I will publish my North Carolina Bar complaint here on this website to ensure that it doesn’t get lost in the political hogwash associated in Raleigh with the Raleigh Mafia. Imagine anything getting swept under some rugs in this state. I will post it as it is written………I will also post it exactly as written to show people that I do know how to actually make a couple of sentences come together when I want too.
The Grievance Committee
The North Carolina State Bar
P.O. Box 25908
Raleigh, North Carolina
21 August 2016
RE: Complaint against George Wayne Goodwin, License # 19029, NC. Department of Insurance, 1201 Mail Service Center, 430 N. Salisbury Street, Raleigh, NC. 27699.
Mark L. Bibbs, License # 22680, Bibbs Law Group, 410, N. Boylan Ave, Raleigh NC. 27603.
Dear Members of the Grievance Committee:
I hereby write to complain against George Wayne Goodwin, an attorney and member of the North Carolina Bar since 1992, and currently Commissioner of Insurance in this state of North Carolina.
While this complaint cannot omit mentioning George Wayne Goodwin, in his elected capacity, I do hereby request that the BAR address his active attorney role. There is of course the fact that the elephant in this detail and that he is the current Commissioner of Insurance and in the regard owes the state of North Carolina a much higher standard than he has shown by his actions. I also believe that he owes the 28,000 members of his profession a better representation than what the public is now witnessing.
I must disclose at this time that I, Ronald Leonard Pierce ran for Commissioner of Insurance for the 2016 election cycle, but did not make it past the primaries. I must also point out a couple of other things. While I am trying not to be a person without feelings in this complaint and since I am not an attorney in any state, I will try and stick to the facts only.
I have tried to separate George Wayne Goodwin and Mark L. Bibbs on these complaints, but it seems thru their own admission with the proof supplied that they are joined at the hip on all of my alleged charges and violations. Please see Exhibit 4 and 5. ( personal letter to Wayne Goodwin from Mark Bibbs with emails associated with each). ( texts supplied by WSOC).
I believe that George Wayne Goodwin, thru direct and indirect actions has caused specific violations of the Rules of Professional Conduct. As well as outright breaking of the laws of North Carolina, of which he has sworn to protect. In more than one avenue or fashion.
Through the actions I alleged herein, at least one attorney, Mark L. Bibbs, License # 22680, Bibbs Law Group, 410 N. Boylan Ave, Raleigh, NC. 27603. Was encouraged and aided in violating the Rules of Professional Conduct. As such includes but not limited to the following:
Rules from the North Carolina State Bar Website. 3.3 And 3.5. I will mark as exhibit 1 and 2 respectfully. And again referring to exhibit 4 and 5 respectfully.
As an attorney and an officer of the court, George Wayne Goodwin, has had direct knowledge of various laws in which he swore to uphold that are being violated, even on a daily basis. He has repeatedly turned a blind eye to enforcing these laws, despite his direct knowledge, at a minimum, thru email complaints forwarded to him and then deny that he has no knowledge of those emails under oath. I will mark this exhibit 3. Please note each and every email with George Wayne Goodwin’s name on it and copied directly to his computer. (I will not supply with this article).
Either by negligence or outright complicity, he has allowed a huge criminal enterprise to operate, in North Carolina, growing behind more than over 100 licensed Bail Bond Agents. This dereliction, of this officer of the court has caused consumers, taxpayers and the citizens of North Carolina to be harmed in many ways.
Through text messages, personal emails, and otherwise, now made public. George Wayne Goodwin has had direct and indirect, to include personal knowledge of a criminal organization operating throughout the state of North Carolina for the past two years, if not beyond. This enterprise has, based upon information supplied herein and on the belief, has illegally and unlawfully, collected and laundered millions of dollars in insurance premiums in our state.
Which brings me to the facts of, NCGS 120-86…? Bribery. “A” No person shall offer or give to a legislator or a member of a legislators family, or to a business with which the legislator is associated, and no legislator shall solicit or receive, anything of monetary value, including a gift, favor or service, or a promise of future employment, based on any understanding that the legislators vote, official actions or judgement would be influenced thereby, or where it could reasonably be inferred that the thing of value would influence the legislator in the discharge of the legislators duties. Exhibit 6.
This enterprise, and Carl Valentine also disqualified in the Commonwealth of Virginia has been allowed to operate in partnerships with appointees of George Wayne Goodwin in his capacity as Commissioner of Insurance and an attorney licensed in this state. Exhibit 7.
This disqualified enterprise in accordance with NCGS 58-71 respectfully, has caused a veteran and a retired senior citizen. Clyde Robert Brawley, ( address not Disclosed)…to invest over $ 850,000, of his retirement funds into an operation that would not have existed if George Wayne Goodwin and his buddy Mark L. Bibbs who by the way represents Premier Judicial, and Cannon Surety without the knowledge of Mr. Brawley. Again this entity would not have existed if not for the collusion between George Wayne Goodwin and Mark L. Bibbs. See exhibits 8, 9, and 10 respectfully.
Carl Valentine, an individual holding multiple disqualifications, and a client of Mark L. Bibbs. Carl Valentine who is part owner of both Cannon Surety and Premier Judicial as seen on the documents supplied. Please note page 1 on copyright 2014. And on page 26 in exhibit 10. The first one listed on Management Team. Again copyrighted on the bottom of page of 2014. When and after this individual had his license revoked in 2012 ? Please see licensee lookup from the NCDOI known as exhibit 7.
These companies and Carl Valentine along with Dallas McClain and Lynette Thompson both Licensed as Bail Bond Agents were allowed to openly operate in this state with full knowledge of George Wayne Goodwin and the Deputy Commissioners of the North Carolina Department of Insurance Captive Unit.
George Wayne Goodwin still allowed these companies to openly operate and while blatantly violating specific areas of North Carolina General Statute 58-71, and under NCGS 58-34, all the while acting as an unlicensed Manager or “MGA” of multiple insurance companies appointed in this state. George Wayne Goodwin also has allowed the Valentine gang who comprises of Mark L. Bibbs, Carl Valentine, Dallas McClain, and Lynette Thompson, to obtain a North Carolina Insurance Company Certificate of Authority all the while hiding behind 173 Bail Bond Agents. This wall of the “Raleigh Mafia” was broken by WSOC.
Furthermore George Wayne Goodwin has communicated with Mark L. Bibbs, who was acting as an unlicensed and unregistered Lobbyist. Communication is also enclosed. Please see exhibit 11. “texts”. Both parties have also communicated on more than one occasion but documented by the parties themselves at least one occasion in secret, see enclosed personal letter to George Wayne Goodwin from Mark L. Bibbs. Of which I will quote….”I have always supported you, and will continue to support you NO MATTER what, I support my friends, whether they are right or wrong. That has been the hallmark of my life. There is no exception, including with you. I will punish my enemies and the enemies of my friends. I have always done that. Including your enemies. If you have told me who they are. That is the way life works. Exhibit 4.
This brings me to several other violations from Mark L. Bibbs who represented numbers of other clients against the NCDOI and George Wayne Goodwin whom I believe with those stated quotes, has not given proper representation to these clients because of his relationship with George Wayne Goodwin.
Mark L. Bibbs, an attorney and an officer of the courts, has openly admitted to violating the North Carolina Open Records Law through correspondence in a letter to George Wayne Goodwin which makes both of them in violation of these laws.
George Wayne Goodwin and Mark L. Bibbs have meet on several occasions all the while Mark L. Bibbs was representing clients that had matters before the agency that George Wayne Goodwin represents, to wit, the North Carolina Department of Insurance. Such correspondence and meetings violated the ex parte relationship that is required to preserve the integrity of the adjudication process in between attorney’s and others in such matters. Please reference Rule 8.4. Exhibit 12. “MISCONDUCT”.
In the texts of which a copy has been provided. In January 2016. Mark L. Bibbs updates George Wayne Goodwin on internal deliberations involving Speaker of House Tim Moore’s office that dealt with committees leadership assignments.
Yet again a new text in March….” GM. Need to talk with you about a new client. RE: insurance bill. It should be openly stated again that Mark L. Bibbs was not even registered to engage in lobbying during the first part of 2016. I would again reference Rules 8.4, 3.3, 3.5. I bring into the Committees attention to rule 7.1, which states: “a lawyer shall not make false or misleading communication about the lawyer or the lawyers services. (1) A communication is false or misleading if it contains a material misrepresentation of fact or law, or omits a fact necessary to make the statement considered as a whole materially misleading. I bring this reference to the facts presented in the texts between Mark L. Bibbs and George Wayne Goodwin on the facts Mark L. Bibbs referenced to his involvement with a new client that he wants George Wayne Goodwin to speak to him about.
George Wayne Goodwin just recently lied, perjured himself openly on my Interrogatories filed in the Federal Court of which a copy is supplied. In this the question was asked….”Did you participate, in any way, either directly or indirectly, in the criminal investigation, arrest, or prosecution of Ronald Leonard Pierce?
ANSWER…No. Criminal Investigations and prosecutions are handled by the Criminal Investigation Division, “CID” of the Department of Insurance and I have never been a member of the “CID”. As Commissioner of Insurance I have indirect supervisory authority over the employees of the Department of Insurance, but I had no involvement in the investigation, arrest, or prosecution of the plaintiff. I reference exhibit 13.
I ask this Committee, how is this even possible when as on a minimum, on June 24, 2014. A press release was issued by the North Carolina Department of Insurance with the following:
CHARLOTTE MAN ACCUSED OF HAIL DAMAGE INSURANCE CLAIM FRAUD
Raleigh-Insurance Commissioner Wayne Goodwin today announced the arrest Ronald Leonard Pierce, 56 of 4917 Cedar Forest Drive, Charlotte; he was charged with 108 charges of Obtaining Property by False Pretense.
After a yearlong investigation, North Carolina Department of Insurance criminal investigators allege that Pierce was acting as a public adjuster without a license to provide those services for two of his businesses, Clear Choice Construction and Piedmont Disaster Services. Pierce is accused of providing inflated hail damage repair estimates to homeowners and receiving $ 450,000 in fraudulent claim payments from insurance companies from 2012 to the beginning of 2013″.
There are several lies, miss-truths, misrepresentation’s, this is also called FRAUD in accordance with the definition of misrepresentation, associated with these statements. First being, there were no charges placed upon me for acting as an unlicensed Public Adjuster in accordance with NCGS 58-33A. I have to bring to the attention to the Committee how is it legal for George Wayne Goodwin to make these false statements. This also comes up under Rule 3.3. Making False Statements.
THE Second False Statement by George Wayne Goodwin in the same paragraph states “Pierce is accused of providing inflated hail damage estimates to homeowners and receiving $ 450,000 in fraudulent claim payments from the insurance companies from 2012 and the beginning of 2013″. Again where are these false statements followed by or associated by charges, so that I may defend myself against them in court proceeding’s or Hearing Process? So without charges these are again false statements. This again is misrepresentation of material facts of exactly what really happened. I will provide a copy of these stated remarks. Exhibit 14.
Also on the charges of 108 felony counts of Obtaining Property under False Pretense, I faced down these false charges, of which all were dismissed here in Mecklenburg County for ” NO PROBABLE CAUSE”. In other terms George Wayne Goodwin lied about the investigation, arrest and prosecution of myself from the very beginning and then lied under oath to my attorney and to the Federal Court that he didn’t know anything about anything. I ask this Committee how is this legal. This is also called perjury under oath. I reference NCGS 14-209, 210, and 211 respectfully. Exhibit 15. Which states as follows: ” If any person shall willfully and corruptly commit perjury, on his oath or affirmation, in any suit, controversy, matter or cause, depending in any courts of the state, or in any deposition or affidavit taken pursuant to law, or in any oath or affirmation duty administered of or concerning any matter or thing whereof such person is lawfully required to be sworn or affirmed, every person so offending shall be punished as a class F felon.
I would also reference Rule 8.4 Misconduct/ NC State Bar.
I would also reference the False Claims Act NCGS 1-605 and 1-606 respectfully. Exhibit 16. These False Charges and False Statements have literally cost me at least 6 Million Dollars, as well as ruined my current business as well as completely ruined my integrity. I cannot get those lies and misrepresentations off of the internet. Also George Wayne Goodwin has ruined my future businesses as well. I ask one question to the Committee here. Who are you or who is the general public going to listen to and believe…A lying state governmental office and person or ME?
It doesn’t take a farm truck to run over me on that one. I refer to Rule 4.1. Truthfulness in statements to others. In this Rule I bring both Mark L. Bibbs and George Wayne Goodwin to bear equally. Which states: “A lawyer is prohibited from counseling or assisting a client that the attorney knows is criminal or fraudulent” Exhibit 17.
In conclusion lawyers have a special obligation to protect the public and or a tribunal against criminal and or fraudulent conduct that undermines the integrity of our judicative process. Such as bribing, intimidation in office or otherwise unlawfully communicating with a witness, juror, court official, nor any other participant in the proceeding, unlawfully destroying, or concealing documents or other evidence or failing to disclose information to the tribunal when required by law to do so. Thus paragraph “B” of Rule 3.3 requires a lawyer to take reasonable remedial measures, included disclosure if necessary, whenever the lawyer knows that a person, including the lawyers client, intends to engage, or is engaging or has engaged in criminal or fraudulent conduct related to every proceeding especially when those proceedings will effect the general public.
I am asking for a complete investigation into the acts of these individuals and ask for them as a minimum to be held in a position to never be able to harm the general public again. I am sure that I have not referenced all of the Rules that were broken by Mark L. Bibbs and George Wayne Goodwin, in which I would expect this Committee to also include with their investigation into the unlawful acts of these individuals.
I have included several other Exhibits for extra proof in establishing the facts of wrong doing. Please read each carefully. In as much as I am fearful that your BAR will do what the Attorney Generals Office has done with my past complaints about the North Carolina Department of Insurance’s wrongful investigation of me and my companies?
And that would be nothing with the exception of saying that I had no legal standing. Hence I am illegally acting as an unlicensed Public Adjuster. Let alone falsely accuse me of Insurance Fraud, and to bring false charges of Obtaining Property under False Pretense NCGS 114-100.
All of this with so called officers of the court. Licensed individuals. Defending our laws and the constitution of North Carolina. People like these are the reasons why the general public do not believe in our system of government.
Please take whatever action you deem necessary to root out these abuses.