ga­tion; (iii) act as law enforce­ment offi­cers man­ag­ing inves­ti­ga­tions con­ducted by the Department of Justice in their judi­cial dis­tricts; and (iv) man­age per­son­nel, depart­ment finances and con­trol procurement.

The statu­tory author­ity afforded USAa and AUSAs is pur­pose­fully broad to enable them to inves­ti­gate and pros­e­cute crim­i­nal mat­ters the­o­ret­i­cally free from poten­tially cor­rupt­ing influ­ences of all branches of gov­ern­ment. “Their pro­fes­sional abil­i­ties and the need for their impar­tial­ity in admin­is­ter­ing jus­tice directly affect the public’s per­cep­tion of fed­eral law enforce­ment and lawyers for the government.”5

Under the law, crime vic­tims must rely on fed­eral, state and local pros­e­cu­tor to bring crim­i­nal cases as cit­i­zens who are pros­e­cu­tors are not per­mit­ted to bring such actions in U.S. courts. Because of the unique respon­si­bil­i­ties of a crim­i­nal pros­e­cu­tor the sphere of his rep­re­sen­ta­tion extends beyond the gov­ern­men­tal entity that employs him to the vic­tims of the indi­vid­u­als he’s pros­e­cut­ing. A crim­i­nal prosecutor’s advo­cacy is not only for the pub­lic at large, to deter crim­i­nal behav­ior, but to obtain jus­tice for crime vic­tims as well. In under­tak­ing pros­e­cu­to­r­ial action state and local pros­e­cu­tors client’s are gen­er­ally speak­ing, the cit­i­zenry of the jurisdiction(s) they serve. Even though each USA or AUSA is assigned to a par­tic­u­lar judi­cial dis­trict, they typ­i­cally pros­e­cute cases in mul­ti­ple dis­tricts. The cost of fed­eral crim­i­nal inves­ti­ga­tions and pros­e­cu­tions is born by fed­eral tax­pay­ers. And the deter­rence effect of their enforce­ment of fed­eral law ben­e­fits all of the People of the United States. Therefore, the true client of a USA or AUSA pros­e­cut­ing a crim­i­nal case are the People of the United States of America (some­times here­inafter col­lec­tively referred to as the “United States”).

3 Title 28, United States Code, Section 541.

APPLICABLE LAW

At the time I pro­vided Miles Ehrlich the May 9, 2005 Criminal Matters infor­ma­tion he was assigned to the U.S. Attorney’s office in San Francisco, California where he remained until he resigned dur­ing the Fall of 2005. Had he charged or indicted the indi­vid­u­als I iden­ti­fied to him, it would have been highly likely those cases would have been brought in the United States District Court, Northern District of California, in San Francisco. Miles Ehrlich’s rep­re­sen­ta­tion of Marcia Bruggeman Hatch and pro­vi­sion of advice and coun­sel to Seamus Hatch and/or Aran Strategic Fiance LLC has taken place in California where: 1) Miles Ehrlich, Marcia Bruggeman Hatch and Seamus Hatch reside; 2) Miles Ehrlich’s law office is located; and 3) Aran Strategic Finance, LLC main­tains an office.

“The State Bar Act found in the Business and Professions Code, Rules of Professional Conduct; var­i­ous statutes passed by the Legislature, e.g., Civil Code, Code of Civil Procedure, Corporations Code, Education Code, Evidence Code, Government Code, Penal Code, Revenue and Taxation Code, and opin­ions of the California Appellate Courts form the basis for estab­lish­ing pro­fes­sional respon­si­bil­ity and con­duct of California attor­neys. To the extent these sources do not answer a par­tic­u­lar ques­tion or solve a prob­lem, other sources are explored, includ­ing sis­ter state rules, court opin­ions, fed­eral court opin­ions and the ABA Rules of pro­fes­sional con­duct. The per­sua­sive­ness of these col­lat­eral sources should depend upon their under­ly­ing logic and his­tor­i­cal basis.” (State Bar Formal Opn. No. 1983–71.) (See, e.g., Flatt v. Superior Court (1994) 9 Cal.4th 275 at pp. 282–283; Ojeda v. Sharp Cabrillo Hospital (1992) 8 Cal.App.4th 1, 8; Goldberg v. Warner/Chappell Music, Inc. (2005) 125 Cal.App.4th 752 [23 Cal.Rptr.3d 116]; People v. Donaldson (2001) 93 Cal.App.4th 916 [113 Cal.Rptr.2d 548].)

Federal District Courts in California pub­lish local rules of court which gov­ern prac­tice before them and pro­vide therein for stan­dards of pro­fes­sional con­duct. For exam­ple, Rule 11–4 of the local rules for the Northern District of California pro­vides that the attor­ney must “[b]e famil­iar and com­ply with the stan­dards of pro­fes­sional con­duct required of mem­bers of the State Bar of California.” 6

The Rules of Professional Conduct of the State Bar of California (here­inafter referred to as the “California Rules of Professional Conduct” or “CRPC”) gov­ern mem­bers of the California Bar prac­tic­ing inside and out­side of the State of California as well as to lawyers from other juris­dic­tions who are not mem­bers of he California Bar while they are engaged in the per­for­mance of lawyer func­tions in the State of California. See CRPC Rule 1–100.

Pursuant to 28 U.S.C. §530B(a) “[a]n attor­ney for the Government shall be sub­ject to State laws and rules, and local Federal court rules, gov­ern­ing attor­neys in each State where such attor­ney engages in that attorney’s duties, to the same extent and in the same man­ner as other attor­neys in that State.” Where there is no pend­ing case, 28 C.F.R. §77.4© directs that an attor­ney for the Government “com­ply with the eth­i­cal rules of the attorney’s state of licen­sure, unless appli­ca­tion of tra­di­tional choice-of-law prin­ci­ples directs the attor­ney to com­ply with the eth­i­cal rule of another juris­dic­tion or court, such as the eth­i­cal rule adopted by the court in which the case is likely to be brought.”

In addi­tion to 18 U.S.C. §207, the American Bar Association Model Rules of Professional Conduct (here­inafter ref­er­eed to as the “ABA Rules”), and court deci­sions restrict the con­duct of attor­neys who are for­mer gov­ern­ment employ­ees and their firms and affil­i­ates. And it should be noted, there is noth­ing in 18 U.S.C. §207 which pre­vents courts and bar asso­ci­a­tions from hold­ing for­mer gov­ern­ment employ­ees to stan­dards more demand­ing than the min­i­mal require­ments of the crim­i­nal law. See 5 C.F.R. 2637.101©(9).

NATURE OF UNDERLYING ISSUES; AND RELATIONSHIPS OF THE VICTIM/WITNESS PARTIES

Narcotics traf­fick­ing is a crime under 21 U.S.C. § 841 and the Health and Safety Code Division 10: California Uniform Controlled Substances Act. Money laun­der­ing and con­spir­acy to laun­der money are fed­eral offenses under 18 U.S.C. § 1956 and under the California Control of Profits of Organized Crime Act (see sec­tion 186 of the California Penal Code). Bribing for­eign judi­cial offi­cials is a crime, under 15 U.S.C. §§ 78dd-1, et seq, the Foreign Corrupt Practices Act (1978) as amended by the International Anti-Bribery and Fair Competition Act of 1998. The fore­go­ing are con­sid­ered crimes against the People of the United States and the People of the State of California. The crimes of fraud, iden­tity theft, and theft of elec­tronic infor­ma­tion were com­mit­ted var­i­ously, against me, enti­ties in which I own inter­ests and other indi­vid­u­als. Bribing judi­cial offi­cials of the Republic of India, a sov­er­eign nation, is a crime in that country.

As averred in my July 31, 2007 com­plaint and above, I’m a cit­i­zen of the United States and a mate­r­ial fact wit­ness for the the People of the United States regard­ing the crimes I alleged to Miles Ehrlich in his capac­ity as an attor­ney for the People of the United States. For a mul­ti­tude of rea­sons, includ­ing the preser­va­tion of the public’s trust and the admin­is­tra­tion of jus­tice, it’s in the United State’s, and the State of California’s inter­est to pro­tect wit­nesses to crim­i­nal activ­i­ties affect­ing the inter­ests of citizens.

The inter­ests of the People of the State of California, the People of the United States, my inter­ests as well as the inter­ests of the other vic­tims of the crimes I reported to Miles Ehrlich, includ­ing the Republic of India are, closely allied and inex­tri­ca­bly intertwined.

EXTORTING, THREATENING, HARASSING AND RETALIATING AGAINST A WITNESS / VICTIM / INFORMANT

I’m a mate­r­ial fact wit­ness, a vic­tim and infor­mant. I’m in pos­ses­sion of sig­nif­i­cant doc­u­men­tary and elec­tronic evi­dence includ­ing wit­ness affi­davits regard­ing the May 9, 2005 Criminal Matters, as well as other activ­i­ties of the indi­vid­u­als I iden­ti­fied to Miles Ehrlich on May 9, 2005 and in November 2006 to another Assistant U.S. Attorney. Miles Ehrlich is aware I reported the May 9, 2005 Criminal Matters and his client,

Marcia Bruggeman Hatch a/k/a Marica Hatch, Marsha Hatch, Marcia A. Hatch (for­merly with Heller Ehrman and Currently with Gunderson Dettmer) and the other par­ties includ­ing, Michael Douglas Bock and Heller Ehrman LLP, who I also iden­ti­fied to Miles Ehrlich are aware of my pos­ses­sion of sen­si­tive infor­ma­tion regard­ing their guilt, knowl­edge and/or com­plic­ity, as the case may be, in the May 9, 2005 Criminal Matters. Certainly, they’ve also com­mu­ni­cated to their nar­cotics traf­fick­ing asso­ciates the fact that I reported the May 9, 2005 Criminal Matters to the DOJ and pre­sum­ably know that upon dis­cov­er­ing Miles Ehrlich “switched sides” that I re-reported the May 9, 2005 Criminal Matters to the Department of Justice.

Prior to my dis­cov­er­ing, by hap­pen­stance, that Miles Ehrlich was rep­re­sent­ing Marcia Bruggeman Hatch and pro­vid­ing advice and coun­sel to Seamus Hatch or Aran Strategic Finance, LLC, his client(s) and their cohorts, act­ing in col­lu­sion, employed tac­tics of extor­tion, threat­en­ing, harass­ing, intim­i­dat­ing and mis­lead­ing behav­ior to inten­tion­ally dis­suade, hin­der, impede, delay, and pre­vent my attempts to com­mu­ni­cate with law enforce­ment offi­cials regard­ing the crimes I reported to him on May 9, 2005.

Miles Ehrlich, in col­lu­sion with his client(s), the other par­ties I iden­ti­fied to him on May 9, 2005, their agents and crim­i­nal defense lawyers, have engaged in harass­ing, intim­i­dat­ing and mis­lead­ing behav­ior to inten­tion­ally dis­suade, hin­der, impede, delay, pre­vent, malign and under­mine my attempts and the effec­tive­ness of those attempts to com­mu­ni­cate with law enforce­ment offi­cials regard­ing their crim­i­nal activity.

For the past four years, the fore­go­ing behav­ior of the indi­vid­u­als and enti­ties I com­plained about to Miles Ehrlich have dis­rupted my career, inter­fered with my liveli­hood, inter­fered with per­sonal rela­tion­ships, includ­ing my rela­tion­ship with my son and caused me to live in a con­stant state of fear, peri­od­i­cally mov­ing from location-to-location to avoid the pos­si­bil­ity of being phys­i­cally harmed by them for:

1) refusing to coop­er­ate in their ille­gal schemes and activities;

2) reporting the May 9, 2005 Criminal Matters to the DOJ; and

3) pos­sess­ing evi­dence of their crim­i­nal acts.

I have copi­ous evi­dence sup­port­ing fore­go­ing con­tentions, and addi­tional evi­dence can be obtained through inves­ti­ga­tion. Based on the per­sis­tent pat­tern of their actions, I believe Miles Ehrlich’s client(s) and/or the other per­pe­tra­tors of the crimes I iden­ti­fied to him will, if given the oppor­tu­nity, mur­der me.

Discussion

California Penal Code ¤ 136 “Intimidation of Witnesses and Victims; Offenses; Penalties; Enhancement; Aggravation” as well as 18 U.S.C. §§ 1512; 1513, “Tampering with a wit­ness, vic­tim, or an infor­mant” and “Retaliating against a wit­ness, vic­tim, or an infor­mant,” respec­tively crim­i­nal­ize the activ­i­ties, Miles Ehrlich, his crim­i­nal defense attor­ney col­leagues, his client(s) and their cohorts, whom I iden­ti­fied to Miles Ehrlich on May 9, 2005 have engaged in against me, my inter­ests as well as the inter­ests of the other indi­vid­ual and entity vic­tims includ­ing the United States and the State of California.

Confederating, in con­tra­ven­tion to California Penal Code ¤ 182 and 18 U.S.C. § 371 Miles Ehrlich, his crim­i­nal defense attor­ney coun­ter­parts, his client(s) and their cohorts have per­verted or obstructed jus­tice and the due admin­is­tra­tion of laws in order to evade pros­e­cu­tion thereby cheat­ing me and other vic­tims of reme­dies to recover money and prop­erty stolen or fraud­u­lently obtained by Seamus Hatch, Michael Bock and enti­ties they con­trol. The mon­e­tary dam­ages to me alone from their ille­gal activ­i­ties exceed $25 million.

CONFIDENTIAL, NONPUBLIC AND PRIVILEGED NATURE OF THE MAY 9, 2005 CRIMINAL MATTERS INFORMATION

As averred above and in my July 31, 2007 com­plaint, act­ing in the dual capac­ity as an attor­ney and law enforce­ment offi­cial for the United States, Miles Ehrlich obtained sen­si­tive infor­ma­tion from me, a mate­r­ial fact wit­ness and vic­tim, regard­ing the May 9, 2005 Criminal Matters.

I believed the infor­ma­tion I sup­plied Miles Ehrlich would be held in con­fi­dence by him and the Department of Justice for the fol­low­ing reasons:

1) the infor­ma­tion had not been dis­sem­i­nated to the gen­eral public;

2) to my knowl­edge, an inves­ti­ga­tion into the activ­i­ties I reported to him had not commenced;

3) the infor­ma­tion detailed very seri­ous crim­i­nal activ­ity includ­ing, but not lim­ited to, the iden­tity of and links to a crim­i­nal nar­cotics traf­fick­ing orga­ni­za­tion oper­at­ing in the San Francisco Bay Area, which infor­ma­tion, if obtained by the indi­vid­u­als I iden­ti­fied to Miles Ehrlich, would be adverse to an inves­ti­ga­tion and pros­e­cu­tion by the United States of the May 9, 2005 Criminal Matters;

4) that in any event, given because I am a mate­r­ial fact wit­ness, the United States would have an inter­est in pro­tect­ing my safety and the safety of my fam­ily from those involved in the May 9, 2005 Criminal Matters.

Thus, when I divulged the May 9, 2005 Criminal Matters, I rea­son­ably expected Miles Ehrlich would main­tain the infor­ma­tion in con­fi­dence to pre­serve the United States’ inter­ests and pro­tect the rights and safety of wit­nesses and vic­tims related to the case. In fact, my rec­ol­lec­tion is that I observed to Miles Ehrlich that the infor­ma­tion was sen­si­tive, because Heller Ehrman LLP, a major law firm was involved as well as a crim­i­nal nar­cotics traf­fick­ing orga­ni­za­tion and that he should there­fore main­tain the infor­ma­tion in confidence.

The Doctrine of Law Enforcement Investigative Privilege

Insight regard­ing the DOJ’s poli­cies con­cern­ing the dis­sem­i­na­tion of infor­ma­tion regard­ing crim­i­nal activ­ity and inves­ti­ga­tions can be found in the “Frequently Asked Questions” sec­tion of the Federal Bureau of Investigation’s (here­inafter referred to as the “FBI”) website7 under the heading:

“Can I obtain detailed infor­ma­tion about a cur­rent FBI inves­ti­ga­tion I see in the news?” (empha­sis added)

To wit the response is:

“No. Such infor­ma­tion is pro­tected from pub­lic dis­clo­sure, in accor­dance with cur­rent law and DOJ and FBI pol­icy. This pol­icy pre­serves the integrity of the inves­ti­ga­tion and the pri­vacy of indi­vid­u­als involved in the inves­ti­ga­tion prior to any pub­lic charg­ing for vio­la­tions of the law. It also serves to pro­tect the rights of peo­ple not yet charged with a crime” (empha­sis added).

* * * * *

According to the DOJ’s United States Attorney’s Manual, (here­inafter referred to as “USAM”) Chapter 3–15.120 “infor­ma­tion secu­rity involves the con­trol and safe­guard­ing of Limited Official Use (LOU) infor­ma­tion… Other depart­ments and agen­cies entrust LOU infor­ma­tion… to the USAOs (U.S. Attorney’s Offices) dur­ing inves­ti­ga­tions and lit­i­ga­tion. It is impor­tant that USAOs pro­tect LOU infor­ma­tion… and any mate­ri­als devel­oped using such infor­ma­tion, in the same man­ner as the orig­i­na­tors. All LOU infor­ma­tion… must be pro­tected to pre­vent dis­clo­sure to indi­vid­u­als not autho­rized access to the infor­ma­tion” (empha­sis added).

USAM Chapter 3–15.120(A) defines Limited Official Use (Sensitive) Information, also referred to as “sen­si­tive,” and estab­lishes pro­ce­dures for its pro­tec­tion as follows:

“LOU infor­ma­tion includes, but is not lim­ited to grand jury infor­ma­tion, infor­mant and wit­ness infor­ma­tion, inves­tiga­tive mate­r­ial, Federal tax and tax return infor­ma­tion, Privacy Act infor­ma­tion, and infor­ma­tion which can cause risk to indi­vid­u­als or could be sold for profit… The infor­ma­tion should be labeled or iden­ti­fied by plac­ing the caveat ‘Limited Official Use’ on the first page, by a nota­tion in a cov­er­ing mem­o­ran­dum, or by affix­ing an LOU label or cover sheet to the mate­r­ial to ensure recip­i­ents are aware the infor­ma­tion requires pro­tec­tion. Provided the USAO has min­i­mum phys­i­cal secu­rity safe­guards in place, sen­si­tive infor­ma­tion may be stored, when not in use, in locked offices, desks, or cab­i­nets. Secure tele­phone and fac­sim­ile equip­ment should be used when­ever pos­si­ble to pro­tect sen­si­tive infor­ma­tion, par­tic­u­larly inves­tiga­tive, infor­mant, wit­ness, or Title III infor­ma­tion” (empha­sis added).

As averred herein and evi­denced in my July 31, 2007 com­plaint, I’m an infor­mant and mate­r­ial fact wit­ness who pro­vided LOU infor­ma­tion to Miles Ehrlich in his capac­ity as an attor­ney for the United States, which infor­ma­tion, accord­ing to USAM Chapter 3–15.120 the United States seeks to pro­tect from dis­clo­sure. The May 9, 2005 Criminal Matters infor­ma­tion I pro­vided Miles Ehrlich was of a char­ac­ter the United States regards not only as con­fi­den­tial but so sen­si­tive as to require the pro­tec­tion of it from indi­vid­u­als, within the DOJ and the U.S. Government, with­out author­ity to access it.

5 C. F.R. § 2635.703(b) defines non­pub­lic infor­ma­tion as infor­ma­tion that which the employee gains by rea­son of Federal employ­ment and that he knows or rea­son­ably should know has not been made avail­able to the gen­eral pub­lic. It includes infor­ma­tion that he knows or rea­son­ably should know:

(1) “Is rou­tinely exempt from dis­clo­sure under 5 U.S.C. 552 or oth­er­wise pro­tected from dis­clo­sure by statute, Executive order or regulation;

(2) Is des­ig­nated as con­fi­den­tial by an agency; or

(3) Has not actu­ally been dis­sem­i­nated to the gen­eral pub­lic and is not autho­rized to be made avail­able to the pub­lic on request” (empha­sis added).

Information of the char­ac­ter of the May 9, 2005 Criminal Matters infor­ma­tion is rou­tinely exempt from dis­clo­sure under 5 U.S.C. 552, the Freedom of Information Act.

5 U.S.C. 552(b)(7) man­dates the nondis­clo­sure of “records or infor­ma­tion com­piled for law enforce­ment pur­poses, but only to the extent that the pro­duc­tion of such law enforce­ment records or infor­ma­tion (A) could rea­son­ably be expected to inter­fere with enforce­ment pro­ceed­ings, (B) would deprive a per­son of a right to a fair trial or an impar­tial adju­di­ca­tion, © could rea­son­ably be expected to con­sti­tute an unwar­ranted inva­sion of per­sonal pri­vacy, (D) could rea­son­ably be expected to dis­close the iden­tity of a con­fi­den­tial source, includ­ing a State, local, or for­eign agency or author­ity or any pri­vate insti­tu­tion which fur­nished infor­ma­tion on a con­fi­den­tial basis, and, in the case of a record or infor­ma­tion com­piled by a crim­i­nal law enforce­ment author­ity in the course of a crim­i­nal inves­ti­ga­tion or by an agency con­duct­ing a law­ful national secu­rity intel­li­gence inves­ti­ga­tion, infor­ma­tion fur­nished by a con­fi­den­tial source, (E) would dis­close tech­niques and pro­ce­dures for law enforce­ment inves­ti­ga­tions or pros­e­cu­tions, or would dis­close guide­lines for law enforce­ment inves­ti­ga­tions or pros­e­cu­tions if such dis­clo­sure could rea­son­ably be expected to risk cir­cum­ven­tion of the law, or (F) could rea­son­ably be expected to endan­ger the life or phys­i­cal safety of any indi­vid­ual” (empha­sis added).

5 U.S.C. 552©(1) pro­vides an exemp­tion to the dis­clo­sure of infor­ma­tion, under the Freedom of Information Act, when­ever a request is made involv­ing access to records or infor­ma­tion com­piled for law enforce­ment pur­poses. Pursuant to 5 U.S.C. 552a(J); heads of U.S. Government agen­cies may pro­mul­gate rules to exempt infor­ma­tion from dis­clo­sure under 5 U.S.C. 552.

5 U.S.C. 552a(J)(2) char­ac­ter­izes infor­ma­tion that may be exempted from dis­clo­sure as that which is: “main­tained by an agency or com­po­nent thereof which per­forms as its prin­ci­pal func­tion any activ­ity per­tain­ing to the enforce­ment of crim­i­nal laws, includ­ing police efforts to pre­vent, con­trol, or reduce crime or to appre­hend crim­i­nals, and the activ­i­ties of pros­e­cu­tors, courts, cor­rec­tional, pro­ba­tion, par­don, or parole author­i­ties, and which con­sists of (A) infor­ma­tion com­piled for the pur­pose of iden­ti­fy­ing indi­vid­ual crim­i­nal offend­ers and alleged offend­ers and con­sist­ing only of iden­ti­fy­ing data and nota­tions of arrests, the nature and dis­po­si­tion of crim­i­nal charges, sen­tenc­ing, con­fine­ment, release, and parole and pro­ba­tion sta­tus; (B) infor­ma­tion com­piled for the pur­pose of a crim­i­nal inves­ti­ga­tion, includ­ing reports of infor­mants and inves­ti­ga­tors, and asso­ci­ated with an iden­ti­fi­able indi­vid­ual; or © reports iden­ti­fi­able to an indi­vid­ual com­piled at any stage of the process of enforce­ment of the crim­i­nal laws from arrest or indict­ment through release from super­vi­sion” (empha­sis added).

Former Attorney’s General Janet Reno, John Ashcroft and Alberto Gonzales, and their pre­de­ces­sors, have sought to pro­tect the infor­ma­tion described in 5 U.S.C. 552a(J)(2) through the adop­tion of a mul­ti­tude of rules gov­ern­ing such infor­ma­tion as described above and elu­ci­dated more fully in the USAM, FBI man­u­als and DOJ mem­o­randa. For exam­ple, pur­suant to USAM Chapter 1–3.100, “Prior Approval Requirements, the Deputy Attorney General must approve any dis­clo­sure of infor­ma­tion by DOJ employ­ees which would be in vio­la­tion of 28 C.F.R. Sec. 16.26(b) which sets out those inter­ests that the DOJ must pro­tect.” See also USAM 1–6.420; .440.

28 C.F.R. 16, “Judicial Administration— Production or Disclosure of Material or Information,” fur­ther sup­ports the fact that the May 9, 2005 Criminal Matters infor­ma­tion was con­fi­den­tial infor­ma­tion of the United States which, is not autho­rized to be made avail­able to the pub­lic on request. These reg­u­la­tions strictly pro­hibit the dis­clo­sure of infor­ma­tion where the dis­clo­sure would reveal inves­ti­ga­tory records com­piled for law enforce­ment pur­poses and would inter­fere with enforce­ment pro­ceed­ings or dis­close inves­tiga­tive tech­niques and pro­ce­dures such that their effec­tive­ness would be impaired. See 28 C.F.R. § 16.26(5).

Pursuant to 28 C.F.R. 16.26(b)(4), con­sid­er­a­tions in deter­min­ing whether pro­duc­tion or dis­clo­sure should be made pur­suant to a demand:

“among the demands in response to which dis­clo­sure will not be made by any Department offi­cial are those demands with respect to which… dis­clo­sure would reveal a con­fi­den­tial source or infor­mant, unless the inves­tiga­tive agency and the source or infor­mant have no objec­tion” (empha­sis added).

Stating the obvi­ous, I would never have released Miles Ehrlich to use the infor­ma­tion I pro­vided him to rep­re­sent and pro­vide advice and coun­sel to the indi­vid­u­als I iden­ti­fied to him as pri­mary actors involved in the May 2005 Criminal Matters. Moreover, because of the nature of the crim­i­nals acts, i.e. nar­cotics traf­fick­ing, money-laundering, bribery of judi­cial offi­cials, and con­spir­acy by mem­bers of a large law firm, for exam­ple, had I real­ized at the time I imparted the infor­ma­tion regard­ing the May 9, 2005 Criminal Matters to him, he would resign his posi­tion as an AUSA and pro­vide rep­re­sen­ta­tion, advice and coun­sel to at least one of the indi­vid­u­als I iden­ti­fied to him, I would never have divulged the May 9, 2005 Criminal Matters information.

Courts have upheld the law enforce­ment inves­tiga­tive priv­i­lege from dis­clo­sure of such records. See e.g., Maroscia v. Levi, 569 F.2d 1000, 1002 (7th Cir. 1977); NLRB v. Robbins Tire and Rubber Co., 437 U.S. 214, 242–43 (1978); Barney v. IRS, 618 F.2d 1268, 1273–74 (8th Cir. 1980) (ital­ics added). The law enforce­ment priv­i­lege pre­sump­tively pro­tects inves­tiga­tive files and tes­ti­mony about inves­tiga­tive files from dis­clo­sure. See In re Sealed Case, 856 F.2d 268, 272 (D.C. Cir. 1988); Friedman v. Bache Halsey Stuart Shields, Inc., 738 F.2d 1336, 1341 (D.C. Cir. 1984); Black v. Sheraton Corp. of America, 564 F.2d 531, 545 (D.C. Cir. 1977) (ital­ics added). The priv­i­lege is designed “to pre­vent dis­clo­sure of law enforce­ment tech­niques and pro­ce­dures, to pre­serve the con­fi­den­tial­ity of sources, to pro­tect wit­ness and law enforce­ment per­son­nel, to safe­guard the pri­vacy of indi­vid­u­als involved in an inves­ti­ga­tion, and oth­er­wise to pre­vent inter­fer­ence with an inves­ti­ga­tion.” See In re Department of Investigation of the City of N.Y., 856 F.2d 481, 484 (2d Cir. 1988); accord United States v. Winner, 641 F.2d 825, 831 (10th Cir. 1981) (quot­ing Black See also, 564 F.2d at 831) (ital­ics added).

A com­pe­tent pros­e­cu­tor would not dis­close the infor­ma­tion Miles Ehrlich obtained from me unless he was: a) cer­tain such dis­clo­sure would fur­ther the U.S. Government’s abil­ity to enhance the out­come of a pros­e­cu­tion; or b) com­pelled by law to dis­close. Even in these instances, he would only dis­close por­tions of the infor­ma­tion that would aid his case or pro­vide the defense excul­pa­tory evi­dence as required by law. See e.g., 28 C.F.R. § 16.26(a).

Had Miles Ehrlich or another pros­e­cu­tor opened a for­mal inves­ti­ga­tion regard­ing the May 9, 2005 Criminal Matters or sought indict­ments from a grand jury, based on the infor­ma­tion I pro­vided, he would not have dis­closed the May 9, 2005 Criminal Matters to the per­pe­tra­tors I iden­ti­fied to him; nor would he (or another pros­e­cu­tor) have dis­closed the source of the infor­ma­tion until such time as he was oblig­ated. Such law enforce­ment inves­tiga­tive priv­i­lege is deeply-rooted in crim­i­nal inves­ti­ga­tory and pros­e­cu­to­r­ial pro­ce­dure. Without such secrecy, an inves­ti­ga­tion into the May 9, 2005 Criminal Matters could become impaired, wit­nesses tam­pered with and retal­i­ated against (which has occurred), etc. to the dis­ad­van­tage of Miles Ehrlich’s for­mer client, the United States.

The May 9, 2005 Criminal Matters infor­ma­tion was of a char­ac­ter Miles Ehrlich’s client, the DOJ con­sid­ers secret, con­fi­den­tial and pro­tected by law enforce­ment inves­tiga­tive priv­i­lege, secur­ing it in such man­ner to avoid its dis­sem­i­na­tion in order to pro­tect wit­nesses, inves­tiga­tive meth­ods, accused par­ties and to pre­serve delib­er­a­tive process and evi­den­tiary priv­i­lege regard­ing such information.

* * * * *

Attorney-Client Secrets and Confidences

“The integrity of the legal pro­fes­sion requires at all times the pro­tec­tion of a client who depends upon and con­fides in the attor­ney.” (Cal State Bar Formal Opn. No. 1981–58 (1981)). Whenever an attorney-client rela­tion­ship exists the duty of con­fi­den­tial­ity pro­tects all infor­ma­tion regard­ing the rep­re­sen­ta­tion, irre­spec­tive of the source of the infor­ma­tion. See Commercial Standard Title Co., Inc. v. Superior Court of San Diego County (4th Dist. 1979) 92 Cal.App.3d 934, 155 Cal.Rptr. 393 (ital­ics added).

Pursuant to CB&PC ¤ 6068(e)(1), it is the duty of an attor­ney “to main­tain invi­o­late the con­fi­dence, and at every peril to him­self or her­self to pre­serve the secrets, of his or her client.” The Rules of Professional Conduct of the State Bar of California (here­inafter referred to as the “California Rules of Professional Conduct” or “CRPC”) pro­vide only two excep­tions to this rule: 1) upon the informed (writ­ten) con­sent of the client; and 2) to “ pre­vent a crim­i­nal act that the mem­ber rea­son­ably believes is likely to result in death of, or sub­stan­tial bod­ily harm to, an indi­vid­ual.” (CRPC 3–100).

“In the con­text of the CB&PC sec­tion 6068, sub­di­vi­sion (e), ‘secret’ is not lim­ited to attorney-client com­mu­ni­ca­tions. ‘This eth­i­cal pre­cept, unlike the evi­den­tiary priv­i­lege, exists with­out regard to the nature or source of infor­ma­tion or the fact that oth­ers share the knowl­edge.’ [Citation.] Any ‘infor­ma­tion gained in the pro­fes­sional rela­tion­ship that the client has requested be held invi­o­late or the dis­clo­sure of which would be embar­rass­ing or would likely be detri­men­tal to the client’ is a secret which must be pre­served. [Citation.] Both ‘con­fi­dences’ and ‘secrets’ are priv­i­leged com­mu­ni­ca­tions. [Citation.].” (Cal. State Bar Formal Opn. No. 1981–58.)

The “Committee has inter­preted the first part of CB&PC sec­tion 6068 (e) (‘to main­tain invi­o­late the con­fi­dence … of his or her client’) to mean that an attor­ney may not do any­thing to breach the trust reposed in the attor­ney by the client.” (Cal. State Bar Formal Opn. No. 1986–87; Anderson v. Eaton (1930) 211 Cal. 113, ital­ics added.)

The rela­tion­ship between attor­ney and client is a fidu­ciary rela­tion­ship of the very high­est char­ac­ter. [cita­tion] [cita­tion] [cita­tion] “Hence, the actual use or mis­use of con­fi­den­tial infor­ma­tion is not deter­mi­na­tive.” (Cal. State Bar Formal Opn. No. 1993-133)

“Client secrets means any infor­ma­tion obtained by the lawyer dur­ing the pro­fes­sional rela­tion­ship, or relat­ing to the rep­re­sen­ta­tion, which the client has requested to be invi­o­late or the dis­clo­sure of which might be embar­rass­ing or detri­men­tal to the client. [Citation.]” (Cal. State Bar Formal Opn. No. 1993-133)

As an attor­ney, Miles Ehrlich has con­tin­u­ing duties to his for­mer clients, the People of the United States, that pre­vent the dis­clo­sure or mis­use of sen­si­tive, con­fi­den­tial and non-public infor­ma­tion beyond the ter­mi­na­tion of his employ­ment as an AUSA.

“The duty to honor the secrets and con­fi­dences of a client also applies to for­mer clients and only the client can release the attor­ney from this duty.” Cal. State Bar Formal Opn. No. 1992-126). See also Commercial Standard Title Co., supra, 92 Cal. App. 3d at p. 945; Woods v. Superior Court (1983) 149 Cal.App.3d 931; David Welch Co. v. Erskine & Tulley (1st Dist. 1988) 203 Cal.App.3d 884, 250 Cal.Rptr. 339; and Earl Scheib, Inc. v. Superior Court (2nd. Dist. 1967) 253 Cal.App.2d 703, 708, 61 Cal.Rptr. 386 (ital­ics added).

“[T]he attorney’s duty to main­tain client con­fi­dences and secrets invi­o­late is broader in scope than the attorney-client priv­i­lege.” [Citation.] (Cal. State Bar Formal Opn. No. 1993-133).

Discussion

Miles Ehrlich directly and per­son­ally rep­re­sented the People of the United States when he obtained from me the May 9, 2005 Criminal Matters infor­ma­tion, which infor­ma­tion, the DOJ, a del­e­gated law enforce­ment arm of the exec­u­tive branch of the United States gov­ern­ment and cus­to­dian of sen­si­tive, con­fi­den­tial infor­ma­tion regard­ing crim­i­nal mat­ters affect­ing the People of the United States, seeks to pro­tect as secret and con­fi­den­tial in order to pre­serve law enforce­ment priv­i­lege, attorney-client priv­i­lege, the iden­ti­ties of infor­mants, the rights of wit­nesses, and vic­tims as well as the rights of the accused.

The California Rules of Professional Conduct, the CB&PC, case law and the State Bar of California Standing Committee on Professional Responsibility and Conduct opinions:

1) require that an attor­ney pro­tect the secrets and con­fi­dences of his or her client, invi­o­late; and

2) pro­vide that the duty to pro­tect such secrets and con­fi­dences sur­vives the ter­mi­na­tion of the attorney-client relationship;

No rel­e­vant excep­tions to Miles Ehrlich’s duty to pro­tect the May 9, 2005 Criminal Matters infor­ma­tion on behalf of his client in crim­i­nal mat­ters, the People of the United States exist in fed­eral or California law.

Considering the fore­go­ing, the fac­tual infor­ma­tion regard­ing the May 9, 2005 Criminal Matters, and Miles Ehrlich’s opin­ions thereon are the secret, con­fi­den­tial infor­ma­tion of the United States sub­ject to law enforce­ment, delib­er­a­tive process and evi­den­tiary priv­i­lege. Miles Ehrlich is there­fore required to main­tain the May 9, 2005 Criminal Matters infor­ma­tion “invi­o­late” even after his employ­ment and client-attorney rela­tion­ship were ter­mi­nated in the Fall of 2005.

CONFLICT OF INTEREST; MILES EHRLICH’S REPRESENTATION OF MATTERS ADVERSE TO THE U.S. GOVERNMENT, HIS FORMER CLIENT

“The para­mount con­cern is the preser­va­tion of pub­lic trust in the scrupu­lous admin­is­tra­tion of jus­tice and the integrity of the bar.” (Comden, supra, 20 Cal.3d, p. 915, empha­sis added.)

One of the issues dis­cussed about in herein and in my July 31, 2007 com­plaint involves Miles Ehrlich’s suc­ces­sive rep­re­sen­ta­tion of clients whose inter­ests are adverse. In such cases, attor­neys must not under­take rep­re­sen­ta­tion of a prospec­tive client if “the attor­ney (1) has actual knowl­edge of mate­r­ial con­fi­den­tial infor­ma­tion or (2) is pre­sumed to have acquired con­fi­den­tial infor­ma­tion because of the rela­tion­ship between the prior rep­re­sen­ta­tion and the cur­rent rep­re­sen­ta­tion.” (Faughn v. Perez (2006) 145 Cal.App.4th 592, 603, ital­ics added.)

Asaverred herein, and averred and evi­denced, in my July 31, 2007 complaint:

1. Miles Ehrlich par­tic­i­pated directly, per­son­ally and sub­stan­tially as an AUSA when he obtained the May 9, 2005 Criminal Matters infor­ma­tion from me, which was the secret, con­fi­den­tial and priv­i­leged infor­ma­tion of his client, the People of the United States.

2. Miles Ehrlich is rep­re­sent­ing Marcia Bruggeman Hatch and pro­vid­ing advise and coun­sel to, Seamus Hatch and/or Aran Strategic Finance, LLC who were among sev­eral indi­vid­u­als and enti­ties I iden­ti­fied to Miles Ehrlich as being among the pri­mary per­pe­tra­tors of the May 9, 2005 Criminal Matters.

3. Heretofore, the course of Miles Ehrlich’s rep­re­sen­ta­tion, advice and coun­sel var­i­ously to Marcia Bruggeman Hatch, Seamus Hatch and Aran Strategic Finance, and, I believe in con­fed­er­a­tion with the other par­ties I iden­ti­fied to him as well as his crim­i­nal defense attor­ney col­leagues, after resign­ing his posi­tion as an AUSA, has been to:

(A) employ intim­i­dat­ing, threat­en­ing, harass­ing and mis­lead­ing tac­tics, in an attempt to dis­suade, me from com­mu­ni­cat­ing with law enforce­ment offi­cials infor­ma­tion relat­ing to the May 9, 2005 Criminal Matters;

(B) to malign my com­mu­ni­ca­tions in order to under­mine my efforts to engage law enforce­ment offi­cials to assist me and the other vic­tims of his client(s) con­duct, includ­ing the People of the United States, and the People of the States of California to obtain relief from his client(s) con­tin­u­ing ille­gal acts.

The mat­ters in which Miles Ehrlich is rep­re­sent­ing and/or advis­ing the fore­go­ing indi­vid­u­als, as a crim­i­nal defense attor­ney, are the same or sub­stan­tially sim­i­lar to the mat­ters in which he offi­cially, per­son­ally and sub­stan­tially rep­re­sented the People of the United States.

Statutory Prohibitions Against Former Government Attorneys “Switching Sides”

18 U.S.C. § 207(a)(1) pro­hibits all for­mer employ­ees from know­ingly mak­ing, with the intent to influ­ence, any com­mu­ni­ca­tion to, or appear­ance before, a depart­ment, agency or court of the United States on behalf of any­one other than the United States regard­ing a par­tic­u­lar mat­ter involv­ing spe­cific par­ties in which they par­tic­i­pated per­son­ally and sub­stan­tially while in government.

California Government Code ¤ 87401 pro­hibits any for­mer state admin­is­tra­tive offi­cial, after the ter­mi­na­tion of his or her employ­ment or term of office, from act­ing for com­pen­sa­tion as an attor­ney for, or oth­er­wise rep­re­sent­ing, any per­son (other than the State of California) before any court or state admin­is­tra­tive agency or par­tic­i­pat­ing in other spec­i­fied activ­i­ties if (a) the State of California is a party or has a direct or sub­stan­tial inter­est and (b) the pro­ceed­ing is one in which the for­mer state admin­is­tra­tive offi­cial participated.

California Government Code ¤ 87402. “No for­mer state admin­is­tra­tive offi­cial, after the ter­mi­na­tion of his or her employ­ment or term of office shall for com­pen­sa­tion aid, advise, coun­sel, con­sult or assist in rep­re­sent­ing any other per­son (except the State of California) in any pro­ceed­ing in which the offi­cial would be pro­hib­ited from appear­ing under Section 87401.”

Pursuant to 28 U.S.C. § 530B “[a]n attor­ney for the Government shall be sub­ject to State laws and rules, and local Federal court rules, gov­ern­ing attor­neys in each State where such attor­ney engages in that attorney’s duties, to the same extent and in the same man­ner as other attor­neys in that State.”

Discussion

Public pol­icy is clear in the con­text of for­mer gov­ern­ment employ­ees “switch­ing sides” and rep­re­sent­ing or advis­ing par­ties before a court or gov­ern­ment agency if the for­mer employee par­tic­i­pated in the mat­ter in his offi­cial capac­ity. Both the State of California and the United States pre­clude such activ­i­ties to (1) pro­tect con­fi­den­tial infor­ma­tion and (2) pre­vent for­mer gov­ern­ment employ­ees from using the knowl­edge they gained through gov­ern­ment ser­vice to fur­ther their own inter­ests at the expense of the pub­lic. As dis­cussed herein, it is in the inter­est of the United States to pro­tect crime vic­tims, wit­nesses and infor­mants. And the mat­ter in which Miles Ehrlich is advis­ing his client(s), to enable them to evade pros­e­cu­tion by intim­i­dat­ing, harass­ing and malign­ing a wit­ness is adverse to the inter­ests of the State of California and the United States.

18 U.S.C. 207(a) and California Government Code ¤ 87401; 87402 are par­al­lel laws restrict­ing the activ­i­ties of for­mer United States gov­ern­ment and State of California, respec­tively. The California statutes pro­hibit both direct and “behind the scenes” rep­re­sen­ta­tion. 28 U.S.C. § 530B, the “Citizens Protection Act,”8 fills gaps reg­u­lat­ing fed­eral pros­e­cu­tors and arguably applies to for­mer pros­e­cu­tors regard­ing conflicts.

While I don’t have the inves­tiga­tive resources at my dis­posal to pre­cisely deter­mine the full extent and nature of Miles Ehrlich’s activ­i­ties regard­ing his rep­re­sen­ta­tion of Marcia Hatch et al, it appears from the elec­tronic doc­u­ment a third party pro­vided me, which is incom­plete, that Miles Ehrlich has rep­re­sented the inter­ests of Marcia Bruggeman Hatch and pro­vided advice and coun­sel to Seamus Hatch before a court or admin­is­tra­tive agency of either the State of California or the United States or both. Certainly, the State Bar of California with it’s inves­ti­ga­tory resources could eas­ily deter­mine the extent of Miles Ehrlich’s activ­i­ties in this regard. This being the case, Miles Ehrlich has acted in con­tra­ven­tion to 18 U.S.C. 207(a) and/or California Government Code ¤ 87401 as ana­lyzed directly or within the sphere of 28 U.S.C. § 530B.

Further inves­ti­ga­tion of this is mer­ited par­tic­u­larly given the mat­ters in which Miles Ehrlich “switched sides” are: (1) crim­i­nal in nature; (2) the activ­i­ties of the offend­ing par­ties have been on-going; and (3) that it is clear from the evi­dence that, at a min­i­mum, Miles Ehrlich breached (a) American Bar Association Rules of Professional Conduct; and (b) the California Rules of Professional Conduct as more fully elu­ci­dated below.

ABA Model Rules of Professional Conduct, Rule 1.11

Rule 1.11 Special Conflicts Of Interest For Former And Current Government Officers And Employees of the ABA Rules clearly pro­hibits the rep­re­sen­ta­tion of a client “in con­nec­tion with a mat­ter [9] in which the lawyer par­tic­i­pated per­son­ally and sub­stan­tially, unless the appro­pri­ate gov­ern­ment agency gives its informed con­sent, con­firmed in writ­ing, to the rep­re­sen­ta­tion;” [10] or if the lawyer has “con­fi­den­tial gov­ern­ment infor­ma­tion about a per­son acquired when the lawyer was a pub­lic offi­cer or employee, [he or she] may not rep­re­sent a pri­vate client whose inter­ests are adverse to that per­son in a mat­ter in which the infor­ma­tion could be used to the mate­r­ial dis­ad­van­tage of that per­son.” 11

Discussion

ABA Rule 1.11 was pro­mul­gated not only to pro­tect for­mer clients but to pre­vent the exploita­tion of pub­lic office to the advan­tage of the for­mer pub­lic offi­cer or another client. Paragraphs © and (d)(2) apply irre­spec­tive of whether a lawyer is adverse to the for­mer client. “This Rule rep­re­sents a bal­anc­ing of inter­ests. On the one hand, where the suc­ces­sive clients are a gov­ern­ment agency and another client, pub­lic or pri­vate, the risk exists that power or dis­cre­tion vested in that agency might be for the spe­cial ben­e­fit of the other client. A lawyer should not be in a posi­tion where ben­e­fit to the other client might affect per­for­mance of the lawyer’s pro­fes­sional func­tions on behalf of the gov­ern­ment. Also, unfair advan­tage could accrue to the pri­vate client by rea­son of access to con­fi­den­tial gov­ern­ment infor­ma­tion about the client’s adver­sary obtain­able only through the lawyer’s gov­ern­ment service.”12

Although California does not have a direct coun­ter­part to ABA Rule 1.11 in the CRPC; the ABA Rules can be of assis­tance where California has not spo­ken. In State Comp. Ins. Fund v. WPS, Inc. (1999) 70 Cal.App.4th 644, the Court of Appeal stated that “the ABA Model Rules of Professional Conduct may be con­sid­ered” to deter­mine an attorney’s duties, “par­tic­u­larly in areas where there is no direct author­ity in California and there is no con­flict with the pub­lic pol­icy of California. [Citation.]” (Id. at p. 656, ital­ics in the orig­i­nal.) See also, Flatt, supra, 9 Cal.4th at pp. 282–283; Ojeda, supra, 8 Cal.App.4th, p.

8; In Lucent Tech. Inc v. Gateway, Inc., 2007 U.S. Dist. Lexis 35502 (S.D. Cal May 15, 2007); Goldberg, supra, 125 Cal.App.4th, p. 752; People v. Donaldson, supra, Cal.App.4th p. 916.

ABA Rule 1.11 is iden­ti­cal to Rule 1.11 of the Pennsylvania Rules of Professional Conduct, Miles Ehrlich’s first state of licen­sure and the only state in which he was licensed at the time he obtained the May 9, 2005 Criminal Matters infor­ma­tion. To my knowl­edge there was no case pend­ing at the time he resigned as an AUSA from the DOJ. This being the case, pur­suant to 28 U.S.C. 530B either the Pennsylvania Rules of Professional Conduct or the CRPC would apply. See 28 C.F.R. §77.2(j)(1)(ii) and 28 C.F.R. §77.4©.

Miles Ehrlich is clearly pro­hib­ited under Rule 1.11 of the Pennsylvania Rules of Professional Conduct and ABA Rule 1.11 from rep­re­sent­ing Marcia Bruggeman Hatch a/k/a Marica Hatch, Marsha Hatch, Marcia A. Hatch (for­merly with Heller Ehrman and Currently with Gunderson Dettmer) and pro­vid­ing advice and coun­sel to Seamus Hatch and/or Aran Strategic Finance because he par­tic­i­pated directly, per­son­ally and sub­stan­tially in the mat­ter when he obtained con­fi­den­tial infor­ma­tion, sub­ject to law enforce­ment priv­i­lege, regard­ing 1) the fact that I informed the DOJ of the May 9, 2005 crim­i­nal mat­ters infor­ma­tion, and 2) the con­tent of the May 9, 2005 Criminal Matters which he could use (read has used) to the mate­r­ial dis­ad­van­tage of his for­mer client, the People of the United States as well as to the dis­ad­van­tage of other vic­tims and witnesses.

California Rules of Professional Conduct 3–310(E)

Pursuant to CRPC 3–310(E) “a mem­ber shall not, with­out the informed writ­ten con­sent of the client or for­mer client, accept employ­ment adverse to the client or for­mer client where, by rea­son of the rep­re­sen­ta­tion of the client or for­mer client, the mem­ber has obtained con­fi­den­tial infor­ma­tion mate­r­ial to the employment.”

Pursuant to CRPC 3–310(A) an attor­ney may obtain a writ­ten waiver from a for­mer client to rep­re­sent a client pro­vided, the for­mer client is fully informed of the “rel­e­vant cir­cum­stances and of the actual and rea­son­ably fore­see­ably adverse consequences”13 to the for­mer client of pro­vid­ing such waiver.

Case Law and California State Bar Formal Ethics Opinions

In People ex rel. Dept. of Corporations v. SpeeDee Oil Change Systems, Inc. (1999) 20 Cal.4th 1135, the California Supreme Court stated: “Protecting the con­fi­den­tial­ity of com­mu­ni­ca­tions between attor­ney and client is fun­da­men­tal to our legal sys­tem.… To this end, a basic oblig­a­tion of every attor­ney is ‘[t]o main­tain invi­o­late the con­fi­dence, and every peril to him­self or her­self to pre­serve the secrets, of his or her client.’

[Citation.]” The court added: “A related but dis­tinct fun­da­men­tal value of our legal sys­tem is the attorney’s oblig­a­tion of loy­alty. Attorneys have a duty to main­tain undi­vided loy­alty to their clients to avoid under­min­ing pub­lic con­fi­dence in the legal pro­fes­sion and the judi­cial process. [Citation.]” (Id. at p. 1145.)

In Earl Scheib, Inc., supra, 253 C.A.2d p. 707, the court stated,

“…the sub­se­quent rep­re­sen­ta­tion of another against a for­mer client is for­bid­den not merely when the attor­ney will be called upon to use con­fi­den­tial infor­ma­tion obtained in the course of the for­mer employ­ment, but in every case when, by rea­son of such sub­se­quent employ­ment he may be called upon to use such con­fi­den­tial information.”

“The pri­mary pur­pose of rule 3–310(E) is to pro­tect the con­fi­den­tial rela­tion­ship which exists between attor­ney and client. (Jacuzzi v. Jacuzzi Bros., Inc. (1963) 218 Cal.App.2d 24, 28.) A lawyer is for­bid­den to do either of two things after sev­er­ing his or her rela­tion­ship with a for­mer client. ‘He may not do any­thing which will inju­ri­ously affect his for­mer client in any mat­ter in which he for­merly rep­re­sented him nor may he at any time use against his for­mer client knowl­edge or infor­ma­tion acquired by virtue of the pre­vi­ous rela­tion­ship.’ (Galbraith v. State Bar (1933) 218 Cal. 329, 333.)” (Cal. State Bar Formal Opn. No. 1993-133) (empha­sis added).

The facts of this case involve suc­ces­sive rep­re­sen­ta­tion. “Where an attorney’s con­flict arises from suc­ces­sive rep­re­sen­ta­tion of clients with poten­tially adverse inter­ests, ‘the chief fidu­ciary value jeop­ar­dized is that of client con­fi­den­tial­ity.’ [Citation.]” (Forrest v. Baeza (1997) 58 Cal.App.4th 65, 73 [67 Cal.Rptr.2d 857], quot­ing Flatt, supra, 9 Cal.4th, 283)

Proof that an attor­ney actu­ally pos­sesses con­fi­den­tial infor­ma­tion is not required to evi­dence a breach of CRPC 3–310(E). Rather, the courts have uti­lized the “sub­stan­tial rela­tion­ship” test: “ ‘When a sub­stan­tial rela­tion­ship has been shown to exist between the for­mer rep­re­sen­ta­tion and the cur­rent rep­re­sen­ta­tion, and when it appears by virtue of the nature of the for­mer rep­re­sen­ta­tion or the rela­tion­ship of the attor­ney to his for­mer client con­fi­den­tial infor­ma­tion mate­r­ial to the cur­rent dis­pute would nor­mally have been imparted to the attor­ney or to sub­or­di­nates for whose legal work he was respon­si­ble, the attorney’s knowl­edge of con­fi­den­tial infor­ma­tion is pre­sumed. [Citation.]’ ” (Rosenfeld Construction Co. v. Superior Court (Sivas)(1991) 235 Cal.App.3d 566 , [286 Cal.Rptr. 609] at p. 574, quot­ing Global Van Lines, Inc. v. Superior Court (1983) 144 Cal.App.3d 483, 489 [192 Cal.Rptr. 609] (Global).)

This stan­dard, with its con­clu­sive pre­sump­tion of knowl­edge of con­fi­den­tial infor­ma­tion, is “jus­ti­fied as a rule of neces­sity” because: “ ‘it is not within the power of the for­mer client to prove what is in the mind of the attor­ney. Nor should the attor­ney have to “engage in a sub­tle eval­u­a­tion of the extent to which he acquired rel­e­vant infor­ma­tion in the first rep­re­sen­ta­tion and of the actual use of that knowl­edge and infor­ma­tion in the sub­se­quent rep­re­sen­ta­tion.” ’ [Citations.] The con­clu­sive pre­sump­tion also avoids the ironic result of dis­clos­ing the for­mer client’s con­fi­dences and secrets through an inquiry into the actual state of the lawyer’s knowl­edge and it makes clear the legal profession’s intent to pre­serve the public’s trust over its own self-interest. [ Citations.]” (H.F. Ahmanson & Co., supra, 229 Cal.App.3d, 1453–1455, ital­ics added.)

“Our Supreme Court has declared that ‘an attor­ney is for­bid­den to do either of two things after sev­er­ing his rela­tion­ship with a for­mer client. He may not do any­thing which will inju­ri­ously affect his for­mer client in any man­ner in which he for­merly rep­re­sented him nor may he at any time use against his for­mer client knowl­edge or infor­ma­tion acquired by virtue of the pre­vi­ous rela­tion­ship.’ … [T]he pro­hi­bi­tion is in the dis­junc­tive: [the attor­ney] may not use infor­ma­tion or ‘do any­thing which will inju­ri­ously affect his for­mer client.’ ” (Brand v. 20th Century Ins. Co./21st Century Ins. Co. (2004)124 Cal.App.4th 594, [Cal.Rptr.3d], quot­ing Wutchumna Water Co. v. Bailey (1932) 216 Cal. 564, 573–574 [15 P.2d 505].)

Discussion

One fac­tor dis­tin­guish­ing this case from oth­ers is that the con­fi­den­tial infor­ma­tion of the prior client, is known to me, a wit­ness and crime vic­tim who informed Miles Ehrlich’s for­mer client, the People of the United States through Miles Ehrlich of the May 9, 2005 Criminal Matters. To reit­er­ate, the nature of the con­fi­den­tial infor­ma­tion Miles Ehrlich obtained from me included:

1. the fact that I reported the crim­i­nal activ­ity to law enforce­ment author­i­ties (directly to Miles Ehrlich in this case);

2. the nature of the crim­i­nal activity;

3. the iden­ti­ties of the per­pe­tra­tors of the crim­i­nal activity;

4. the breadth of the evi­dence in my pos­ses­sion sup­port­ing my allegations.

The con­fi­den­tial, priv­i­leged infor­ma­tion Miles Ehrlich obtained from me included the iden­ti­ties of the par­ties to the May 9, 2005 Criminal Matters, the spe­cific nature of those crimes as well as the gen­eral nature of the evi­dence in my pos­ses­sion. In addi­tion, Miles Ehrlich was aware I reported the May 9, 2005 Criminal Matters to him. Such infor­ma­tion would cer­tainly be help­ful to his rep­re­sen­ta­tion of Marcia Bruggeman Hatch and his pro­vi­sion of advice and coun­sel to Seamus Hatch and/or Aran Strategic Finance, LLC. For exam­ple, their learn­ing that I reported the May 9, 2005 Criminal Matters would be use­ful to because it would be obvi­ous that their Marcia Bruggeman Hatch’s husband’s and his cohorts man­u­fac­tur­ing accu­sa­tions to cast me in an unfa­vor­able light and the use of their man­u­fac­tured state­ments to attempt to extort a “gen­eral release” from me had not pre­vented me from con­tact­ing law enforce­ment author­i­ties to inform them of their crim­i­nal activ­i­ties. Thus, Miles Ehrlich and his crim­i­nal defense attor­ney col­leagues could use their con­tacts and influ­ence with law enforce­ment agen­cies to assist Marcia Bruggeman Hatch et al to evade inves­ti­ga­tion and pros­e­cu­tion by pre­empt­ing and delay­ing my attempts to com­mu­ni­cate with law enforce­ment offi­cials. I believe this was the strat­egy they were pur­su­ing until I dis­cov­ered, by hap­pen­stance that Miles Ehrlich had “switched sides” and was clan­des­tinely rep­re­sent­ing Marcia Bruggeman Hatch.

When Miles Ehrlich returned my call to him on November 15, 2006 he did not tell me he was rep­re­sent­ing Marcia Bruggeman Hatch and pro­vid­ing advice and coun­sel to Seamus Hatch and/or Aran Strategic Finance. When I asked him for a refer­ral to his suc­ces­sor at the United States Attorney’s office he asked me if I could be reached at the tele­phone num­ber he called me on to wit I responded affir­ma­tively. Miles Ehrlich then told me: “I’ll get back to you” and ter­mi­nated the call. Several hours later I received a harass­ing tele­phone call from agents who refused to dis­close to me the iden­tity of their client. I believe were employed by the par­ties to the May 9, 2005 Criminal Matters. These agents wanted to know my loca­tion which I refused to pro­vide them. Sometime later, I received a call from John Daniel Sharp, Esq. who told me that Miles Ehrlich was rep­re­sent­ing Marcia Bruggeman Hatch a/k/a Marica Hatch, Marsha Hatch, Marcia A. Hatch (for­merly with Heller Ehrman and Currently with Gunderson Dettmer) and he there­fore couldn’t help me.

As per­sons pur­ported to have com­mit­ted crim­i­nal acts against the United States, the State of California and other vic­tims, the inter­ests of Marcia Bruggeman Hatch a/k/a Marica Hatch, Marsha Hatch, Marcia A. Hatch (for­merly with Heller Ehrman and Currently with Gunderson Dettmer), Seamus Hatch and Aran Strategic Finance, LLC are by def­i­n­i­tion adverse to the inter­ests of the People of the United States, vic­tims, wit­nesses who can pro­vide tes­ti­mony regard­ing their ille­gal acts. Any rep­re­sen­ta­tion Miles Ehrlich has under­taken, against the wit­nesses to or neg­a­tively par­ties affected by the May 9, 2005 Criminal Matters, to facil­i­tate the eva­sion of pros­e­cu­tion or to cover up crimes per­pe­trated by Marcia Bruggeman Hatch, Seamus Hatch and their cohorts is adverse to the objects of his for­mer client, the People of the United States.

Because I dis­cov­ered the fact that Miles Ehrlich had under­taken the rep­re­sen­ta­tion of mat­ters adverse to his for­mer client, the People of the United States, it is my assess­ment that it is best to dis­close these facts in light of his client’s and her cohorts con­tin­u­ing pat­tern of ille­gal activ­ity. My hope is that by mak­ing this infor­ma­tion pub­lic, it will: 1) dis­suade Marcia Bruggeman Hatch, her hus­band and their cohorts from con­tin­u­ing their crim­i­nal enter­prises and attacks on me; and 2) coun­ter­act any effect Miles Ehrlich and his cohorts have had to impede an inves­ti­ga­tion of the case by law enforce­ment authorities.

The appli­ca­tion of CRPC Rule 3–310(E) is very straight­for­ward in this case because it can be proven: 1) Miles Ehrlich pos­sessed con­fi­den­tial infor­ma­tion of his for­mer client mate­r­ial to the rep­re­sen­ta­tion of his cur­rent client(s); 2) that in obtain­ing the May 9, 2005 Criminal Matters infor­ma­tion from me Miles Ehrlich’s involve­ment was direct and per­sonal; and 3) the mat­ters in which he is rep­re­sent­ing Marcia Hatch a/k/a Marcia Bruggeman, Marsha Bruggeman and pro­vid­ing advice and coun­sel to Seamus Hatch and/or Aran Strategic Fiance, LLC are sub­stan­tially related because his crim­i­nal defense efforts are cen­tered on harass­ing and retal­i­at­ing against the wit­ness and vic­tim who reported the crim­i­nal activ­ity to him in the first place.

Regarding the pos­si­bil­ity Miles Ehrlich obtained a waiver from the United States prior to under­tak­ing rep­re­sen­ta­tion of Marcia Bruggeman Hatch, et al, I have no infor­ma­tion Miles Ehrlich fully informed the People of the United States or the DOJ, the cus­to­dian of the May 9, 2005 Criminal Matters infor­ma­tion, in writ­ing pur­suant to CRPC 3–310(A), and that he was pro­vided a waiver to rep­re­sent Marcia Bruggeman Hatch and pro­vide advice and coun­sel to Seamus Hatch and Aran Strategic Finance, prior to his under­tak­ing such activ­i­ties. Moreover, sec­tion 6068, sub­di­vi­sion (e) of the CB&PC, may in fact have pre­cluded Miles Ehrlich from mak­ing ade­quate dis­clo­sure under CRPC 3–310(A). If such dis­clo­sure is pre­cluded, informed writ­ten con­sent is like­wise precluded.

California law is very clear that with­out informed con­sent of the for­mer client, an attor­ney may not rep­re­sent a suc­ces­sive client with inter­ests adverse to the for­mer client where the attor­ney has “obtained con­fi­den­tial infor­ma­tion mate­r­ial to the employment.”14 Miles Ehrlich fla­grantly dis­re­garded CRPC 3–310(E) when he furtively under­took rep­re­sent­ing Marcia Bruggeman Hatch a/k/a Marica Hatch, Marsha Hatch, Marcia A. Hatch (for­merly with Heller Ehrman and Currently with Gunderson Dettmer) and pro­vided advice and coun­sel to Seamus Hatch and/or Aran Strategic Finance, LLC. Had I not, by hap­pen­stance, dis­cov­ered Miles Ehrlich’s involve­ment in rep­re­sent­ing and pro­vid­ing advice and coun­sel to par­ties to the May 9, 2005 Criminal Matters, his involve­ment therein would have escaped my detection.

By pro­vid­ing rep­re­sen­ta­tion to Marcia Bruggeman Hatch and advice and coun­sel to Seamus Hatch and/or Aran Strategic Finance, LLC, Miles Ehrlich fla­grantly breached his pro­fes­sional respon­si­bil­i­ties under 3–310(E) of the California Rules of Professional Conduct.

LAWYER SELF-DEALING IN CONFIDENTIAL INFORMATION

California law for­bids attor­neys from using the con­fi­den­tial infor­ma­tion of a client to ben­e­fit them­selves. See David Welch Co., supra, 203 Cal.App.3d pp. 891–892, where an attor­ney acquired and used a for­mer client’s busi­ness clien­tele to the attorney’s advan­tage. Self-dealing occurs when con­fi­den­tial client infor­ma­tion is eco­nom­i­cally advan­ta­geous to the attor­ney yet unfa­vor­able to the client or for­mer client as the case may be. See e.g., Tri-Growth Centre City, Ltd. v. Silldorf, Burdman, Duignan & Eisenberg (4th Dist. 1990) 216 Cal.App.3d 1139, 1152–1154, 265 Cal.Rptr. 330 (ital­ics added) where the defen­dant used its posi­tion as both attor­ney and part­ner to acquire con­fi­den­tial infor­ma­tion that led his law firm to offer an ear­lier clos­ing date and ensure its offer on a piece of property.

Miles Ehrlich obtained the May 9, 2005 Criminal Matters from me which became the con­fi­den­tial infor­ma­tion of his client, the People of the United States. Subsequent to my iden­ti­fy­ing the par­ties to Miles Ehrlich, he under­took rep­re­sen­ta­tion of Marcia Bruggeman Hatch and has pro­vided coun­sel and advice to Seamus Hatch and/or Aran Strategic Finance, LLC. Certainly, Miles Ehrlich has been remu­ner­ated for his ser­vices to these parties.

Pursuant to CRPC Rule 3–300 “[a] mem­ber shall not enter into a busi­ness trans­ac­tion with a client; or know­ingly acquire an own­er­ship, pos­ses­sory, secu­rity, or other pecu­niary inter­est adverse to a client… ”

By under­tak­ing rep­re­sen­ta­tion of Marcia Bruggeman Hatch and pro­vid­ing advice and coun­sel to Seamus Hatch and/or Aran Strategic Fiance, LLC, Miles Ehrlich acquired the abil­ity to use the May 9, 2005 Criminal Matters infor­ma­tion in a man­ner detri­men­tal to his for­mer client, the United States Miles Ehrlich has thereby breached his pro­fes­sional respon­si­bil­i­ties under CRPC 3–300. (See e.g., Welch, supra, 203 Cal.App.3d 884, pp. 891–892; Ames v. State Bar (1975) 8 Cal.3d 910, 920; Connor v. State Bar (1990) 50 Cal.3d 1047, 1058; and In the Matter of Fonte (Review Dept. 1994) 2 Cal. State Bar Ct. Rptr. 752, 759–760.)

MILES EHRLICH’S DISSEMINATION OF THE MAY 9, 2005 CRIMINAL MATTERS INFORMATION

Miles Ehrlich pro­vided my tele­phone num­ber to at least one attor­ney, John Daniel Sharp, Esq. either directly or through agents. John Daniel Sharp, Esq., a crim­i­nal defense lawyer, claimed to me that he rep­re­sents Heller Ehrman LLP and that Miles Ehrlich was rep­re­sent­ing Marcia Bruggeman Hatch, a Heller Ehrman “share­holder.” The tele­phone num­ber is a num­ber I reserve for per­sonal calls is unlisted and not gen­er­ally known. Agents work­ing for one or more of the par­ties to the May 9, 2005 crim­i­nal mat­ters tele­phoned on this num­ber for the pur­pose of intim­i­dat­ing, threat­en­ing and harass­ing me. For instance, the agents requested I pro­vide them my phys­i­cal loca­tion which I inter­preted as a threat given Marcia Bruggeman Hatch’s affil­i­a­tion with a crim­i­nal orga­ni­za­tion. While fur­ther inves­ti­ga­tion is nec­es­sary and practical15; given the cir­cum­stances and the col­lu­sion among the var­i­ous adverse par­ties and their attor­neys it is highly likely that Miles Ehrlich divulged the May 9, 2005 Criminal Matters infor­ma­tion to John Daniel Sharp, Esq. and oth­ers in con­tra­ven­tion to CB&PC ¤ 6068(e)(1), CRPC 3–100 and other laws, ana­lyzed directly or in the sphere of 28 U.S.C. § 530B, regard­ing the main­te­nance of sen­si­tive, con­fi­den­tial infor­ma­tion by cur­rent and for­mer gov­ern­ment employees.

PROHIBITED OBJECTIVES OF EMPLOYMENT

Pursuant to CRPC “Rule 3–200 Prohibited Objectives of Employment. A mem­ber shall not seek, accept, or con­tinue employ­ment if the mem­ber knows or should know that the objec­tive of such employ­ment is: (A) To bring an action, con­duct a defense, assert a posi­tion in lit­i­ga­tion, or take an appeal, with­out prob­a­ble cause and for the pur­pose of harass­ing or mali­ciously injur­ing any person…”

Miles Ehrlich and John Daniel Sharp are aware of my fears for my phys­i­cal safety as a con­se­quence of Marcia Bruggeman Hatch’s and Seamus Hatch’s asso­ci­a­tion with the head of a nar­cotics traf­fick­ing orga­ni­za­tion, I iden­ti­fied to Miles Ehrlich on May 9, 2005 and have used that knowl­edge to harass and intim­i­date me from con­tin­u­ing to pur­sue legal reme­dies against their clients. It’s appar­ent from the incom­plete doc­u­ments, a third party emailed to me, that Miles Ehrlich and/or John Daniel Sharp have either brought actions or con­fed­er­ated with other par­ties to the May 9, 2005 Criminal Matters to cause actions to be advanced in a court with the objec­tive of harass­ing and mali­ciously injur­ing my abil­ity to obtain reme­dies for the crim­i­nal activ­ity that has severely impacted my life.

The fore­go­ing and other activ­i­ties dis­cussed herein are pro­hib­ited objec­tives of Miles Ehrlich’s employ­ment by Marcia Bruggeman Hatch under rule 3–200 of the CRPC.

ADVISING THE VIOLATION OF LAW

Pursuant to CRPC “Rule 3–210, “Advising the Violation of Law… [a] mem­ber shall not advise the vio­la­tion of any law, rule, or rul­ing of a tri­bunal unless the mem­ber believes in good faith that such law, rule, or rul­ing is invalid.”

Miles Ehrlich’s rep­re­sen­ta­tion of Marcia Bruggeman Hatch and col­lud­ing with other par­ties involved in per­pe­trat­ing the May 9, 2005 Criminal Matters thus facil­i­tat­ing their efforts to retal­i­ate against me and con­tinue to intim­i­date, harass and threaten me for the pur­pose of mali­ciously injur­ing me as well as enabling the par­ties to evade jus­tice is clearly ille­gal under both California and fed­eral statutes such as 18 U.S.C. §§ 1512; 1513.

DECEIT, COLLUSION, DELAY OF SUIT AND IMPROPER RECEIPT OF MONEY

Pursuant to § 6128 of the California State Bar Act “Deceit, Collusion, Delay of Suit and Improper Receipt of Money as Misdemeanor. Every attor­ney is guilty of a mis­de­meanor who either: (a) Is guilty of any deceit or col­lu­sion, or con­sents to any deceit or col­lu­sion, with intent to deceive the court or any party… ”

By not inform­ing me on November 15, 2006 that he was rep­re­sent­ing Marcia Hatch, Miles Ehrlich attempted to deceive me into believ­ing he had not under­taken the rep­re­sen­ta­tion of any of the par­ties to the May 9, 2005 Criminal Matters when accord­ing to John Daniel Sharp, Esq. Miles Ehrlich had in fact under­taken such representation.

Miles Ehrlich con­sented to and engaged in col­lu­sion with John Daniel Sharp, the par­ties to the May 9, 2005 Criminal Matters and I believe oth­ers when he under­took to mis­lead, intim­i­date, harass and threaten me to inten­tion­ally dis­suade, hin­der, impede, delay, pre­vent, malign and under­mine my attempts and the effec­tive­ness of those attempts to com­mu­ni­cate with law enforce­ment offi­cials regard­ing their crim­i­nal activ­ity. inves­ti­gate and pros­e­cute the May 9, 2005 Criminal Matters.

FAILING TO ACT COMPETENTLY

Pursuant to Rule 3–110, “Failing to Act Competently, …(A) A mem­ber shall not inten­tion­ally, reck­lessly, or repeat­edly fail to per­form legal ser­vices with com­pe­tence. (B) For pur­poses of this rule, ‘com­pe­tence’ in any legal ser­vice shall mean to apply the 1) dili­gence, 2) learn­ing and skill, and 3) men­tal, emo­tional, and phys­i­cal abil­ity rea­son­ably nec­es­sary for the per­for­mance of such service.”

In engag­ing in the activ­i­ties described herein Miles Ehrlich has, on his own and in col­lu­sion with oth­ers, failed to act com­pe­tently and failed to com­pe­tently super­vise non-attorney employ­ees and/or agents.

SANCTIONS AND DISCIPLINE

As dis­cussed herein and in my July 31, 2007 com­plaint Miles Ehrlich has under­taken rep­re­sen­ta­tion of Marcia Bruggeman Hatch a/k/a Marica Hatch, Marsha Hatch, Marcia A. Hatch (for­merly with Heller Ehrman and Currently with Gunderson Dettmer) and pro­vided advise and coun­sel to Seamus Hatch or Aran Strategic Finance, LLC, a clear con­flict of inter­est with his for­mer client, the People of the United States. By engag­ing in the pat­tern of con­duct and dis­crete activ­i­ties described herein, Miles Ehrlich has vio­lated and/or col­luded with oth­ers thereby violating:

1. California Penal Code ¤ 136, and 18 U.S.C. §§ 1512; 1513;

2. California Penal Code ¤ 182 and 18 U.S.C. § 371;

3. § 6128 of the California State Bar Act;

4. his duties as an AUSA, Pennsylvania attor­ney and California attor­ney (see §§ 6068 and 6103 of the California State Bar Act);

5. his oaths as an AUSA, Pennsylvania attor­ney and California attor­ney (see §§ 6067 and 6103 of the California State Bar Act);

6. ABA Rule 1.11 and Rule 1.11 of the Pennsylvania Rules of Professional Conduct; and

7. CPRC Rules 3–310(E), 3–200, 3–300, 3–110, and 3–210.

It is highly likely that if the Office of the Chief Trial Counsel inves­ti­gates this case, addi­tional infrac­tions of the law, the CRPC and the ABA Rules will be dis­cov­ered includ­ing that Miles Ehrlich has vio­lated rel­e­vant pro­vi­sions of: 18 U.S.C. § 207; California Government Code ¤ 87401; California Government Code ¤ 87402; CB&PC ¤ 6068(e)(1) and CRPC 3–100.

Miles Ehrlich’s con­duct has irrepara­bly harmed the admin­is­tra­tion of jus­tice regard­ing the May 9, 2005 Criminal Matters and caused sig­nif­i­cant, irrepara­ble harm to me and his for­mer client, the People of the United States.

The CB&PC ¤ 6077 pro­vides that, for a will­ful breach of any of the CRPC, the State Bar Board of Governors has the power to dis­ci­pline attor­neys by reproval, pub­lic or pri­vate, or to rec­om­mend to the Supreme Court the sus­pen­sion from prac­tice for an attor­ney not exceed­ing three years. CB&PC ¤ 6077 pro­vides that an attor­ney may be dis­barred or sus­pended by the Supreme Court for any of the causes set forth in Article 6 (CB&PC ¤ 6100 and fol­low­ing) of the State Bar Act. These causes include the vio­la­tion by an attor­ney of his duties as an attor­ney (see CB&PC ¤ 6103) and acts involv­ing moral turpi­tude, dis­hon­esty or cor­rup­tion (CB&PC 6106). These lat­ter pro­vi­sions have been inter­preted to include sit­u­a­tions involv­ing con­flicts of inter­est. Thus, breach of CRPC con­cern­ing con­flicts of inter­est may be grounds for the impo­si­tion of a broad vari­ety of dis­ci­pli­nary sanc­tions. See, e.g., Kapelus v. State Bar (1987) 44 Cal.3d 179, 242 Cal.Rptr. 196, 745 P.2d 917 (dis­bar­ment); Benson v. State Bar (1975) 13 Cal.3d 581, 119 Cal.Rptr. 297, 531 P.2d 1081 (dis­bar­ment); In the Matter of Hindin (Review Dept. 1997) 1997 WL 469424 (dis­bar­ment); Rosenthal v. State Bar (1982) 43 Cal.3d 612, 238 Cal.Rptr. 377, 738 P.2d 723 (dis­bar­ment); Gendron v. State Bar (1983) 35 Cal.3d 409, 197 Cal.Rptr. 590, 673 P.2d 260, (for­mer CRPC 4–101 (1975)) (pub­lic rep­ri­mand); Ames, supra, 8 Cal.3d 910, 506 P.2d 625, (pri­vate reproval); Lee v. State Bar (1970) 2 Cal.3d 927, 88 Cal.Rptr. 361, 472 P.2d 449 (three years pro­ba­tion, with actual sus­pen­sion for first year).

PLEA FOR WITNESS / VICTIM / INFORMANT RELIEF, PROTECTION AND ASSISTANCE

Marcia Bruggeman Hatch, an attor­ney with a large law firm, Heller Ehrman LLP pre­sented a cohort of hers who is pur­ported to head the afore­men­tioned nar­cotics traf­fick­ing orga­ni­za­tion, to a mer­chant bank­ing firm in which I am an equity owner to laun­der her cohort’s organization’s money. I believe Seamus Hatch and his busi­ness part­ner, Michael Bock have assisted Seamus Hatch’s wife to laun­der her drug traf­fick­ing  cohort’s organization’s illicit money. And I strongly sus­pect Heller Ehrman LLP and/or enti­ties Heller Ehrman LLP acquired have engaged in using their cor­po­rate clients and other orga­ni­za­tions to laun­der money result­ing from ille­gal activ­ity. In addi­tion to my tes­ti­mony regard­ing the fore­go­ing, another wit­ness is avail­able who can sup­port this and addi­tional evi­dence can be obtained through investigation.

The indi­vid­u­als and enti­ties dis­cussed herein have cor­ruptly con­fed­er­ated to harm me, enti­ties in which I own equity inter­ests, through numer­ous vio­la­tions of law, reg­u­la­tions and rules. They’ve oper­ated as a orga­ni­za­tion with crim­i­nal designs and are asso­ci­ated with a crim­i­nal nar­cotics traf­fick­ing orga­ni­za­tion. They have the means to mur­der me.

I require the assis­tance of the State Bar of California and law enforce­ment agen­cies to: 1) take action to halt the on-going crim­i­nal actions and activ­i­ties of the par­ties; 2) pro­tect me from fur­ther efforts on their part to hin­der my com­mu­ni­cat­ing with law enforce­ment offi­cials; 3) pro­tect me from fur­ther retal­i­a­tion; 4) pro­vide me assis­tance to mit­i­gate the extreme finan­cial dam­age caused me by their activ­i­ties; and 5) assist me to obtain resti­tu­tion for the crimes which I’ve been a victim.

* * * * *

I appre­ci­ate your direct­ing me to an attor­ney. Are you mad (read CRAZY)? Why would I expose myself to a crim­i­nal nar­cotics traf­fick­ing orga­ni­za­tion the pur­ported head of which is affil­i­ated with a Heller Ehrman LLP “share­holder” and some of her cronies? That is if I could even retain a lawyer in this sit­u­a­tion. Law enforce­ment needs to take action in this case prior to engag­ing lawyers to sue the lawyer parties.

In case you’re unfa­mil­iar with them, Heller Ehrman is the big San Francisco law firm in the midst of being sanc­tioned for appar­ently advis­ing Qualcomm, not to com­ply with a dis­cov­ery request. Two hun­dred fifty emails were withheld.

What was the true cost to Broadcom of Heller Ehrman’s alleged advice to Qualcomm? Certainly it was more than Broadcom’s legal fees. What about he tremen­dous inter­nal cost to Broadcom to defend itself against Qualcomm and their unscrupu­lous attor­neys? Litigation is very dis­rup­tive to com­pa­nies in many terms. Did Broadcom forego busi­ness oppor­tu­ni­ties as a con­se­quence of the lit­i­ga­tion? What impact did this have on Broadcom’s share­hold­ers? The cost of attor­ney mis­con­duct in California, and the U.S. gen­er­ally, is incal­cu­la­ble in both mon­e­tary and social terms. And given my expe­ri­ence so far, it’s obvi­ous your orga­ni­za­tion is inef­fec­tive at deter­ring lawyer mis­con­duct that, like a can­cer, gnaws away at the U.S. econ­omy and the social fab­ric of our country.

Do you real­ize Heller Ehrman LLP have signed a com­pact with many other law firms not to sue each other? That makes it quite dif­fi­cult for surfs like me to sue them. Why don’t you put together an anti-trust task force to deal with that? Or would that bring you, the “Office of the Chief Trail Counsel” into dis­fa­vor among the mul­ti­tude of California law firm’s who are a party to such agree­ments and pay you to police them? In addi­tion to me how many other vic­tims of lawyer crimes can­not sue lawyer mis­cre­ants because they can’t retain a law firm 1) large enough to han­dle the case and 2) who aren’t a party to a com­pact not to sue the offend­ing law firm?

Because you’ve put the onus on me, the vic­tim of sig­nif­i­cant lawyer mis­con­duct to pro­vide you with an analy­sis of the issues, I’m tak­ing the lib­erty of pub­lish­ing this let­ter. And I’m nearly fin­ished with a man­u­script for a book to be pub­lished regard­ing this case. I plan to pro­vide read­ers a com­pan­ion web­site to access the sig­nif­i­cant body evi­dence my inves­ti­ga­tions have uncov­ered. It’s about time American’s and their rep­re­sen­ta­tives become informed about the lack of avail­able real reme­dies to ordi­nary folks who’ve been defrauded of all of their money by lawyers, regard­ing the sig­nif­i­cant cor­rup­tion prob­lem exis­tent in the “prac­tice of law.”…and the reg­u­la­tion of lawyers?

Do you want to write the end­ing of my book or shall I?

FURTHER COMMUNICATIONS

I stated in my July 31, 2007 com­plaint, which Ms. Stowe appar­ently did not read, I do not have an address you can mail cor­re­spon­dence to because I’m afraid that, like the infor­ma­tion I pro­vided Miles Ehrlich, my address will be pur­pose­fully misused.

Please do not send another let­ter to the address you sent your September 21, 2007 response to. The indi­vid­ual whose address you posted the let­ter to does not want you to use their address. They too are con­cerned about the inabil­ity of law enforce­ment per­son­nel to pro­tect sen­si­tive infor­ma­tion, con­trol a for­mer AUSAs and that they could become an avenue for the par­ties to the May 9, 2005 Criminal Matters, I iden­ti­fied to Miles Ehrlich to attempt intim­i­date me from con­tin­u­ing to try to engage law enforce­ment author­i­ties to take action regard­ing the May 9, 2005 Criminal Matters as well as other crimes I sus­pect they’ve committed.

Copied to:

Magistrate Judge Barbara Major
US Senator Barbara Boxer
California Attorney General Jerry Brown

California Bar Complaint Against Miles Ehrlich, 5.0 out of 5 based on 34 rat­ings