Bar Complaint Topics
by Robert Hedges ©


Attorney John D. Dale jr claimed he never represented Complainant HEDGES, and no complaint is valid unless from a client. Yet he expects to collect a fee from the property belonging to HEDGES and presumably had/has control of some financial resources of HEDGES.

The issues, complete with (case law citation) covered in the two complaints made to the KY Bar are:

  • 2966 - Feb 1992
  • Misleading the deceased about the law . . KRS 383 and KRS 376.
  • Violation of the Doctrine of Fiduciary Trust. - Accounting for rents, profit, revenues and expenses is required by law.
  • Appraisal intent which fails to protect the financial interest of the client and other heirs.
  • Attorney testifying "by proxy" presumably, without benefit of being sworn. Opinion of what facts may be is not proof of facts.
  • Enhanced billing- frivolous and void hearings, as well as litigation intended to lead to higher legal billing.
  • Elevating the secondary attorney lien ahead of the substantive property right of Hedges against real property which was filed first.
  • Failure to maximize real property values, or personal property values.
  • Violations of Rule 11, and being a participant in multiple frivolous acts, leading to nullities, and a false arrest.

  • 4413- Feb 1995
  • Part I = violation of planning and zoning notice, consent and hearing requirements - Conflict of Interest with multiple representation, including representing Spencer County, which may lead to the county being named as defendant in the Federal case 95 CV 33. (SCR 3.130-1.7)
  • Part II = missing record of safety deposit box - violation of KRS 132.420. Houston Hedges always had a safety deposit box, and never kept valuables in his homes.
  • Part III = missing land, which is a fraud against the estate and the owners thereof, as well as a deprivation of the constitutional right of use and possession of property.
  • Part IV = misrepresentation of the court of appeals jurisdictional technical dismissals which are not appeals heard or adjudicated.
  • Part V = property values and fiduciary trust - fraudulent appraisal and intent to defraud by the use of low appraisal.
  • Part VI = Using as supporting witnesses the same judges who after being urged to carry out frivolous motions, have signed "nullities" into the cases and committed constitutional violations against Complainant Hedges.
  • Attorney Dale failed to respond to this complaint with a single fact, but rather answering with argumentative opinion statements. (did not . . . . did to . . . . did not . . . did to . . . ). That type of opinion answer is defined legally as non-responsive.

    THE KENTUCKY BAR FAILED TO DEMAND A FACTUAL RESPONSE.
    THE APPEARANCE OF IMPROPRIETY ALONE IS A ETHICS VIOLATION


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    Last modified: November 1996