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TracieM.

Hunter,Judge
POBox11007
Cincinnati,Ohio45211
January8,2016
RichardA.Dove,Secretary
BoardofCommissionersonGrievancesandDiscipline
65SouthFrontStreet,5thFloor
Columbus,Ohio432153431
RE:ComplaintagainstKatherinePridemore,Esq.
DearMr.Dove:
Aftermultiplepublicrecordsrequests,ithascometomyattentionthat Assistant Hamilton
County Prosecutor Katie Pridemore violated rules: 1.0; 3.4, 3.5 and 8.4 of the Ohio Rules of
Professional Conduct when she fabricated evidence during a jury trial and falsely testified that
she was commissioned by the Ohio Supreme Court (hereafter OSC) to conduct an investigation
of Judge Tracie M. Hunter. Not only has the OSC denied authorizing any such investigation, I
am unaware of any laws or rules that would have authorized such investigation without Judge
Hunters Knowledge and ability to respond. It is upon good information and belief that in
conducting such unauthorized investigation, Ms. Pridemore gained unauthorized access to cases
appearing before Judge Hunter that she was prohibited by law to access, due to the prosecutors
direct interest in all such cases. Ms. Pridemore testified as the States key witness against Judge
Hunter, knowing such evidence was false, but did so with purpose to unlawfully influence a jury.
The Ohio Rules of Professional Conduct defines Fraud in Section 1.0 (d). Fraud or fraudulent
denotes conduct that has an intent to deceive and is either of the following: (1) an actual or
implied misrepresentation of a material fact that is made either with knowledge of its falsity or
with such utter disregard and recklessness about its falsity that knowledge may be inferred; (2) a
knowing concealment of a material fact where there is a duty to disclose the material fact.
During a jury trial between September-October 2014 in which Judge Tracie Hunter was named
as a Defendant following accusations by employees of Hamilton County Prosecutor Joe Deters,
Ms. Pridemore testified repeatedly that the Ohio Supreme Court instructed her to spy on Judge
Tracie M. Hunter and to prepare a report that the Ohio Supreme Court could use to build a case
against Judge Hunter to remove her from office. In her testimony, Ms. Pridemore repeatedly
referenced a 50-page report that she was commissioned to prepare at the direction of the OSC,
but never produced the report that she used to influence a jury in violation of the Rules of
Evidence, Rules of Professional Conduct and, more significantly, the law. Ms. Pridemore made
inaccurate assertions about Judge Hunters cases and inflammatory statements about Judge
Hunters character with no evidence to support her statements in violation of Rule 1(d)(1)(2).

Ms. Pridemore repeatedly invoked the OSC as her authority to watch Judge Hunter. If the OSC
had undertaken an independent investigation of Judge Hunter, the rules of Superintendence,
ORC and the Ohio and the United States Constitution would have entitled Judge Hunter to be
notified in order to respond or would implicate serious constitutional concerns of due process.
Based on Ms. Pridemores testimony, reporter and PHD student Vanessa Enoch filed an open
records request with the Ohio Supreme Court to secure a copy of the report and all
communications associated with the report that Katie referenced during her testimony. The Ohio
Supreme Court responded that no such reports or communications existed and that they did not
request Katie to do the report that she alleged to have been authorized by the OSC. Ex. A. Judge
Hunter subsequently filed a records request for a copy all communications and records from the
Ohio Supreme Court authorizing Ms. Pridemore to conduct an investigation of Judge Hunter
based on her repeated testimony indicating she prepared a report at their request. The Chief
Counsel and Administrative Director sent correspondence denying such communication existed.
Ex. B
If the OSC responded truthfully, Ms. Pridemores testimony, based on the OSCs response, was
fraudulent in that she represented herself as an agent of the OSC, performing an investigation of
Judge Hunter at their direction. Ms. Pridemore knew at the time she testified against Judge
Hunter that such statement was false, and therefore fraudulent, as defined above and was only
made with one purpose, to improperly influence a jury. The Cincinnati Enquirer identified Ms.
Pridemore as one of the states most compelling and critical star witnesses against Judge Hunter,
demonstrating how much weight was given her false testimony. Ex. C
Katie engaged in all such conduct defined as fraudulent in her accusations against Judge Tracie
M. Hunter, in violation of the law and the rules of ethics governing lawyers.
RULE 3.4: FAIRNESS TO OPPOSING PARTY AND COUNSEL
A lawyer shall not do any of the following: (b) falsify evidence, counsel or assist a witness to
testify falsely, or offer an inducement to a witness that is prohibited by law; (e) in trial, allude to
any matter that the lawyer does not reasonably believe is relevant or that will not be supported by
admissible evidence or by a good -faith belief that such evidence may exist, assert personal
knowledge of facts in issue except when testifying as a witness, or state a personal opinion as to
the justness of a cause, the credibility of a witness, the culpability of a civil litigant , or the guilt
or innocence of an accused;
Katie violated Rule 3. 4(b) when she presented false testimony to a petit jury regarding her being
commissioned by the OSC to investigate Judge Hunter and prepare a report.
Katie violated Rule 3.4(e) when she testified about a report that she knew would not be
supported by admissible evidence as it was false and never presented in violation of the rules.
Katie made brought sweeping statements about Judge Hunter with no evidence to support her
statements, accusing her of hating prosecutors and running juvenile cases into the ground. Those
comments were unethical, baseless, false and made in reckless disregard for the truth.

Katie testified that Judge Hunter disrespected and held prosecutors in contempt for no reason.
Ms. Pridemore did not produce any specific examples either by videotape or audiotape or any
other tangible evidence of Judge Hunter disrespecting any prosecutor. All of Judge Hunters
hearings were videotaped with sound. In fact, Judge Hunter only threatened one assistant
prosecutor with contempt in her courtroom, Charles Lippert, when he blatantly refused to follow
a court order to turn over discovery for an in camera inspection as the law required. Ms.
Pridemore failed to also testify that in that one case, Judge Hunter withdrew her contempt action
against Charles. Ms. Pridemore testified that there were multiple prosecutors held in contempt, a
statement she knew was false when it was made in open court with the intent to influence a jury.
Ms. Pridemores testimony proved, however, that contrary to Ms. Pridemores testimony,
prosecutors in Hamilton County Juvenile Court disrespected and disregarded Judge Hunters
authority, the same as all other Judges, to exercise contempt powers when lawyers blatantly
failed to follow laws, rules of procedure or judicial orders in her courtroom. Ms. Pridemore also
failed to truthfully testify that Judge Hunter held multiple defense lawyers in contempt for failing
to show up during scheduled hearings on several occasions, in comparison to a single prosecutor,
when she falsely testified that Judge Hunter treated prosecutors differently in her courtroom.
Ms. Pridemores statements were not only false, but also irrelevant to the charges and violated
rule 3.4(e). She said that the First District overturned Judge Hunter all the time, implying that
other Hamilton County Judges had never been overturned, including those on the First District
Court of Appeals, Common Pleas Court and other courts, intentionally misleading the jury to
conclude that Judge Hunter lacked judicial authority to rule independently of the prosecutors.
Ms. Pridemore basically testified that Judge Hunter was guilty of crime for being overruled. Ms.
Pridemore failed to testify of the times that Judge Hunters decisions and rulings were affirmed.
Ms. Pridemore testified to persuade a jury that the Ohio Supreme Court
backed up her allegations against Judge Hunter. If a complaint is made to the
OSC about a Judge, per the disciplinary process, the Judge would be notified
and allowed to respond to any complaints made by a third party. Judge
Hunter was never notified by the OSC that Katie had filed a complaint and
that Katie was investigating Judge Hunter at the direction of the OSC. If that
had occurred, Judge Hunter would have been legally entitled to respond.
Based on Katies testimony, Judge Hunter contacted the OSC and requested
all records associated with Katies testimony. Additionally, Judge Hunter
secured a response by the Ohio Supreme Court to an independent media
outlet that requested more exhaustive information regarding Ms. Pridemores
testimony. The Ohio Supreme Court denied that it conducted, authorized or
requested any investigation of Judge Hunter by Katie. A copy of both records
requests and the corresponding responses from the OSC are enclosed.
RULE 3.5: IMPARTIALITY AND DECORUM OF THE TRIBUNAL
(a) A lawyer shall not do any of the following: (1) seek to influence a judicial officer, juror,
prospective juror, or other official by means prohibited by law; (b) A lawyer shall reveal
promptly to the tribunal improper conduct by a juror or prospective juror, or by another

toward a juror, prospective juror, or family member of a juror or prospective juror, of


which the lawyer has knowledge.
The trial transcript and the enclosed documents will evidence that Katie falsely testified during
an official legal proceeding with intent to improperly and illegally influence a judge (judicial
officer), jury and prospective jurors against Judge Hunter, to rely on her false testimony. Ex. C.
Rule 8.2 JUDICIAL OFFICIALS
(a) A lawyer shall not make a statement that the lawyer knows to be false or with reckless
disregard as to its truth or falsity concerning the qualifications or integrity of a judicial
officer, or candidate for election or appointment to judicial office.
Katie made innumerable statements about Judge Hunter that she knew to be false or with
reckless disregard as to truth or falsity in violation of the law and rules of ethics. Her broad
sweeping statements were neither supported by facts, law or tangible evidence when made.
RULE 8.4: MISCONDUCT
It is professional misconduct for a lawyer to do any of the following: (a) violate or attempt to
violate the Ohio Rules of Professional Conduct, knowingly assist or induce another to do so, or
do so through the acts of another; (b) commit an illegal act that reflects adversely on the lawyers
honesty or trustworthiness; (c) engage in conduct involving dishonesty, fraud, deceit, or
misrepresentation; (d) engage in conduct that is prejudicial to the a administration of justice; (e)
state or imply an ability to influence improperly a government agency or official or to achieve
results by means that violate the Ohio Rules of Professional Conduct or other law; (f)
knowingly assist a judge or judicial officer in conduct that is a violation of the Ohio Rules of
Professional Conduct, the applicable rules of judicial conduct, or other law; (g) engage, in a
professional capacity, in conduct involving discrimination prohibited by law because of race,
color, religion, age, gender, sexual orientation, national origin, marital status, or disability;
(h) engage in any other conduct that adversely reflects on the lawyers fitness to practice law.
Pursuant to a subpoena duces tecum issued by Judge Hunters attorneys, Ms. Pridemore
produced a document on December 22, 2015 alleged to be the report she created at the direction
of the OSC. If Ms. Pridemore in fact went through the thousands of cases assigned to Judge
Hunter, of which she was not the prosecuting attorney of record, such conduct was unethical and
violated confidentiality and privacy laws governing juvenile cases. Ms. Pridemore only
supervised delinquency cases in her courtroom. An independent review of any Judges cases, by
an assistant prosecutor whose office has a direct interest in the outcome of those cases, violates
numerous federal and state laws and would result in an egregious violation of the publics trust.
Ms. Pridemore untruthfully testified and misstated the law when she reported that Judge Hunter
failed to rule on all of her cases within 120 days. As the supervising prosecutor in Juvenile Court
in delinquency, Katie must have known that Juvenile Court judges, including Judge Hunter
followed the Form D report, which provided varying time frames for different types of cases on
Objection. Judge Hunter followed the Form D, provided by the OSC, which was confirmed as

the proper guideline on timeframes by the Ohio Supreme Court when Judge Hunters office
called the Ohio Supreme Court for verification. Judge Hunters cases were not untimely,
pursuant to the Form D guidelines. Ms. Pridemore conveniently failed to testify that transcripts
ordered by prosecutors on Objection hearings and Motions to Set Aside were as a practice rarely
ever prepared and filed with the court within 30 days as the law required. Judge Hunter had cases
that transcripts took years to prepare and had been on Objection for years before prior Judges
when Judge Hunter inherited the backlog, which was common knowledge at the Prosecutors
Office and Juvenile Court. This backlog and failure to prepare and file timely transcripts with the
court was a problem that existed before Judge Hunter arrived and was not due to any fault of
Judge Hunters. Ms. Pridemore, as the supervising attorney in delinquency, even if only for one
month, when she accused Judge Hunter of hating prosecutors, having it in for prosecutors,
holding prosecutors in contempt and backdating documents prepared by Juvenile Court staff and
case managers at the direction of Connie Murdock, and not Judge Hunter, should have known
that Rule 40 required her to independently read all transcripts before ruling on substantive issues.
Ms. Pridemore testified that Judge Hunter had it in for the prosecutors office and that she
absolutely hated the prosecutors office at every turn. Ex. B. Her testimony was published and
circulated in media across the world. Such statements were made with reckless regard for the
truth, as no evidence was presented as to statements or actions taken by Judge Hunter that would
give credence to such an absurd statement. Judge Hunter requests this Commission to have Ms.
Pridemore produce evidence that Judge Hunter hated prosecutors, had it in for prosecutors and
required protection from Judge Hunter and needed to safeguard [her] cases... and prosecutors.
All of the conduct exercised by Assistant Prosecutor Katie Pridemore, as indicated in the
enclosed complaint, with the attached exhibits, evidences that Katie violated Rules 1.0; 3.4, 3.5
and 8.4 (a-h) of the Ohio Rules of Professional Conduct and should be sanctioned accordingly.
Sincerely,
Tracie M. Hunter, Judge