How many times can a person say CORRUPTION that goes on in this State……. Hello Daniel and Denise, how do you like me and my attorney John Mansfield NOW. You both represent the citizens of North Carolina don’t you. Oh wait a minute you don’t do you. I guess that Roy Cooper has lied again, by saying to everyone in the State of North Carolina that himself, and the Attorney Generals Office represents the citizens of North Carolina. And he wants to be Governor of this State. I guess that I mislead myself on that one. Don’t worry, I won’t have that happen again to myself.

So let’s get back to where I was going with this article. You Daniel Snipes Johnson, Assistant Attorney General of North Carolina, and you M. Denise Stanford, Assistant Attorney General of North Carolina are perjurers in your own right. You have lied under oath. And I along with my attorney are NOT going to let you get away with it. I hope that the Federal Judge, puts your asses in jail for NCGS 14-210 Subornation of Perjury. Oh yes, we filed with the court today asking for Sanctions against both of you. But don’t worry I’ll make sure that I attach all of these filings to a new NC Bar complaint against the both of you, and I will again post everything here, and on Facebook, to show just what kind of corrupt criminals that we have at the top of our legal system here in North Carolina.

So are you ready for it Daniel and Denise, here we go………..

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF NORTH CAROLINA

No. 4:16-cv-20 BO

RONALD LEONARD PIERCE. PLAINTIFF, V. ANNE M. GARMON, et al. Defendants.

VERIFIED MOTION FOR SANCTIONS AGAINST DANIEL JOHNSON AND DENISE STANFORD

John D. Mansfield, Esq. Of Counsel, Polanco Law, P.C. 2840 Plaza Place, suite 260, Raleigh, NC. 27612….919-294-8032, Attorney for Plaintiff.

NOW COMES the undersigned counsel for Plaintiff, John D. Mansfield, ESQ., and moves the Court for an order for Rule 26(g) Monetary Sanctions against Ms. Denise Stanford, ESQ. and Daniel Snipes Johnson, ESQ. of the Insurance Section of the North Carolina Attorney Generals Office. In support of this Motion for Monetary Sanctions, the movant asks that this Verified Motion be treated as an Affidavit, and shows unto the Court as follows:

  1. That I am Counsel of record for Mr. Ronald L. Pierce in the above entitled action:
  2. That I am over the age of eighteen years old (18) and am competent to give verified statements; nor do I suffer from any mental or physical disability;
  3. That, in response to Plaintiff’s Limited Scope Interrogatories pursuant to the Federal Rules of Civil Procedure, Ms. Stanford and Mr. Johnson have put forth deceptive, untruthful, and sanctionable discovery responses in this case;
  4. That I was surprised to learn that Ms. Stanford, an officer of the Court, and Co-counsel for the defense in this case, not only has personal knowledge about, but was actually involved in, to one degree or another, in the DOI’s investigation on and of Ronald Pierce, going back all the way to at least 2012;
  5. This makes Ms. Stanford a potential witness in this matter, to the extent her clients have made documents and correspondence public, thus waiving attorney-client privilege to that extent;
  6. All the more egregious it is that Ms. Stanford would certify and put forth to this Court discovery responses, when she knew or should have known that such responses were false;
  7. that one of two things happened. Either Ms. Stanford made a reasonable inquiry into the facts (which she already knew) or should have known that such responses were false;
  8. Exhibits P-5, P-6, and S-1 through S-5, attached hereto as though fully set forth herein;
  9. That M. Denise Stanford, ESQ., co-counsel for the Defendants, and an officer of the Court, did engage in civil discovery violations insofar as certifying discovery responses of Shane Guyant and Angela Hatchell, among others, which knew or should have known to be false, to wit, that neither Hatchell nor Guyant had even indirect participation, with respect to investigating Ronald Pierce concerning possible or suspected criminal activity;
  10. That, upon information and belief, Ms. Stanford deliberately suborned a perjured statement(s) of one or more of the DOI defendants; Exhibit’s P-8, P-9, and P-9b attached hereto;
  11. That Ms. Stanford’s involvement in the DOI’s dealings with Ronald Pierce was substantial, and upon belief, she could not have been unaware of defendant Guyant’s involvement with investigating Ronald Pierce;
  12. that the Plaintiff in this case, Ronald Pierce, has been harmed financially by Ms. Stanford’s willful and deceptive conduct, insofar as he has to pay his counsel the sum of $ 2,400 for 8 hours of his time at his rate of $ 300.00, plus any additional fees incurred in prosecuting this motion;
  13. That counsel for the Plaintiff in this case, John D. Mansfield, wasted his time and expended a great deal of time and resources to analyze and respond to deceptive, evasive, and potentially perjured discovery responses; to dutifully inform this Court of such injustices and dilatory tactics;
  14. That I have been practicing law since 1992 and my hourly rate is $ 300.00 per hour for my legal services;
  15. That I spent 8 hours of my time poring through Department records and correspondence, procured through a public records request and other lawful means, comparing them with the deceptive and evasive answers to Plaintiff’s Limited Scope Interrogatories, and drafting this motion and memorandum with the attached exhibits;
  16. There is an outstanding invoice for 8 hours of my time at the rate of $300.00 per hour, which equals $ 2,400.00; a copy of invoice available upon request;
  17. that Ms. M. Denise Stanford’s conduct in regards to the discovery violation, is sanctionable;
  18. That, upon information and belief, because of his close working relationship with Ms. Stanford, as fellow A.G. Co-Counsel, as well as his signatures on discovery responses at issue, Daniel Snipes Johnson should also be sanctioned for his role, in regards to the hereinabove-referenced discovery violations, and;
  19. That the North Carolina Attorney Generals Office, Ms. Stanford’s employer (and Mr. Johnson’s), should be Ordered by this Court to pay $ 2,400.00 in attorney fee’s (plus any additional fees and cost yet to be incurred in prosecuting this motion) to John D. Mansfield, as sanctions for the wrongful and deceptive conduct of Ms. M. Denise Stanford and Daniel Snipes Johnson, as it relates to Rule 26 (g) discovery violations hereinabove described, and factually supported by the evidence in the attached exhibits.
  20. Wherefore, undersigned counsel also requests that Ms. Stanford be required to fully disclose the extent of her involvement with the DOI as it relates to Ronald L. Pierce, produce all documents relating to that involvement, and to withdraw from her representation in this case, if required by the Rules of Professional Conduct.
  21. Finally, undersigned counsel for the Plaintiff seeks such other and further relief that the Court deems just and proper.

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