The Judge Daniel D’Alessandro Case FM-09-1928-14A

Brad Micklin promoted parental alienation in my divorce case. In addition to having to help my mentally unstable wife to understand what is the right thing to do for our son, I also had to fight Brad Micklin's vile motions. At the end, it was my son that lost and my ex wife who was tagged with a huge bill.

Brad M Micklin is the lead attorney and managing member at The Micklin Law Group. Brad was recently added to the Lawyers to Avoid list of the Association for Honest Attorneys (A.H.A.) following multiple complaints on his unethical practices.

Brad Micklin violated the following NJ Rules of Professional Conduct in my case,

R.P.C. 3.2 Expediting Litigation
R.P.C. 3.3 Candor Toward the Tribunal
R.P.C. 3.4 Fairness to Opposing Party and Counsel
R.P.C. 3.7 Lawyer as Witness
R.P.C. 4.1 (a) Truthfulness in Statements to Others
R.P.C. 8.4 Misconduct

I filed the following Attorney Ethics Grievance Form, with the New Jersey Courts, Office of Attorney Ethics. The grievance was docketed by the Secretary of the District Ethics Committee on November 13 2015 with Docket Number: V-C-2015-0018-E and is currently under investigation.

The Supreme Court of New Jersey has held that persons who file grievances “may speak publicly regarding the fact that a grievance was filed, the content of that grievance, and the result of the process.”


            May 7, 2015


 Sent via U.S. PRIORITY MAIL w/USPS Tracking

Office of Attorney Ethics                                                                                                        Mailing Address:   P.O. Box 963 Trenton, New Jersey 08625


            Re:      John ---------- vs. Anastasia -------                                                                    Docket No.  FM-09-1928-14A

            Re:      Attorney Grievance(s)/Complaint(s) against Brad Micklin, Esq.,                                     THE MICKLIN LAW GROUP, and Rachel Isaacs, Esq.



I am submitting this Attorney Grievance complaint against Attorney Brad Micklin, Esq., of the Micklin Law Group, and Attorney Rachel Isaacs, Esq., 187 Washington Avenue, Suite 2F, Nutley, New Jersey 07110,  in the form of a Certification with numbered paragraphs.


Attorney Brad Micklin (and his representative Richard M. Muglia and Rachel Isaacs), performed the following unethical acts while representing my wife, Anastasia ....., in the above captioned divorce matter:

  • Advised Anastasia ..... to follow specific parental alienation tactics to gain unfair advantage in our divorce case, leaving my 3yr old son orphan of a father in the process and causing him intense psychological stress.
  • Orchestrated my being forced out of my primary residence, away from my 3yr old son, so that he could initiate a temporary support motion going after 93% of my income.
  • Made written and verbal (captured in the form of a transcript) false statements he knew were not true to falsely and fraudulently influence a tribunal with false statements of material facts, and offered evidence that he knew were false. (para. 19) (para. 27)
  • Unethically manipulated and delayed for 43 days a settlement already agreed between myself and my ex-wife, defrauding her of over $10,000 in the process, causing me to spend $10,000 in lawyer fees while waiting, and at the end torpedoing the settlement leaving my son orphan of a father and my ex-wife without financial support and indebted to him. (para. 25)
  • Under threat of suing her to recover his legal fees, Brad Micklin has blackmailed my ex-wife to pay my portion of his legal fees, an obligation that the Court has awarded me. (para. 26)


1.     Upon knowledge and belief, Attorney Brad Micklin, representing my wife, Anastasia ------, in the above captioned divorce matter, orchestrated my being forced out of my primary  residence so that he could initiate a temporary support motion. Not only did Micklin involve himself in advising my wife to file a false and fraudulent domestic violence restraining order to get me out, he interfered with our constitutionally protected family relationship and my constitutionally protected parental rights.                                                                                        

2.     On July 10, 2014 I moved out of my apartment fearing my wife’s dilatory actions against my freedoms and well being (She had already called the police following her not letting me sleep for the night).  THE MICKLIN LAW GROUP sent a letter to my lawyer threatening me with a false and fraudulent domestic violence restraining order!! Inside my own house!  (I attach a copy of that letter as EXHIBIT #1).                                                                                         

3.     Even though the letter was sent by Brad Micklin’s associate Rachel Isaacs, Esq., Brad Micklin is ultimately responsible since “the buck stops with him” as his name is on the letterhead of “THE ‘MICKLIN’ LAW GROUP”.     It is apparent that he was advised of this letter by Ms. Isaacs, if not the one who advised Isaacs to submit such a letter.                          

4.     This letter of threat tactic of advising their client to use a false and fraudulent domestic violence restraining order against me constitutes several violations of the New Jersey Rules of Professional Conduct, specifically R.P.C. 3.4(g):

       “A lawyer shall not present, participate in presenting, or threaten to present                criminal charges to obtain an improper advantage in a civil matter”.

5.     Given that the New Jersey Prevention of Domestic Violence Laws involve civil matters and civil remedies, the underlying acts of domestic violence, for it to be domestic violence, range from the 14 criminal causes of action from Homicide to Harassment to Stalking. Therefore, The MICKLIN LAW GROUP, specifically Brad Micklin, Esq. and Rachel Isaacs, Esq., are guilty of violation of R.P.C. 3.4(g).           

6.     Notwithstanding it is a violation to obtain unfair advantage in a civil matter, namely a divorce proceeding in Hudson County Family Court, it is a criminal act of making false statements to public officials (e.g., judges and other judicial officers, law enforcement officers, etc.), namely in violation of New Jersey Criminal Statutes,  N.J.S.A. 2C:28-1 (Perjury); in violation of N.J.S.A. 2C:28-2 (False swearing under oath or equivalent affirmation, since lawyers took an oath to uphold, support and defend the U.S. Constitution and N.J. Constitution, and the laws thereunder);  in violation of N.J.S.A. 2C:28-4 (a) (Giving false reports to law enforcement authorities and falsely incriminating another);  in violation of N.J.S.A. 2C:28-4 (b) (1) (a person reports or causes to be reported to law enforcement authorities an offense or other incident knowing it did not occur); and in violation of N.J.S.A. 2C:28-4 (b)(2)(a person pretends to furnish or causes to be furnished such authorities with information relating to an offense or incident when he/she knows he has no information relating to such offense or incident).                           

7.     Micklin and Isaacs made written false statements they knew were not true to falsely and fraudulently influence a tribunal with false statements of material facts, and offered evidence that the lawyers knew was false, in violation of R.P.C. 3.3 (a)(1) (Candor Toward the Tribunal).

8.     In addition, Micklin and Isaacs violated R.P.C. 3.4 (b)(Fairness to Opposing Party and Counsel) by counseling or assisting their client/witness my ex-wife to testify falsely.

9.     Micklin and Isaacs violated R.P.C. 4.1 (Truthfulness in Statements to Others) by making a false statement of material fact or law to a third party, my attorney, Thomas Sidoti, Esq.                                                                                                                                                       

10.    These false statements by Micklin and Isaacs in advising their client, Ms. Anastasia ------ (my ex-wife), to file a false and fraudulent domestic violence restraining order to have me removed from my marital residence without cause or justification, but using it as a tactic to obtain unfair advantage in a divorce and child custody dispute, also constitutes a violation of R.P.C. 8.4 (Misconduct) wherein it is professional misconduct for a lawyer to:

(a)        engage in conduct involving dishonesty, fraud, deceit or misrepresentation;

(b)       engage in conduct that is prejudicial to the administration of justice;

(c)        engage, in a professional capacity, in conduct involving discrimination  because of race, color, religion, age, sex, sexual orientation, national origin, language, marital status, socioeconomic status, or handicap, where the conduct is intended or likely to cause harm.

11.    Furthermore, these false and fraudulent acts by Micklin and Isaacs to advise their client to file a false and fraudulent domestic violence restraining order against me constitutes the following criminal acts:

(a)        Tampering with witnesses (their client and threatening me as an adversarial witness), in violation of N.J.S.A.  2C:28-5 (a)(1) (Tampering with witnesses to have them testify or inform falsely) and N.J.S.A. 2C:28-5 (a)(5) (obstruct, delay, prevent or impede an official proceeding).

(b)       Micklin and Isaacs, by falsely and fraudulently advising their client, Ms. Anastasia ----- (my ex-wife), to file a false and fraudulent domestic violence restraining order against me were in violation of New Jersey criminal statute, N.J.S.A. 2C:28-7 (Tampering with information), specifically N.J.S.A. 2C:28-7(a)(2) (Makes, presents, offers for filing, or uses any record, document or thing knowing it to be false, and with purpose that it be taken as a genuine part of information).


12.       These false and fraudulent acts by Micklin and Isaacs constitute Obstruction of the Administration of Law, in violation of N.J.S.A. 2C:29-1 ( A person commits an offense if he/she purposely obstructs, impairs or perverts the administration of law by unlawful acts.                  

13.       These criminal acts by Micklin and Isaacs in advising their client to file false domestic violence restraining orders would also constitute Offering a false instrument for filing that contains false statements or false information, in violation of N.J.S.A. 2C:21-3 (b) (Offering a false instrument for filing), and in violation of N.J.S.A. 2C:21-4 (Falsifying or tampering with records) because the record contains false statement(s) or information with purpose to deceive or injure anyone or to conceal any wrongdoing.


14.       This July 10, 2014 letter to my attorneys that I woke up my 3 year-old child, the child only woke up when my wife called the police and she had to come out of the room to explain to them why she called them. When her explanation was “he is giving me a divorce…” they brushed her off and told her to never call them again “for such frivolous complaints”. See copy of July 11, 2014 letter from my attorney, Thomas Sidoti, Esq., to Defendant Anastasia ------ (my ex-wife)’ attorney, Rachel Isaacs, Esq., of THE MICKLIN LAW GROUP as EXHIBIT #2.                                          

15.       Because of the very physical and emotional abusive behavior of my wife, Defendant Anastasia ---- (my ex-wife), I moved out of my residence on July 10, 2014.  Six (6) days later I received a Pendente Lite support motion from my wife’s attorney, Brad Micklin, Esq, dated July 10 2014.  It took Micklin 0 days to prepare this voluminous motion, yet later that year (2014) it took him 45 days to review a draft proposal of a 4-page settlement agreement that he “torpedoed”.                                                     

16.       I had initiated the divorce while staying in the apartment with my child and wife and I had no intention of leaving until the divorce was over.  I simply did not want to put my family at risk. I accuse Brad Micklin of advising my wife to harass me constantly and not let me sleep to call the police on me so that I was forced to leave and so that he could initiate the Pendente Lite motion.                                                                                                                   

17.       In the 7/10/2014 certification in support of the Pendente Lite motion,  Brad Micklin convinced my wife to ask for 93% of my net income (before 401Kdeductions).  This is insane!! Is this man a lunatic? How is it even possible that when I was living in the same house I was only using 7% of my net income for my own expenses?! This man is a liar and deceived the court, in violation of R.P.C. 3.3, R.P.C. 3.4, R.P.C. 8.4.

18.       This act of filing a Pendente  Lite motion that was fraught with false statements, frauds, and fabrications placed my son’s well being at risk. 93% of my net income as temporary support to my wife means that I would automatically lose my dwelling and thus my job. It meant that my son would stay without a source of income and without a father.  My net MONTHLY salary was $7,100.  Micklin asked as temporary support (all schedule A, B, C expenses totaling $6,600.00).  This was a fraudulent and false statement being made without any hearing to vet the information or ability to pay.  By fraudulently getting the Court to award his client 93%, (violation of R.P.C. 3.3 and R.P.C. 8.4), it forced me to have to return to my home country, Greece.                                                                                                                                              

19.       After 3 weeks when I returned from Greece to give this another try and put my freedom on the line for my son (although I knew I would go to jail) Brad Micklin wrote a despicable certification for Defendant Anastasia ----- (my ex-wife) which I attach (attachment#1 – August 27). This is a disgrace to the attorney’s ethics. It is full of lies and mud. I list them one by one:

a.     Attachment#3, page 3: “The Plaintiff fled the United States, created more debt, and provided no support.”

Here Brad Micklin is diluting the truth. I did leave the US for 3 weeks but I neither created more debt nor provided no support. I paid $3,802 for July (which is what my ex-wife’s total real expenses were) and $2,960 in August in support of my ex wife!!! With proof that I have already submitted to the Court. And he claims I did not provide any support!! In addition my wife at the time had withdrawn $21,000 of our joint assets!!!

Proof: Attachment#4, APPENDIX E – Payments to Defendant during July/August.

b.     Attachment#3, page 4: “The Plaintiff does not have the ability to care for Alexander”.

I have been a father to my son for 3 years, I was with him when he was born, I saw him before his mother did, I would sleep and wake up with him, I taught him how to float in the swimming pool, how to ride the scooter, how to play the solfege on the piano, we were cooking together while I was holding him in my arms teaching him the names of the vegetables, the fruits, the different spices, I would feed and protect him, I taught him the letters of the Greek and English alphabet, the names of animals, the numbers, I taught him how to speak, I was an amazing father. There is no evidence I am a bad father and never had any incidence of reported violence, not one iota of proof of anything. How was it that in her original certification my wife had accepted the joint legal and physical custody? (page 5 of Attachment#5, 8.c).

How is it that 6 months later the defendant proposed joint legal custody of our kid in return to $16,425K cash in order to end the divorce? (page 4 of 8 Custody/Parenting Time of Attachment#6).

I was and am of no threat to my son and I have submitted to the court evidence to prove that (Available upon request). The following notarized letter by my appointed ‘supervisor’ is further substantiating this:

Notarized Affidavid Supervisor


20.       Throughout the hearings when I was mostly pro se, Brad Micklin swamped the Judge with lies one after the other taking advantage of his knowing the system. He would interrupt me and create a false sense of my being a bad guy in court. He would misrepresent and alter what I said to confuse the judge who ended up being incompetent himself. He also revealed to Court confidential emails between myself my ex wife and a friend of ours who agreed to help us settle under the agreement that our communication would be confidential.  These acts by Micklin constituted violations of R.P.C. 3.3, R.P.C. 3.4, and R.P.C. 3.7 (Attorney cannot act as a witness and attorney in the same case).                                                                                            

21.       Herein lies the problem.  Brad Micklin has made many unsubstantiated, unbridled, and false statements against me in open Court.  He has no proof to back up what he says. He is making false and fraudulent statements as a witness and not as an attorney.  Micklin and his associations and lawfirm, THE MICKLIN GROUP, should be removed from the case for acting as hostile witnesses and attorneys in the same case.  As the caselaw states, a lawyer’s statements or comments are not evidence.
            Defendant’s attorney, Brad Micklin, Esq.,  is making statements and certifying to facts within the primary knowledge of his client, which is prohibited by the Rules of Professional Conduct, R.P.C. 3.7 (an attorney cannot act as a necessary witness and advocate in the same case).  See also, Pressler & Veniero, Current N.J. Court Rules, comment on R. 1:6-6 (2011); Higgins v. Thurber, 413 N.J. Super. 1, 21 n. 19, 992 A.2d 50 (App. Div. 2010), aff’d, 205 N.J. 227, 14 A.3d 745 (2011).                   
            Attorneys written statements are not evidence.  Hickman v. Taylor,   329 U.S. 495 (1947).   Statements of counsel are not facts before the Court.  Statements of counsel are unsworn and therefore cannot be considered.  United States v. Lovasco, 431 U.S. 783, 97 S.Ct. 2044, 52 L. Ed. 2d 752 (1977).
            Further, counsel's statements in motion briefs that are neither of record, judicially noticeable, nor stipulated do not constitute cognizable facts. See, e.g., Gonzalez v. Ideal Tile Importing Co., 371 N.J. Super. 349, 358 (App. Div. 2004), aff'd, 184 N.J. 415; Templeton Arms v. Feins, 220 N.J. Super. 1, 24 (App. Div. 1987).
            Statements of counsel in their briefs or argument while enlightening to the Court are not sufficient for purposes of granting a motion to dismiss or summary judgment.  Trinsey v. Pagliaro, 229 F.Supp. 647, 649 (E.D. Pa. 1964).                                                                              

22.       Here is a list of attacks, unprofessional sarcasm, and falsification of my statements that this criminal threw at me...this was happening while I was desperately trying to keep my tears from bursting out since I could clearly see that I would lose my son:

Transcript 11/14/2014, p.4 (EXHIBIT #3)

JOHN: I did not pay the entire amount

THE COURT: How much do you say you owe?

JOHN: Im sorry, I don’t have the number – in front of me

[here Brad Micklin passes in front of me a piece of paper with over 40 numbers]

MR MICKLIN:  Actually, Judge, he does have the number in front of him. I handed him the number.

JOHN: Im sorry, Im just not sure. Is it this one?

[here Micklin circles a number at the piece of paper]

MICKLIN: It’s the number that’s circled there. It says current balance.

JOHN: Thank you



Transcript 11/14/2014, p.4

Then after I was unemployed for 3 months and could not pay the entire rent for my ex wife instead of accepting my proposal to use my part of the 401K balance my wife had accrued he suggested I was thrown out of my apartment! This criminal knew that by doing that I would lose my job but he did not care!!!


JOHN: I really don’t know what to do. I don’t have the money.

MICKLIN: Judge, my suggestion, I believe he lives relatively close and his rent is paid. I would ask for a temporary possession of his apartment.

THE COURT: do you agree to that?

JOHN: I don’t understand how I will be able to continue going to work. I live in a studio.

THE COURT: Mr Micklin do you mean that they will live together?

MICKLIN: No, no, no, that he moves somewhere!!


Total disrespect to whether my son would be evicted from his primary residence, He proposes arbitrarily for my son to move out of his room out of the apartment that he was raised on just to throw me on the streets, to terrorize me. We had money on the side in the form of my wife’s 401K, alternatively my wife could borrow money for a month till I got my first paycheck but he chose to terrorize me instead!!


Transcript 11/14/2014, p.10

The Judge then asks the obvious question--does my wife have any other place to stay? Since she refuses to work, since she refused to cash out our 401K , since it made no sense for me to lose my job the only other solution was for her to move to her cousin who was 45 minutes away or to our own apartments in Maryland! In Maryland is the only other place that my son knew and loved, a luxury place with an Olympic-size swimming pool. But Brad Micklin SHUTS DOWN THE JUDGE!! The only other solution that would ensure my son would keep enjoying a source of income and a father!!


THE COURT: Do you have any other place to stay?

MR MICKLIN: Judge respectfully to even ask that question when she has a child, when there’s a support order in effect ----

THE COURT: I understand, but I want to know what the options are.


Transcript 11/14/2014, p.11

Then he falsifies the reasons I left my apartment. I left my home because my wife was abusing me and calling the police on me. I was afraid of being deprived of my freedom on false and fraudulent allegations.  I wanted to protect my kid who would lose his only source of income if I were jailed like many fathers have under the false claims of bitter spouses. I am a father fighting for my child and here is what this malicious attorney comes to court and says instead of trying to find a solution!! After he went after me for 93% of my income and piled up a ton of lawyer fees he accuses me of breaking down and does not even recognize that I am back to defend my son’s right to equal access to both of his parents.


MICKLIN: I’d ask the court to be mindful, and I’m sure Your Honor is, that JOHN elected to get his own luxury apartment, elected to quit his job and flee the country, causing this situation.


Transcript 11/14/2014, p.12

He then does the unthinkable, while I was just 3 weeks from my first paycheck, with a freshly landed job….he asks for my imprisonment. The surefire way for me to lose my job.  This was a false and fraudulent statement.  It was a criminal act by Micklin making false testimony, in violation of R.P.C. 3.7.  Who jails a father for a CIVIL DEBT that is a violation of constitutional law?  Who jails a father that is fighting for the well being  of his son just because he was able to pay 60% of his net income and not 84%, reduced down from 93%.


MICKLIN:  I would ask, Judge, since he’s acknowledged under oath that he’s failed to comply with the order, not only for the rent but for the PL and for my legal fees, that Your Honor award that come Monday, if he’s not up to date, that a warrant for his arrest issue. I’m pretty sure he’ll get the money by then, Judge. There’s no incentive right now for him to do that.

            Again, Micklin asking for criminal sanctions in a civil matter, in violation of R.P.C. 3.4(g).


Transcript 11/14/2014, p.14

Then I suggest the defendant moves in with her cousin if she does not want to use the funds she got out of our joint assets. While I try to find a viable solution, Micklin keeps interrupting the process, thus obstructing of the administration of law and tampering with the case:


THE COURT: Where does her cousin live?

JOHN: I will have to refer to the defendant.

MICKLIN: See Judge the statements by the plaintiff show his motivations by not paying again, he’s managed to pay his rent current but he comes in here talking about my client’s 401K, my client’s ability to earn money which just shows you he’s just thumbing his nose at the Court because he wants her to work.


These false statements to the Court are not only the attorney testifying (testilying) as a witness, but they are criminal acts of making false statements to the Court, and tampering with the case.  I want my 3-yr unemployed wife to stop listening to the lies of this attorney (that she could live off of me for the next 10 years) and go find a job to help me get schooling for my child. And it is not “HER 401K”,  it is “OUR 401K”. These are joint assets on which she accrued thousands of dollars in interest while she was unemployed studying for her fashion degree while I was working my ass off. And yes, of course I will pay my rent first since I have already provided $21,000 to my wife that she can use at her discretion and since if I don’t have a place to stay she will get nothing.  I will not be able to provide anything to my son if I am homeless, which is what ended up happening.




Transcript 11/14/2014, p.17


MICKLIN: The interesting thing, Judge, is he didn’t pay my fees pursuant to your honors order, he didn’t pay the rent and he didn’t pay the PL money but he paid his lawyers.


First of all I still owe money to my lawyers because Micklin left me broke and impoverished based on false and fraudulent allegations he made to the Court. Second, of course I will pay my lawyers first because I have provided $21,000 to my wife to cover everything she needs to cover.  Micklin’s fees have been paid many times over and he has been lying that they have not. I have to defend myself against these false allegations to the Court . And, I have been forced to represent myself pro se  because Micklin caused me to be impoverished.


Transcript 11/14/2014, p.19

JOHN: I’m not saying that this is a good situation. I don’t want to see my son go out there but I warned the defendant. I told her that I do not have the money. I am not able to support this.

[MICKLIN interrupts me]

MICKLIN: Judge, and that’s what’s most troubling is that he’s made it clear to her that he’s not going to and it should be his way.


Which way?  The way that there is not enough money to support a luxury apartment and $40,000 in frivolous motions? Yes that is THE way;  not my way. That is the way of reason. Micklin falsely represents to the Court as if I have a masterplan to kick my son and ex wife on the street. He criminalizes a father who had everything in place for his ex wife and son till he stepped in.  He is criminalizing me in a CIVIL matter.



Transcript 11/18/2014, p.11

On November 18 Brad Micklin was the instigator of a crime. He was the mastermind behind leaving my son orphan. He misrepresented the truth, he lied to the court. A friend of ours had offered to help us find a settlement. We had all agreed to keep our discussions confidential away from lawyers. He did not offer to help us financially but as a mediator. The discussions were going very well until the friend offered to lend us $10,000 to cover the rent of my wife’s apartment. After I explained to him that I would be unable to pay him off due to the 84% requirement on my salary and after I explained that next month he will have to repeat his offer and give us more money he understood that this offer was of no value. It would just put us in debt and he would have never gotten his money back.


23.       On November 18, my ex-wife broke, with high probability on advise of

her attorney, Micklin, our confidentiality agreement and mentioned in court the discussion but Micklin completely altered it.  Micklin presented it as if our friend gave us the money and I threw it back at him following some type of strategy. Instead of looking at the facts, at what is viable, this criminal presented me as a liar. I was merely following our confidentiality agreement that my ex wife broke to the best interest of my child. Micklin even misrepresented our family ties with my friend to make it appear as if we were handed the money by a relative.                       24.       We had agreed with my ex wife to not mention this event.  We had an agreement. I could have easily referred to it in the hearing and explain what happened. But my ex-wife/MICKLIN framed me to make me appear as a liar. If there was such a breakthrough offer that I threw out the window why would I ever conceal it from the Court? Since I knew that my wife had such an email in her hands it would make absolute sense that she would bring it over. But we had agreed not to talk about it and that is why I did not mention it.

 Transcript November 18, 2014 p.11 (EXHIBIT #4).


“MICKLIN:  First, I believe the plaintiff is being less than candid to the Court. My client advises me that his uncle had e-mailed him with a copy where he was offering to pay this money and to assist him in catching up and he rejected it.


JOHN: Judge, the gentleman that Mr. Micklin is referring to is not my uncle, he’s a friend of my dad’s and he offered to provide us $7,500. When I explained to him that I will not be able to pay him back and when I explained to him that the next month we’re going to need a big amount, the same amount, he pulled back. I called him, I called friends. They know the situation and because they understand that I will not be able to pay them back they’re not anymore offering to pay that money. “

[so the malicious attorney Micklin commences on his plan to misrepresent what I said]


Transcript November 18, 2014, p12.


“MICKLIN:  Judge, my problem with everything he’s saying is that it’s – first of all, aside from the fact that he’s lying to the Court because he told your Honor a minute ago that he didn’t have anybody that he could borrow money from. Now he’s saying, when I brought it to the Court’s attention that he’s lying he said, well, he can’t pay it back but he told you a minute ago he’s making $120,000 and looking for $150,000.”


Herein, Micklin makes several fraudulent and false representations about me “lying” to the Court to improperly and illegally inflame and prejudice the Court with false statements to public officials, in order to manipulate, obstruct, and tamper with the case, evidence, and witness (me) by painting me in a “bad light” with the Court.


Transcript November 18, 2014, p13.


MICKLIN: “He simply stopped paying once Your Honor made it an order and that’s the problem, Judge, is that he’s doing this so he can retain control of this and while giving my client temporary possession of the apartment is a step in the right direction, I still think a warrant should issue for his arrest if he doesn’t have it paid up to date in 48 hours.”

THE COURT: I understand. How much are his arrears today?

MICKLIN: “…What I think he wants to do, Judge, is force her into either having to agree to a different support amount that he wants to pay or force her to have to live where he wants her to because he’s living nicely and rejecting money people are offering and lying to the Court about it.

JOHN: That’s not true, I’m really sorry. I did not lie to the Court. I said that I cannot borrow because when I reached back to the gentleman that offered that money he was more aware of what’s going on and he refused to give me the money and I can have him give me a written statement for that.


[now Micklin starts blurting nonsense saying absolutely nothing trying to confuse the Judge that I am saying something different than what I said before. How exactly is this helping my child? In my first statement I said exactly what I said in my former statement]


MICKLIN: Now, see, Judge, that’s interesting because that’s now the second story because a moment ago he said – he told him he couldn’t pay him back he rejected it. Now he’s saying that  because the man learned more about the story he’s not willing to offer it. So, I don’t know which story he ants us to believe, Judge, but the simple fact is he should have borrowed money if it was offered to him regardless of whether he could pay it back o he could comply with the Court order and make sure his wife and son are fed.”



Listen to what this man says!!! “He should have borrowed money regardless of whether he could pay it back so he could comply with the Court order!!!” Defraud my friends of their money so that Micklin can buy his son expensive shoes. So that my  ex wife can stay unemployed!! No ne of this money would have gone to my son’s well being. I would have been indebted to the point I would have not been able to provide anything to my son. And for what!? So that my ex wife could sit on her ass and not go back to her $75,000 career cause she was bitter.



25.       On December 2014, Brad Micklin sabotaged the already agreed settlement I had drafted with my wife, defrauding us of $20,000 ($10,000 lawyer fees I had to incur and $10,000 my wife had to incur) and leaving my son orphan of a father. On December 5th 2014 my wife and I agreed on a settlement. Brad Micklin dragged his review for 43 days and finally delivered an altered settlement that was totally different from our original agreement. After I crossed out all the fraudulent alterations he had made, he further delayed the process and eventually after 2 weeks sent me the original settlement (with a few additions)! Which means that he had fraudulently added changes to the original agreement with no purpose. But 43 days had passed during which I had paid all of my offer money to my attorney and he had charged almost $10,000 to my ex wife thus totally torpedoing the core benefit that the settlement had for my wife.



The settlement my wife and I had originally agreed on gave my wife far more money and privileges than what the Judge eventually gave her, than what Brad Micklin tricked her to go after. Below I compare the settlement agreement I had with my wife and what Brad Micklin eventually managed to get her by sabotaging our agreement. I am doing this to show that he was not trying to protect her in any way from some “malicious” offer I made:


- On December 5th 2014 my ex-wife and I agreed on the above points informally (see detailed settlement as Attachment 9). I had the necessary money to fulfill the lump-sum requirement and my ex-wife agreed to have the settlement signed within a matter of days. At the time I was pro se. So I hired an attorney to take care of the settlement process.

- On December 10 my ex-wife sent me the below email:

----- Forwarded Message -----
From: Anastasia .....<>
To: John ...... <>;
Sent: Wednesday, December 10, 2014 4:49 AM
Subject: Settlement Update

I have followed up with my attorney to see how soon they can get the formal agreement drafted (considering all the other cases) and have it ready for signatures by the end of this week if not early next week.

- On December 11 my ex-wife sends me the below email:

----- Forwarded Message -----
From: Anastasia .........
To: John .........
Sent: Thursday, December 11, 2014 5:42 PM
Subject: Settlement Update


I have been following up with my attorney and there is progress made they are drafting it but they have other urgent customers to work with. Having said that the original estimate of this Friday or latest Monday seems to be the more accurate. I will let you know as soon as I have a definitive answer today.


- On December 15 my ex-wife sends me the below email having been frustrated with Brad Micklin’s stalling:

----- Forwarded Message -----
From: Anastasia .........
To: John .........
Sent: Monday, December 15, 2014 4:28 PM
Subject: Question

When you speak to your lawyer ask her how much I should expect to pay another attorney to review/draft the settlement and how much time if I go somewhere else.
1pm or evenings work for Alexander.

- On December 15 my ex-wife writes to me on Skype:

Skype, Anastasia .......:

“I have found another lawyer if mine does not do the settlement.”

- On December 16 my ex-wife sends me the below email:

----- Forwarded Message -----
From: Anastasia
To: John .........
Sent: Tuesday, December 16, 2014 5:35 PM
Subject: Settlement

Thank you for asking her. Give me this week to see what my lawyer will really do so that I can have a cause/proof that he did not follow my orders so that I can file a grief against him. Following that we can follow with the scenario you are suggesting. For now he told me that he will send a simple letter as a response to the motion and he will start the settlement drafting.

Please continue to send me recorded videos of you playing songs on the guitar and keep calling him [Alexander] on skype. He [Alexander] likes the guitar a lot for obvious reasons and the violin.

- On December 19 Brad Micklin suddenly becomes active on our case and asks the Judge for an adjournment of an upcoming hearing scheduled for December 22 2015 claiming he is working on the settlement (Besides the above emails sent from my frustrated ex-wife). My lawyer advises me against the adjournment and that she has verbally refused it. My lawyer specifically writes to me:

“The court has required that I put this in writing. Even though I am out of the office, I am forwarding this letter below. As soon as I get your approval, I will send it.

The bottom line is they have all weekend to draw up the settlement and you can tell your wife that they did not agree when we asked.

Also, I have questions regarding her true intentions. I do not think settlement is on her agenda at all.

If we give them more time, they may just use it to respond adequately to our motion which may not be good for you. “

- On December 22, during the hearing, my lawyer exposes Brad Micklin in Court. Below are excerpts of the trial (Brad Micklin claimed sick on that day and he sent in his place Richard Muglia of the Micklin Law Group):

Transcript December 22, 2014, p5. (ATTACHMENT #10) my lawyer speaking:

Instead of Richard Muglia admitting there was a settlement on the table he went on to seek enforcement on what I was allegedly owing to my ex-wife. His intentions were revealed on this hearing. His intentions were to delay and sabotage the settlement so that he could bring me on my knees financially so that he could keep sucking money out of my ex-wife. Even the Judge questioned his actions. Richard Muglia responds with a lie. Up to that moment I had been providing support every month to the tune of over $2,400 per month:

Transcript December 22, 2014, p6. (ATTACHMENT #10), Judge speaking:

Then Mr Muglia proceeds with lying to the Court indicating the case is not settled. My wife and I had a settlement and the only thing he had to do was put it on paper and give it to us to sign it. Also at that stage, there had been 18 days were Brad Miclkin had done absolutely nothing, he had refused to put together a 4 page settlement:

Transcript December 22, 2014, p9. (ATTACHMENT #10), Judge speaking:

Then Richard Muglia proceeds with lying to the Court again that I was the one that prepared the settlement. Attachment#9 includes the email I received from my ex-wife where she has worked out the settlement and delivered it to me, the attachment includes everything she added and crossed out. We worked on the settlement together. Richard Muglia is deliberately lying to deceive the Court:

Transcript December 22, 2014, p9, line 25. (ATTACHMENT #10):

My attorney then points out the obvious, the reason I have brought that day that man in Court:

Transcript December 22, 2014, p10 (ATTACHMENT #10):

And my attorney continues:

Transcript December 22, 2014, p11 (ATTACHMENT #10):

Battling with the incompetence of the Judge who refuses to understand what is going on, my attorney continues:

Transcript December 22, 2014, p13 (ATTACHMENT #10):

Then besides my ex-wife and I being in the middle of a settlement, Brad Micklin, via his representative Richard Muglia, asks for my arrest!!

Transcript December 22, 2014, p23 (ATTACHMENT #10):

My attorney points out the true motives behind Brad Micklin’s request to arrest me. In my cross motion I was simply asking to see my son. Brad Micklin has been preaching parental alienation tactics to my ex-wife which culminated to his request to arrest me because I refused to surrender my fundamental right to travel by handing over my passports to the Court:

Transcript December 22, 2014, p25 (ATTACHMENT #10):

- On January 2nd 2015 Brad Micklin after 4 weeks of unnecessary delay sends my attorney a draft settlement that has been totally altered with clauses that are beyond what we agreed with my ex-wife (Attachment#11). He has altered the settlement to sabotage our agreement and further minimize any possibility I have to stand back on my feet. Every day that passes renders it more impossible for me to find a job and get back to my son.

- On January 5th 2015 my attorney responds to the totally altered settlement refusing all of the added clauses.

- On January 19 2015, with close to 2 weeks delay, Brad Micklin accepts almost ALL of the clauses I removed (See Attachment #12), clearly showing that he was simply buying time. My ex-wife did not want any of the clauses added by him and she was frustrated with this process the same way I was. Still, he retains in the settlement clauses that increased the risk of my landing in jail for no reason leaving my son orphan.

- By January 19 2015, I have now exhausted all of my lump sum money in this relentless settlement delay. I am forced to alter the settlement agreement removing the lump sum at which point the settlement collapses.

26. On July 21 2015, Judge Daniel D’Alessandro awarded me the payment of $38,520 of Brad’s legal fees (Attachment#13, p.4, clauses 25, 26). Instead of Brad honoring the Judge’s decision, he went after my ex-wife, blackmailed her that if she does not pay him the entire lump sum awarded to me he will sue her, and stroke a deal for her to be paying him a small fee every month for an indefinite number of months. This arrangement has to be investigated, my ex-wife contacted by you, and you should determine exactly what she has been forced to pay him illegally and what her illegal arrangement with Brad Micklin is. This man threatened to put in jail single mom with a kid that was left orphan of a father because of his parental alienation actions.

27. Violation of R.P.C 4.1 Truthfulness in Statements to Others. On November 18 2014, before Judge D’Alessandro, attorney Brad Micklin made the following statement to the Court (Attachment#8 accompanying original Grievance, pg 21/22):

I am requesting that Brad Micklin provides proof of how he came up to the conclusion that I have a controlling abusive nature. A conclusion he presented to the Court as fact! What is that paperwork he is referring to that shows I am abusive and controlling?

There is not a single record with authorities of my being abusive, not a single record with authorities that I am controlling or anything close to that accusation. I have been with my ex-wife for 3 years, if I were abusive and controlling wouldn’t there be at least some evidence lying around? If I had temper issues would I have been able to retain a 14yr career without a single day of unemployment?

All of my motions up to the moment a warrant for my arrest was issued included absolutely no bad mouthing of my wife since I did not want my child to have any record of us accusing each other of anything bad. That is the level of ethics I exhibited during that divorce. A level of ethics that got bulldozed by the unethical machine called Brad Micklin.


A kid is orphan, without a dad for 12 months. My ex-wife had agreed on a settlement that would have made sure my son could have a dad. Brad Micklin, violated his client’s trust, raped my son’s emotional well being, dragged the process unnecessarily for 43 days all in order to make more money.

This man has to be stripped of his license and penalized for what he did to my son.



            I certify that the foregoing statements made by me are true.  I am aware that if any of the

foregoing statements made by me are willfully false, I am subject to punishment.




Dated:  May 8, 2015                                       _________________________________________                                                                          John, Plaintiff, pro se