COMPLAINT

REGARDING ATTORNEY:

Robert M.A. Nadeau

311 Alfred Street
Biddeford, Maine 04005

DATE:

June 30, 2016

TO:

Massachusetts Office of the Bar Counsel

99 High St., Boston, MA 02110
New Hampshire Professional Conduct Committee
4 Park Street, Suite 304, Concord, NH 03301
Maine Board of Overseers of the Bar
97 Winthrop St., Augusta, ME 04332

RE:

Ethics Violations by Robert M.A. Nadeau

I hereby lodge an official complaint against Attorney Robert M. A. Nadeau in all three states
where he is licensed to practice law, and therefore subject to review on ethics violations.
Please note that I have referenced the statutes for Maine, with the understanding and belief
that Massachusetts and New Hampshire have corresponding statutes (please apply all
applicable statutes in your state).
Nature of the complaint:
Attached is my GRIEVANCE, PARTS A-F, with EXHIBITS 1-28, which cites the following
ethics violations:
1. PARTS A-F: Systemic Professional Misconduct. Robert M.A. Nadeau has engaged in an
ongoing, recurring and extreme pattern of unethical and prohibited behaviorfrom 2005
to 2016which has undermined the integrity of the courts he practices in, as described in
Maines Professional Misconduct Rules 8.4(a), 8.4(b), 8.4(c) and 8.4(d), and with such
regularity that his professional misconduct has become systemic. Nadeau knowingly
and repeatedly commits unlawful acts that reflect adversely on his honesty,
trustworthiness and fitness as a lawyer. He knowingly and repeatedly engages in conduct
involving dishonesty, fraud, deceit and misrepresentations. He knowingly and repeatedly
engages in conduct that interferes with and often prohibits the administration of justice.
2. PART F: Fraud upon the Court. Robert M.A. Nadeaus systemic professional
misconduct includes misrepresentations so deliberate and heinous that any decision
produced from them is not in essence a decision at all, and never becomes final. (Kenner v.
C.I.R., 387 F 3d 689 (1968); Moores Federal Practice, 2d ed., p. 512, Section 60.23). Nadeau
has compounded this misconduct by taking one such decision that is not in essence a
decision at all and using it to bring claims that he knew to be founded on his own lies. In
Nadeau Bar Complaint, Grievance 1, Page 1

fact, he brought two claims on the same lie, both of which were filed in Essex County Court,
Massachusetts, and both of which were withdrawn by Nadeau on the eve of trial. These
lawsuits embrace that species of fraud which does, or attempts to, defile the court itself; are
perpetrated by an officer of the court; and are executed for the purpose of obstructing
justice (Kenner v. C.I.R., 387 F 3d 689 (1968); Moores Federal Practice, 2d ed., p. 512,
Section 60.23).
3. PART F: With the above referenced behavior, Nadeau has engaged in conduct that
repeatedly violates Maine Rule 3.1 in regards to Meritorious Claims and Contentions;
and
4. PART F: Nadeau has not only engaged in conduct that repeatedly violates Maine Rule 3.3
regarding Candor Toward the Tribunal by making false representations to the court, but
also by tampering with evidence and witnesses and with various other attempts to mislead
the court as outlined in Part F.
Although some of the violations listed in this grievance fall outside the statute of limitations
(PARTS A-E), they are still relevant because:
1. The older violations support the charge of systemic professional misconduct by
showing a pattern of unethical and unprofessional misconduct that has become
systemic for Nadeau.
2. The older violations support the current 2014-2016 allegations (as outlined above,
in items 2-4 and in more detail in Part F).
3. The older violations are part of a chain of events that escalated from misconduct to
misrepresentations; from misrepresentations to tampering with witnesses and
evidence; and from tampering with witnesses and evidence to multiple acts of fraud
upon the court.
4. The older violations are raised by Nadeau in his 2014-2106 lawsuit.
5. It is only through a full review of the chronological events leading up to and
including Nadeaus 2014-2016 actions that the various boards can determine
whether or not Nadeaus misconduct is, in fact, systemic professional misconduct;
and whether his subsequent behavior did, in fact, represent fraud upon the court
and numerous violations to the statutes relating to meritorious claims and candor
toward a tribunal.
Date of Violation:

Ongoing, from 2005 - 2016

About the Complainant:

After nearly six years of punitive litigation and abuse, I am entitled to an answer:
Is Nadeaus behavior unethical or not?
Nancy Madore
author.nancymadore@gmail.com
www.nmadore.com

Nadeau Bar Complaint, Grievance 1, Page 2

GRIEVANCE
BACKGROUND
On March 3, 2003, my friend, Lynnann Frydrych (Frydrych) hired Attorney Robert M.A.
Nadeau (Nadeau) to represent her in her divorce from Dean Scuilli (Frydrychs Ex). In
the course of her representation, Frydrych told Nadeau three key things pertaining to this
grievance: 1. Frydrych had had an extramarital affair with her former surgeon, Dr.
Ehrlichman (Frydrych Affair); 2. Frydrychs Ex had made tape recordings of her private
telephone conversations discussing the affair, which she feared he might try to use against
her in their divorce; and 3. Frydrych was concerned that her ex-mother-in-law (who hated
and harassed Frydrych to the point where she and her husband had kept their children
from her during their marriage) would have access to the children after the divorce.
On June 20, 2003, Nadeau had a consensual sexual encounter with Frydrych in his office
during an attorney-client appointment (EXHIBIT 1, page 3, paragraph 1). Nadeau moved
into Frydrychs marital home shortly after, and their affair continued until August 13, 2003.
On June 22, 2003, Nadeau prepared his motion for leave to withdraw, but did not file it
with the court. Instead, he put the motion in Frydrychs case file (EXHIBIT 1, page 6).
On August 20, 2003, Frydrych filed a bar complaint against Nadeau with the Board of
Overseers of the Bar in Maine (The Bar).
On May 19-20, 2005, The Bar conducted its hearing.
On June 3, 2005, The Bar issued a Finding on Frydrychs complaint and another, second
complaint filed against Nadeau by his former law partners, as follows:
1. As to Nadeaus failure to file his motion to withdraw in Frydrychs case, The Bar
determined that [Nadeaus] motive in proceeding in this manner was to conceal the
sexual relationship between himself and his client. (EXHIBIT 1, page 3, paragraph 2).
2. After considering all of Nadeaus actions toward Frydrych, The Bar determined that
[Nadeau] has conducted himself in a manner unworthy of an attorney. (EXHIBIT 1,
page 5, paragraph 3)
3. The Bar also determined that contrary to [Nadeaus] assertion, his misconduct
caused substantial injury to his client. (EXHIBIT1, page 6, paragraph 3)
4. The Bar recommended Nadeaus suspension or disbarment and instructed Bar
Counsel to commence an attorney disciplinary action with the Court. (EXHIBIT 1,
pages 5-7)
5. As to the second complaint from Nadeaus former partners, The Bar issued an
immediate Public Reprimand to Nadeau for communicating directly with a party
[he] knows to be represented by counsel. (EXHIBIT 1, pages 5 and 7)

Nadeau Bar Complaint, Grievance 1, Page 3

GRIEVANCE
PART A
BAR RULES VIOLATED
Confidentiality of Information
Maine Rule 1.6(a)

Duties to Former Clients

Maine Rule 1.9(a), 1.9(b)(1), 1.9(c)(1), 1.9(c)(2)

Misconduct

Maine Rule 8.4(a), 8.4(b), 8.4(c) and 8.4(d)

CRIMINAL RULES VIOLATED

Tampering with a Witness
Maines Criminal Code, Title 17, Part 2, Chapter 19, Section 454(1)(a)(1)

NOTICE
The purpose of citing these 2005 violations in this Grievance is:
1. To establish a pattern of behavior that is systemic professional misconduct; and
2. To provide evidence in support of the claims in Part F this grievance of fraud upon the
court and other violations relating to meritorious claims and candor toward a tribunal.

On May 6, 2005, a few weeks before the scheduled Bar hearing in the above referenced
matter, Nadeau emailed Frydrychs Affair in an attempt to get him to testify that Frydrych
had a history of going after professional, married men. The email violates Frydrychs
attorney-client privilege per Maine Rule 1.6(a) with the following statements:
1. Through extensive efforts I will not address at this point I have learned about the
torrid, adulterous sexual affair you had with [Frydrych] from December 2000 through
September 2001. (EXHIBIT 2, page 1, paragraph 1)

2. [Frydrych] told me many things about her relationship with [Ex] and about her

allegedly innocent, vulnerable past and of her allegedly, historically unhappy marriage,
as well as, surprisingly (without any solicitation or need whatsoever), very graphic
sexual information concerning her experiences with and unhappiness about [Ex]all of
which I later learned were untrue. (EXHIBIT 2, page 2, paragraph 5).

3. [Frydrych] had been dishonest with me about many things she had told me when I was
her attorney. I also did not understand why she had worn a birth control patch on her
abdomen on June 20, 2003 inasmuch as she had previously volunteered during one of
our earliest office consultations that due to her alleged hatred of [Ex] she had not had
sexual relations for almost a year. (EXHIBIT 2, page 3, paragraph 2)

As well, this email to a potential witness is written in a very threatening manner from start
to finish. The underlying threat is emphasized when Nadeau writes:
Your attendance to testify fully on May 20 at that hearing is essential I would like to
protect you from being subpoenaed at your home or office to secure your attendance
and testimony at the hearing, but I will need your cooperation if such process may be
avoided. (EXHIBIT 2, page 2, paragraph 3).
Nadeau Bar Complaint, Grievance 1, Page 4

Nadeau gave this married doctor until 5:00 pm that evening to contact him. He later
testified that their conversation left the man pleading and in tears.
NOTICE: Shortly before the bar hearing, Nadeau informed The Bar of his intention to have
Frydrychs Affair testify, and also his intention to enter the tape recordings of their affair
into evidence. However, Nadeau testified that it was his attorneynot himwho
contacted Frydrychs affair and who secured the tapes from her ex-husband. Even so,
The Bar refused to allow the evidence.
Around the same time, Nadeau began communicating directly with Frydrychs Ex and even
Frydrychs ex-mother-in-law. In particular, he was encouraging them to file for custody of
Frydrychs two minor children and offering his support if they were to do so. He even
agreed to speak to their lawyer. In exchange, Nadeau was seeking their participation in his
bar defense. He asked for affidavits and even dictated a letter for Frydrychs Ex to write to
The Bar. This grievance cites only one of their communications (others are available upon
request).
On May 30, 2005, 10 days after the Bar hearing (but before the Bars decision on
disciplinary action), Nadeau authored a particularly disturbing email, which includes
responses from Frydrychs Ex (EXHIBIT 3).
First, Nadeau discloses the information that he already acknowledged Frydrych had shared
with him in one of their earliest appointments (EXHIBIT 2, page 3, paragraph 2). Once
again, Nadeau is violating Frydrychs attorney-client privilege per Maine Rule 1.6(a) by
sharing the following information:
Also, why was she wearing a birth control patch the evening of June 20, 2003, when
our affair began, inasmuch as she insisted that she hadnt had sex with you for a year
because she was allegedly so unhappy with you? (EXHIBIT 3, page 2, paragraph 3)

Next, Nadeau violates Maine Rule 1.9(c)(1) by disparaging Frydrych to the opposing party
in her ongoing divorce case:
[Frydrych] is nothing short of a completely dishonest lush, a narcissistic slut, a gold
digger looking for a sugar daddy, and an extremely poor role model for your children.

(EXHIBIT 3, page 3, paragraph 2)

Nadeau tells Frydrychs Ex that he intends to sue Frydrych and her mother for lying about
Frydrychs sexual escapades based on what Frydrychs Ex supposedly told him. Nadeau
makes it very clear that these sexual escapades are necessary, not just to his lawsuit, but to
the disciplinary action that might be taken against him as well. He encourages Frydrychs
Ex to confirm these sexual escapades, even after Frydrychs Ex admits that they might not
have occurred. At the very least, Nadeau is engaging in knowing misconduct toward both
his former client and a potential witness, in violation of Maine Rule 8.4(a), 8.4(b), 8.4(c)
and 8.4(d). But in light of the pending disciplinary actioncombined with Nadeaus offers
to assist Frydrychs Ex with a custody battlethe communication also violates Maines
Criminal Code, Title 17, Part 2, Chapter 19, Section 454(1)(a)(1), where it states: A person
is guilty of tampering with a witness or informant if, believing that an official proceeding is
Nadeau Bar Complaint, Grievance 1, Page 5

pending or will be instituted, the actor (a) induces or otherwise causes, or attempts to induce
or cause, a witness or informant (1) to testify or inform in a manner the actor knows to be
false. This is particularly true when Nadeau continues to push for the testimony he wants,
even after he receives this admission from Frydrychs Ex:
I think either I misspoke in one of the conversations I had with you or we just got our
wires crossed somehow, and I only suspect that something may have happened during
that time, but have no hard evidence to back it up. (EXHIBIT 3, page 4, paragraph 1) and
Well, here is where we kind of get into conjecture and theory and not much hard fact.

(EXHIBIT 3, page 4, paragraph 8)

Nadeau further violates the above referenced misconduct rulesas well as the criminal
code regarding witness tampering (and this becomes even more evident in the email
communications to come)when Nadeau asks Frydrychs Ex, to do the following:
The one other thing you could do (but it would need to be done immediately, if at all,
because the panel is right now finalizing its hearing decision), is to write to and email
Nora Sosnoff at the Maine Board of Overseers of the Bar, to tell her that she and the
hearing panel in my case have done a very grave injustice by refusing to consider your
affidavit and by causing the panel to believe that you altered those emails in any way
Please tell Sosnoff that none of those things is so and that [Frydrych] has perjured
herself; tell her about [Frydrychs] sordid, deceitful past and the diamond rings; tell her
that I am being unfairly harmed by this very horrible, dishonest person, and that only
she can prevent that; and tell her that you request that she take the extraordinary step
of notifying the panel that heard my case immediately about these things, in fairness
and justice, so that the injustice can be prevented. (EXHIBIT 3, page 7, paragraph 1)

Nadeau follows this with:

In closing, [Ex], your kids are definitely being harmed emotionally and psychologically,
with every day that goes by while they remain in [Frydrychs] care. You should have
those kids, and [Frydrych] should be required to get a full time job and to pay child
support to you; (EXHIBIT 3, page 7, paragraph 3), and You can count on me to be
your ally for Aaron and Livis [Frydrychs children] benefit. (EXHIBIT 3, page 8,

paragraph 3)

There is no denying that these emails violate the ethics codesor that The Bar most
certainly would have remarked upon them if they had seen them. Everything on file
confirms The Bars belief that Nadeaus attorney had affected all contacts for the sole
purpose of discovery. Further, this email was written after The Bar conducted their
hearing.

Nadeau Bar Complaint, Grievance 1, Page 6

GRIEVANCE
PART B
BAR RULES VIOLATED
Duties to Former Clients

Maine Rules 1.9(a), 1.9(b)(1), 1.9(c)(1), 1.9(c)(2)

Misconduct

Maine Rules 8.4(a), 8.4(b), 8.4(c) and 8.4(d)

Improper Communications
Maine Bar Rules 3.1(a), 3.2(1)(4), 3.6(a), and 3.6(f)

CRIMINAL RULES VIOLATED

Tampering with a Witness

Maines Criminal Code, Title 17, Part 2, Chapter 19, Section 454(1)(a)(1)

NOTICE
The purpose of citing these 2005 violations in this Grievance is:
1. To establish a pattern of behavior that is systemic professional misconduct; and
2. To provide evidence in support of the claims in Part F this grievance of fraud upon the
court and other violations relating to meritorious claims and candor toward a tribunal.

On May 22, 2005, Nadeau began contacting me, Frydrychs friend, in an attempt to reach
Frydrych. Once he established that I was, in fact, forwarding his emails to Frydrych, he
began using this method to communicate with Frydrych, even though he knew that
Frydrych was being represented by counselnot just as a witness in his ongoing bar
complaint but also as the complainant.
Nadeau persisted in these contacts even after the June 3, 2005 Bar Finding, where you may
recall he was issued a public reprimand for violating Maine Bar Rules 3.1(a), 3.2(1)(4),
3.6(a), and 3.6(f) by communicating directly with a party [he] knows to be represented by
counsel. (EXHIBIT 1, page 5 and 7)
This continued misconduct is exacerbated by the fact that Nadeau was conducting these
unethical communications while communicating with Frydrychs Ex. He was deliberately
tampering with witnesses on both sides of the fence in an effort to gain an advantage in an
ongoing legal proceeding.
On June 19, 2005, Nadeau authored a particularly disturbing communication for me to pass
on to Frydrych. This email represents serious violations to Maine Rules 3.1(a), 3.2(1)(4),
3.6(a) and 3.6(f) and Maine Bar Rule 8.4(a):
I took some time this evening to carefully review the bar rules. They only prohibit my
contact with an adverse party (ostensibly, [Frydrych], until, if ever, she may decide
that we are not adverse anymore) when I am an attorney representing [Frydrychs]
adversary. However, in this situation, I am neither representing myself nor anyone else
against [Frydrych]. On the contrary, I am being represented by counsel. Therefore,
there does not appear to be any impediment against my talking with [Frydrych], if she
wants to talk to or email me. (EXHIBIT 4, page 1, paragraph 3)
Nadeau Bar Complaint, Grievance 1, Page 7

Nadeau then attempts to discourage Frydrych from discussing this communication with
her attorneys:
She may want to check with her attorneys first about this, if she feels uncomfortable
about the situation and feels that she still needs her Maine attorneys (God knows why
for reasons you and I have already discussed) to advise her and to make her decisions
for her, but you and I both know how much advisors, starting with my former
counselor, can screw things up so badly. You did indicate that [Frydrych] has tried to
reach me but that her lawyerswho in my humble opinion handled her divorce case
over the course of some 8 months or so poorly have been beating her down and
causing her to feel she has no right to tell them to take a hike. (EXHIBIT 4 page 1,

paragraph 3)

NOTE: The commentary he attributes to me never took place (copies of all the
correspondence is available upon request).
Nadeaus next statement represents a violation of Maines Criminal Code, Title 17, Part 2,
Chapter 19, Section 454(1)(a)(1), regarding the tampering of a witness:
All that having been said, I had a brainstorm during my bike ride, in terms of how I can
help [Frydrych]. I have a credit card account with a large limit--$31,000, with no
balance due. I want to help [Frydrych] as much as I can, so I will max out that account
and send to her, in care of her mother whose address I have, along with a letter of
apology to [her mother], three checks from that account, as gifts made payable as
follows: Lyannann Frydrych obo [her son] ($10,000), Lynnann Frydrych obo [her
daughter] ($10,000) and Lynnann Frydrych (11,000). I simply do not have any liquid
accounts right now, as everything must unfortunately go to my on-going defense until it
may somehow be ended satisfactorily so that we can move on. (EXHIBIT 4, page 2,

paragraph 3)

Nadeau follows this with a second attempt to discourage Frydrych from contacting her
attorneys:
I am sending [the checks] to Pennsylvania, not to [Frydrychs] Maine attorneys. I do not
want those attorneys to get a single dime from these funds on an alleged contingency
fee basis, on some premise that they had anything to do with this money or are
deserving of anything for any reason whatsoever. This money is for [Frydrych] and the
kids, period, without any deduction for those lawyers and without any obligation by
[Frydrych] to pay them for any of it. (EXHIBIT 4, page 2, paragraph 5)

Nadeau then attempts to manipulate Frydrych on an emotional level:

The money is pursuant to my long-standing desire to help [Frydrych] that I expressed
when we were together, let alone ever since, but that became drowned out by the confusion,
the hurt and disappointment, the lawyer intervention and lawyer threats on her
behalfwhile everyone and everything have been working to keep us apart. (EXHIBIT 4,

page 2, paragraph 5)

Nadeau Bar Complaint, Grievance 1, Page 8

The email worked. Frydrych called Nadeau that very evening. Although Nadeau would
never actually deliver on his gift, he was swearing his undying love for her in an email
dated the very next day (EXHIBIT 5). Nadeau and Frydrych were reunited and Frydrych
retracted her statement shortly thereafter.
This communicationespecially in light of Nadeaus simultaneous communications with
Frydrychs Ex, represents a complete disregard for the interests of a former client, in direct
violation of Maine Rules 1.9(a), 1.9(b)(1), 1.9(c)(1), 1.9(c)(2).
It is certain that The Bar would have remarked on this email if they had seen it, especially
in light of Frydrychs subsequent retraction letter. The simple fact is that the email has
never, to date, been taken under review by any tribunal or court. The reasons for this will
become apparent as the grievance continues.

Nadeau Bar Complaint, Grievance 1, Page 9

GRIEVANCE
PART C
BAR RULES VIOLATED
Duties to Former Clients

Maine Rules 1.9(a), 1.9(b)(1), 1.9(c)(1), 1.9(c)(2)

Misconduct

Maine Rules 8.4(a), 8.4(b), 8.4(c) and 8.4(d)

Improper Communications
Maine Bar Rules 3.1(a), 3.2(1)(4), 3.6(a), and 3.6(f)

CRIMINAL RULES VIOLATED

Tampering with a Witness
Maines Criminal Code, Title 17, Part 2, Chapter 19, Section 454(1)(b)(1)

NOTICE
The purpose of citing these 2005 violations in this Grievance is:
1. To establish a pattern of behavior that is systemic professional misconduct; and
2. To provide evidence in support of the claims in Part F this grievance of fraud upon the
court and other violations relating to meritorious claims and candor toward a tribunal.

When Frydrychs Ex and ex-mother in-law learned that Frydrych and Nadeau had reunited,
Frydrychs mother in-law forwarded all of the emails Nadeau sent them to me. I forwarded
them to Frydrych. This is the first indication we had that Nadeau had been directly
contacting the other side of Frydrychs case.
Frydrych confronted Nadeau with the emails. She threatened to show them to The Bar
and/or tear up the retraction statement that Nadeau had written for her to sign.
On June 28, 2005, Nadeau wrote to Frydrychs Ex:
If you or your mother or anyone apparently or actually acting on your behalves, emails
or in any other way communicates with [Madore] or [Frydrych] one more time, for the
purpose of sharing any of our obsolete and badly misinformed (by you and your
mother) communications and/or for the apparent purpose or negligent effect of
invading our privacy, inflicting emotion distress, defaming any one of us, or harassing
us, you and your mother can be assured that your ex-wife, to wit, my future wife, will
own your mothers home and will be happy to evict her from it. (EXHIBIT 6, page 1,

paragraph 4)
In this incredible turnabout, Nadeau virtually proves all of the violations I cited in the
previous portions of this grievance. As to Frydrychs parenting, Nadeau now writes:
[Frydrych] is the best mother Ive ever seen (and Ive seen lots of parents, both as an
attorney and from the bench in very heated, emotional custody disputes through the
years). (EXHIBIT 6, page 1, paragraph 4)

Nadeau Bar Complaint, Grievance 1, Page 10

As to the custody battle Nadeau tried to encourage Frydrychs ex-husband to instigate,

Nadeau writes:
You will not succeed in any effort to wrest those kids from her, either, for any of a
number of reasons that frankly completely disentitle you to even being considered for
primary residence or custody of those childrenfor example, alcoholism, excessive
smoking, refusal to obtain and hold down a job consistent with your educational level,
failure to honor court orders regarding child and child support matters, inability to
promote and foster a positive image of the childrens other parent, inability or refusal
to establish financial independence and a consistent level of responsibility, and refusal
to seek guardianship of your mother and to have her committed. (EXHIBIT 6, page 1,

paragraph 3)

This shows a startling lack of ethics and, in light of Frydrychs threat to reveal the conduct
to The Bar, it also represents a violation of Maines Criminal Code, Title 17, Part 2, Chapter
19, Section 454(1)(b)(1), which states: A person is guilty of tampering with a witness or
informant if, believing that an official criminal investigation will be instituted, the actor
(b) uses force or intimidation with the intent to induce a witness to withhold testimony,
information or evidence.
It is certain that The Bar never saw this email when they made their final decision on
March 6, 2006 (after receiving Frydrychs retraction letter) to dismiss her bar complaint
against Nadeau with a warning (EXHIBIT 10).

Nadeau Bar Complaint, Grievance 1, Page 11

GRIEVANCE
PART D
BAR RULES VIOLATED
Duties to Former Clients

Maine Rules 1.9(a), 1.9(b)(1), 1.9(c)(1), 1.9(c)(2)

Misconduct

Maine Rules 8.4(a), 8.4(b), 8.4(c) and 8.4(d)

Improper Communications
Maine Bar Rules 3.1(a), 3.2(1)(4), 3.6(a), and 3.6(f)

Candor toward a Tribunal

Maine Bar Rules 3.3(a)(1), 3.3(a)(4)

NOTICE
The purpose of citing these 2007-2008 violations in this Grievance is:
1. To establish a pattern of behavior that is systemic professional misconduct; and
2. To provide evidence in support of the claims in Part F this grievance of fraud upon the
court and other violations relating to meritorious claims and candor toward a tribunal l.

On July 17, 2007, well within the three-year time limit to file, I lodged a bar complaint
against Nadeau containing two separate grievances. This portion of the grievance
references the first grievance in that complaint. (EXHIBIT 7, pages 16-48)
My grievance made the claim that Nadeau had behaved unethically with his
communications to me, Frydrychs ex-husband and Frydrychs former doctor. All four of
the exhibits in this grievance were included in that grievance (EXHIBIT 7, pages 19-21,
pages 25-32, pages 41-42, and pages 47-48).
In the course of his bar defense, Nadeau once again repeatedly and knowingly violated
Maine Bar Rules 3.3(a)(1), 3.3(a)(4), which state: A lawyer shall not knowingly (1) make a
false statement of material fact to a tribunal; (4) offer evidence that the lawyer knows to be
false. The falsehoods in Nadeaus defense are so egregious that they exceed the standard
for fraud, which only requires intentional misrepresentations of material existing facts.
Nadeaus claims are complete falsehoods, and yet another example of professional
misconduct as described in Maine Rules 8.4(a), 8.4(b), 8.4(c) and 8.4(d). Specifically;
1. Nadeau told The Bar that the unethical emails had already been reviewed and
dismissed by the review board in Frydrychs 2003-2005 bar complaint. The Bar
believed Nadeaus assertion, as is evidenced by their statement;
The facts giving rise to your claims of ethical violations by Attorney Nadeau
appear to be many of the same factual allegations that were brought against
Attorney Nadeau in a prior complaint filed by Lynn Frydrych (GCF # 03-255) and
considered at a Grievance Commission Panels disciplinary hearing in 2005.
Those same issues were subsequently the subject of an Order of the Maine
Supreme Judicial Court. (EXHIBIT 9, page 1, paragraph 3)

Nadeau Bar Complaint, Grievance 1, Page 12

How could the ethical violations have been considered at the disciplinary hearing in
2005 when the three worst ethical violations were written after the disciplinary
hearing in 2005? The Bar Counsel goes on to say;
Those same issues were subsequently the subject of an Order of the Maine
Supreme Judicial Court. In that Order issued on March 6, 2006, Justice Alexander
noted that Ms. Frydrych now denies that Attorney Nadeau acted
unprofessionally concerning her or that she suffered any harm from his
conduct. Since the Court has heard and decided those matters and facts, they
cannot now be revisited by the Board of Overseers of the Bar or Bar Counsel.

(EXHIBIT 9, page 1, paragraph 3)

That final statement would only apply to the claims listed in Frydrychs 2005 bar
complaint. Those were the claims that were retracted. The evidence I submitted in my
2007 complaintnamely the unethical communications that were occurring behind the
sceneswere not part of Frydrychs bar complaint. She didnt even know they were
happening until after she and Nadeau reunited, as is evidenced by the fourth email,
where Nadeau is threatening to sue Frydrychs ex-mother-in-law for revealing the
communications to us.
Despite Nadeaus insistence that the unethical emails were previously adjudicated,
these are the facts:
a. None of the unethical emails can be found in the 2003-2005 Frydrych bar
complaint file.
b. None of the unethical emails are even mentioned in the 2003-2005 Frydrych
bar complaint file.
c. None of the unethical emails are mentioned in the June 3, 2005 Bar Finding.
d. None of the unethical emails are mentioned in The Bars March 6, 2006
Final Order dismissing the complaint.
e. If The Bar had been aware of the unethical communications, it is more likely
than not that they would have remarked upon them at some point in the
proceedings.
2. In addition to misleading the Bar tribunal into believing that the communications
had already been adjudicated, Nadeau wasat that very momentrepeating the
same behavior that I was reporting, which represents ongoing violations of Maine
Rules 1.9(a), 1.9(b)(1), 1.9(c)(1) and 1.9(c)(2), Maine Rules 3.1(a), 3.2(1)(4), 3.6(a),
and 3.6(f) and Maine Rules 8.4(a), 8.4(b), 8.4(c) and 8.4(d) as follows:
a. On 8/6/07, three days after The Bar dismissed my complaint, and nine days
after Nadeau entered into an agreement not to harass, disparage or harm
Frydrych, Nadeau contacted Frydrychs ex-husband, to write:
I very, very strongly urge you to rescue your childrenimmediately.
[Frydrych] and I are permanently separated [Frydrych] is neglecting
your children She is an extremely poor role model for those children
and, I have come to believe, a danger to their safety and emotional wellbeing There are very serious psychiatric issues with [Frydrych], in my
opinion. She is violent, seemingly bipolar and manic-depressive, very
Nadeau Bar Complaint, Grievance 1, Page 13

lazy, irresponsible, narcissistic, schizophrenic and probably more I

have absolutely no doubt in my mind at this point, that those children
need to be away from her permanently and that you need to get them,
even if doing so would be inconvenient to you and your new family
Please do something to protect and rescue your kids, immediately. I will
testify on your behalf and on behalf of those children She is a violent,
hotheaded, vile, profane and very loose and irresponsible human being
There is something extremely wrong and dangerous Your kids should
absolutely not be around her. I dont take this lightly, and I encourage
you not to do so either. (EXHIBIT 10)

b. On 8/14/07, Nadeau sent Frydrychs Ex-husbandin care of his new wife,

Annean email that reveals his true motives for these communications. He
copied Frydrych on this email:
I feel compelled to take a moment to issue to you, and especially to
[Frydrych], an apology. I truly feel disgusted and betrayed about the
things [Frydrych] did to me Earlier this evening, [Frydrych] actually
approached me and was nice She even blew me a kiss causing me to
do a double take and actually melt I have accused [Frydrych] of being a
prostitute and I have said other mean things about her what I have
said about her recently in retaliation was very beneath me and very
unfair to her as well After speaking with [Frydrych], I once again have
to say that she deserves a considerable amount of credit for the courage
Ive always loved about her, and for her unquestionably deep love of and
attention to those kids. She is the kind of mother who will always find a
way to deliver the best for those kids, so I am satisfied that despite her
recent mean and horrifying behavior toward me, the kids are and will
continue to be just fine and happy It is difficult for me to believe much
of what Lynn has said to me lately, ladened with denials of the many
things others have said about her that I have related to you, largely out
of concern for the kid but also in part in retaliation for what she has
done to me As for her motherhood, she remains remarkable in my
eyes. (EXHIBIT 11)

c. The contradictory emails continued, as is evidenced in Nadeaus December

11, 2007 email to 44 attorneys in Maine, (which he copied Frydrych on). One
of the attorneys who responded remarked that it reads like a love letter.
Among other things, Nadeau wrote:
[Frydrych] is courageous and a wonderful mother (EXHIBIT 12, page
3, paragraph 3) and; [Frydrych] was a terrific partner and mother of her
children. (EXHIBIT 12, page 6, paragraph 1)

d. However, it soon became evident (even to Nadeau) that the relationship was
doomed. So Nadeau resumed his unethical contacts with Frydrychs Ex
through Frydrychs Exs new wife, Annenot only encouraging them to file
for custody but also to find out who Frydrych was currently dating. Here are

Nadeau Bar Complaint, Grievance 1, Page 14

just a few examples of Nadeaus ongoing violations, which now include the
stalking and harassment of his former client:
i. On 2/4/08 Anne wrote to Nadeau about Frydrychs ongoing divorce
case: I will definitely keep you informed and take your suggestions as to
some things to say; and I can only assume that our plant might have
been compromised; to which Nadeau, concerned about the past
breaches on the part of Frydrychs ex-mother-in-law and
complications with his new wife, replied, Can we just keep our
communications between you and me? We can be & have been mutually
supportive, informative and assistive. (EXHIBIT 13A)

ii. Meanwhile, a few minutes later that same day, Nadeau wrote to
Frydrychs ex-mother-in-law: I have very strong reason to believe that
[Frydrychs] new fianc is William Boyd, M.D somebody should
probably warn him I will leave that issue to you. (EXHIBIT 13B)
iii. On 2/11/08, Nadeau wrote to Anne: I stand by what I told you
previously, regarding cooperation if you need it. However, Frydrychs

ex-husband and wife were cooling off the custody idea. Anne wrote:
It may be better if [Frydrychs Ex] just stays away until [the children]
are older and can make up their own minds. To this Nadeau replied: I
agree once again with all of your comments except those seemingly
subdued comments pertinent to your chances regarding contempts and
attorney fee/other sanctions against [Frydrych], full summertime and
school vacation residence with the kids, & telephone contact resolution. I
will leave that for you to discuss with your lawyer, as I must not be
construed as giving legal advice against someone who was once (in 03) a
client, even though I can & will testify against her regarding all of the
non-privileged things & more that I have shared with you if called upon
Your chances are much better now Id be happy to speak with your
lawyer if youd like [Frydrych] is very unstable, & its not a good thing
for those kids to see. (EXHIBIT 13C)
iv. On 2/14/08, Nadeau violated Frydrychs attorney-client privilege by

disclosing, yet again, the information she had shared with him as her
attorney in her divorce to a man he believed she was dating. This is
just one of the many Dr. Bills that Nadeau contacted in his search for
Fryrychs fianc. Posing as Bob Auclair, and referring to himself in
the third person, Nadeau wrote: Ms. Frydrych has admitted that, while
she was married to her first husband, Dean Sciulli, she engaged in sexual
intercourse with her breast implant surgeon; and In 2003, Ms.
Frydrych engaged in sexual intercourse with her divorce lawyer,
Attorney Robert Nadeau. Nadeau then proceeded to slander and

disparage Frydrych to this doctor who had no idea on earth who

Frydrych was. (EXHIBIT 13D)

Nadeau Bar Complaint, Grievance 1, Page 15

v. On 2/15/08, Nadeau wrote to Anne; I received a couple of phone calls

this morning from [Frydrych]. She indicated to me that she knew much
about my research efforts concerning Bill possibilities, etc.; and I am
concerned that you may have been giving her information regarding our
private communications, rather than just working together as I thought
we had agreed to do. This troubles me. I am absolutely willing to help
you guys by testifying truthfully regarding the things I mentioned to you,
and I can tell you that even [Frydrych] thinks that she may have to fight
the custody thing in the PA, not the ME, courts (good for you). However, I
feel very uncomfortable about cooperating if there is a breach of the
confidence I thought we had. (EXHIBIT 13E)
vi. On 2/29/08, Nadeau wrote to Anne; I have to be careful not to cross
the line between being your very cooperative witness verses arguably
giving legal advice you should just have your lawyer take over to get
[Frydrych] served.
vii. On 3/1/08, Anne sent Nadeau a review copy of a Final Notice to

Comply that she and Frydrychs Ex intended to send Frydrcyh before

filing for custody of the children. The next day, Nadeau wrote: Looks
pretty solid, Anne, from this laypersons perspective. (EXHIBIT 13G)
viii. On 3/6/08, Anne wrote to Nadeau: I sent the notice to [Frydrych]
again last night and asked her if she was aware of what Remedial
Sanctions were. Nadeaus awareness of the wrongfulness of his
actions is clear in his response: Call me on my cell & Ill answer your
questions & give you some insights although I have to be careful not
give you actual legal advice. Still, he cant resist adding, You should
act immediately & decisively. (EXHIBIT 13H)
ix. On 3/7/08, as a follow up on their phone conversation the previous
day, Nadeau wrote to Anne: You really need to act immediately. You
have such a very strong opportunity now, that [Frydrychs ex-husband]
will never have again. You would be foolish to even try to communicate
with her any further instead of immediately hiring your lawyer & getting
those kids without giving her any more signals or opportunities to screw
you guys or to run even further away, in my laymans opinion You
shouldnt fool around with ineffectiveness any longer Go get her now!
Good luck & keep me posted! (EXHIBIT 13I)

e. It is noteworthy that Nadeau never reported any child abuse in Frydrychs

home to any authority.
3. On September 10, 2007, in a second letter of defense to The Bar, Nadeau even
further violated Maine Bar Rules 3.3(a)(1), 3.3(a)(4), which state: A lawyer shall
not knowingly (1) make a false statement of material fact to a tribunal; (4) offer
evidence that the lawyer knows to be false, with statements so egregious that they
epitomize professional misconduct as described in Maine Rules 8.4(a), 8.4(b), 8.4(c)
and 8.4(d), when he wrote:
Nadeau Bar Complaint, Grievance 1, Page 16

I fully know that [the 2007 bar complaint] is intended to serve as some type of
effort to discourage my cooperation with Officer Ian Munger of the Wells Police
Department and, shortly, with the York Court Sheriffs Department and/or the
Attorney Generals office, as may be applicable, regarding investigations of
several significant crimes that have been committed by Ms. Pratt and more
particularly by her claimed best friend/my former fiance, Lynnann
Frydrych. (EXHIBIT 8, page 1, paragraph 2)

These are blatant lies from start to finish. There were absolutely NO investigations
being conducted on menot by Officer Ian Munger of the Wells Police Department,
not by the York Court Sheriffs Department and not by the Attorney Generals office.
I am almost certain there were no such investigations on Lynnann Frydrych either,
although I do believe that Nadeau attempted (but failed) to have charges filed
against her for allegedly assaulting him.
Nadeau actually fabricates details to enhance his lies, making his knowing
misrepresentations to a tribunal all the more heinous:
Those charges already partially under review by the York County District

Attorneys office and partially still under intensive investigation by Officer

Munger include several counts of computer hacking by both Ms. Madore Pratt
and, more particularly, by Ms. Frydrych, that have victimized Ms. Frydrychs exmother-in-law, Dianne Sciulli, my ex-wife, Kimberly Brennan (who has no
affinity for me whatsoever but who has nevertheless decided to press charges
against these people), and me, in numerous separate incidents each victim is
reportedly seeking to have vigorously prosecuted; theft of property of mine by
Ms. Frydrych; receiving stolen property of mine by Ms. Madore Pratt and by
Frydrychs/Ms. Pratts attorney, Steven Candors of Kennebunk; false swearing to
a police officer by Ms. Frydrych; assault by Ms. Frydrych against me on July 4,
2007; and, possible, several counts of criminal trespass by Ms. Frydrych.

(EXHIBIT 8, page 1, paragraph 2)

Again, every single detail in those statements is false.

The misrepresentations in items 1 and 3 are so egregious that they exceed the criteria
required to establish fraud, which is an intentional misrepresentation of a materially
existing fact with knowledge of its falsity and for the purpose of inducing the other person to
act. In this case, Nadeau went well beyond an intentional misrepresentation of a
materially existing fact when he created falsehoods with no connection whatsoever to
any materially existing fact. Whats more, Nadeau clearly did it for the purpose of inducing
a person,in this case, The Barto act. The Bars dismissal of my grievance was the
action Nadeau desiredand which The Bar took (EXHIBIT 9, page 1, paragraph 3).
This fraud is indeed that species of fraud which does, or attempts to, defile the court itself.
As well, it is a fraud perpetrated by officers of the court so that the judicial machinery
cannot perform in the usual manner its impartial task of adjudging cases that are present for
adjudication. As such, it qualifies as a fraud upon the court. (Kenner v. C.I.R., 387 F 3d 689
(1968); Moores Federal Practice, 2d ed., p. 512, Section 60.23).

Nadeau Bar Complaint, Grievance 1, Page 17

As the 7th Circuit Court makes clear: A decision produced by fraud upon the court is not in
essence a decision at all, and never becomes final. (Kenner v. C.I.R., 387 F 3d 689 (1968);
Moores Federal Practice, 2d ed., p. 512, Section 60.23).
And while Nadeau was committing this fraud upon the court, he was actively engaging in
the exact same misconduct that I was reportingand The Bar was dismissing as previously
adjudicated!

Nadeau Bar Complaint, Grievance 1, Page 18

GRIEVANCE
PART E
BAR RULES VIOLATED
Misconduct

Maine Rules 8.4(a), 8.4(b), 8.4(c) and 8.4(d)

Candor toward a Tribunal

Maine Bar Rules 3.3(a)(1), 3.3(a)(4)

Meritorious Claims and Contentions

Maine Bar Rules 3.1(a)

Fraud on the Court

Kenner v. C.I.R., 387 F 3d 689 (1968)

Moores Federal Practice, 2d ed., p. 512, Section 60.23

NOTICE
The purpose of citing these 2010-2013 violations in this Grievance is:
1. To establish a pattern of behavior that is systemic professional misconduct; and
2. To provide evidence in support of the claims in Part F this grievance of fraud upon the
court and other violations relating to meritorious claims and candor toward a tribunal.

On May 25, 2010, Nadeau filed a lawsuit against me. 5 of the 7 claims related exclusively to
the bar complaint I had filed against him. Mainly, Nadeau was citing malice and
defamation, with damages of just over a million dollars. The remaining 2 claims were
over a $5,000 legal bill for my brother (EXHIBIT 14).
Shortly before this case went to trial, Nadeau withdrew all five of his claims pertaining to
the bar complaintand the malice, defamation and damages he was alleging in
connection with it. This Superior Court lawsuit, which was comprised of five legal boxes
stuffed to overflowing and which Nadeau himself estimated between $50,000 and
$100,000 in legal expenses (he represented himself) came down to a $5,000 legal bill on a
case that I wasnt even the client in. That final claim will be discussed in Part F of this
grievance.
Nadeaus withdrawal of the five claims relating to defamation, malice and damages
reveals his bad faith in filing the lawsuit. But more than that, it reveals his intent to commit
fraud on the court. Those million dollar claims were based entirely on my 2007 bar
complaint, as is clear from his lawsuit Complaint (EXHIBIT 14, items 14, 17-19, 21-26 and
31) and in his deposition (highlighted excerpts in EXHIBITS 15A and 15B). But his
testimony in a deposition a few years later sums it up best:
Me:
In [the 2010-2013 lawsuit] against me wasnt that the only claim you brought
forwardthat I had filed that bar complaint against you?
Nadeau:
You had filed two different bar grievances at least that I know of. You
also filed a fee arbitration claim. You also filed a judicial conduct claim.
Me:
So that was the defamation you are talking about?
Nadeau:
Those were some of the aspects of defamation.
Me:
What were the rest?
Nadeau:
On information and belief you had been extremely negative about me to
others. Most particularly Miss Frydrych but others as well.
Nadeau Bar Complaint, Grievance 1, Page 19

Me:
Who?
Nadeau:
That I dont know. Obviously your attorney and your brother.
Me:
You sued me for defamation and [five years later] you still dont know who I
said something to, other than my best friend, my brother and my lawyer?
Nadeau:
Your best friend told me in late 2007 you had said negative things
towards me.
Me:
Besides Frydrych, my brother and my lawyer, who else did I say anything to?
Nadeau:
I dont know at this point.
Me:
[Frydrych and I], as best friends back then, having a conversation about you,
where supposedly I said negative things; is that defamation?
Nadeau:
It can be, depending on what you said.
Me:
What did I say?

No answer was given to this question and the subject was effectively changed (excerpt
highlighted in EXHIBIT 16).
Over 20 hours of extremely invasive and abusive depositions had been conducted by
Nadeau in the course of that 2010-2013 lawsuit, and this testimony reflects the totality of
his 5 counts relating to defamation, malice and the million dollars in damages. In fact,
Nadeau wasnt even using those depositions for my case. The time was spent harassing,
humiliating and victimizing me, Frydrych and my brother. As well, Nadeau took the
information from those depositions and misrepresented it in three separate, unrelated
proceedings that he brought against Frydrych, my brother and someone Frydrych had an
affair with. These abuses were severe and actionable, and the various courts refusal to take
action was the catalyst to my writing the book.
There were too many abuses in that 2010-2013 litigation to list here. Ive attached two
examples. The first is an email Nadeau sent Frydrych before filing a seven-million-dollar
lawsuit against an attorney who had an affair with Frydrych (Scott Wanner). Nadeau knew
that Wanner had never represented Frydrych, but it didnt stop him from suggesting that
she fabricate a claim (based on an error about it in an earlier hearing) to bring a
malpractice lawsuit against Wanner (and promise his support with the same). This offer
to assist Frydrych in the filing of a fraudulent claim against Wanner represents, at best,
tampering with a witness and at worst, a bribe (EXHIBIT 17). The second email was sent
from Nadeau to Frydrych a few weeks before calling her in for depositions in his lawsuits
against me and Wanner (EXHIBIT 18). Among other things, he wrote to this witness:
I am so very thankful that I found someone so much more attractive, sincere, genuine
and worthwhile, as well as sexy as hell but athletic and devoid of your fake, grossly
oversized boobs and flabby butt with thick upper legs, than you, who like so many
others could spot a lowlife white trash slut, white trash, homely, having a big, ugly
nose, a manipulator, very narcissistic, very immature, very insecure despite your
posturing to the contrary, a vamp, a user, and, most importantly, an utter liar and
fraud with very little of meaning to contribute to anyone elses life; (EXHIBIT 18, page
2, paragraph 2) and the threat that; In time, I will write a bio and probably a blog.
You will be a substantial chapter or two, or three, in them. (EXHIBIT 18, page 3,

paragraph 1)

Nadeau Bar Complaint, Grievance 1, Page 20

Nadeaus misconduct in the course of this litigation is intentional and knowing. Nadeau
knew that he was violating Maine Rule 3.3(a) with his lawsuit by knowingly (1) making a
false statement of material fact; and by (4) offering evidence that he knew to be false.
He knew that he was violating Maine Bar Rule 3.1(a) by bringing a frivolous proceeding,
with no basis in law and fact for doing so. He knew that The Bar dismissal he based his
lawsuit on represented yet another fraud upon the court. (Kenner v. C.I.R., 387 F 3d 689
(1968); Moores Federal Practice, 2d ed., p. 512, Section 60.23). He knows that all of these
actions represent professional misconduct, as described in Maine Rules 8.4(a), 8.4(b),
8.4(c) and 8.4(d), by (a) violating numerous provisions of the Maine Rules of Professional
Conduct and the Maine Bar Rules; (b) committing unlawful acts that reflect adversely on his
honesty, trustworthiness and fitness as a lawyer in other respects; (c) engaging in conduct
involving dishonesty, fraud, deceit or misrepresentation; and (d) engaging in conduct that is
prejudicial to the administration of justice. And finally, by repeating this misconduct over
and over again, he knows that he is engaging in a pattern of behavior that makes his
professional misconduct systemic.

Nadeau Bar Complaint, Grievance 1, Page 21

GRIEVANCE
PART F
BAR RULES VIOLATED
Professional Misconduct (Systemic)
Maine Rules 8.4(a), 8.4(b), 8.4(c) and 8.4(d)

Candor toward a Tribunal

Maine Bar Rules 3.3(a)(1), 3.3(a)(4)

Meritorious Claims and Contentions

Maine Bar Rules 3.1(a)

Fraud on the Court

Kenner v. C.I.R., 387 F 3d 689 (1968)

Moores Federal Practice, 2d ed., p. 512, Section 60.23

NOTICE
The violations listed in this part of Grievance 1 constitute a clear pattern of professional
misconduct that has become systemic for Nadeau. Further, these violations fall within the statute
of limitations, as they occurred from 2014 to 2016, and are, therefore, indictable. These violations
include several counts of a fraud upon the court, the filing of a frivolous lawsuit, knowingly
submitting false facts and evidence to the court, repeatedly lying under oath, tampering with
a witness and tampering with evidence.

On October 15, 2013, I published a book entitled The Ethics of Judge Nadeau (The Book),
which discusses all of the same violations I have described in this grievance and more.
On May 22, 2014, Nadeau filed a second lawsuit against me for injunctive relief, requesting
the removal of The Book from publication, based on a 2007 Agreement he had entered into
with Frydrych that barred Nadeau and Frydrych from disparaging each other. Nadeau
knew this claim was frivolous because:
1. I was not a party in that 2007 Agreement between Nadeau and Frydrych; and
2. Nadeau had already violated that agreement hundreds of times, rendering it
disputable, if not invalid. This is particularly true as it pertains to the stipulation
that he and Frydrych not disparage each other. Nine days after signing the
agreement, Nadeau began an aggressive campaign of disparaging Frydrych
with, among other people, the other side of her case that he had previously
represented her in. Nadeau also began stalking Frydrych in an effort to find out
who she was dating, and then disparaged her to every man living or working in
the state of Maine who fit the description. And throughout it all, he harassed her
with emails like the one in EXHIBIT 18. (For evidence of this, refer back to page
13 of this grievance, in item 2).
On June 6, 2014, after the Court denied Nadeaus request for injunctive relief (twice),
Nadeau amended his lawsuit to add the charges of malice, defamation and damages in
connection with The Book combined with my 2007 bar complaint, which he insisted
established a pattern of behavior that proved my malicious intent.

Nadeau Bar Complaint, Grievance 1, Page 22

The book/bar complaint proving a pattern of behavior was a regular theme throughout
Nadeaus litigation, as well as in his correspondence to me:
It is indeed unfortunate that you have a history of utilizing administrative licensing
threats endlessly to attempt to attain collateral retribution and influence over persons
who dare to pursue claims against you such a course of conduct is highly indicative of
apparent malicious intentions underlying your publications of me that are at issue in
the present litigation As you may know, malice is an alternative element of proof of
defamation. (EXHIBIT 19, page 1, paragraphs 1 and 2)

To date, Nadeau has failed to produced evidence of a single false statement in my book and
my bar complaint. Meanwhile, there was nothing but false statements in Nadeaus
pleadings. His Sworn Affidavit in support of his Amended Complaint is just one example:
1. In items 7-9 of his Sworn Affidavit, Nadeau wrote: Pratt asserts in her objection
that I have sued her for defamation and money damages before, making similar
blanket claims, and that I later withdrew those claims. She asserts that the
process was abusive. She neither cites, nor can she cite, any such judicial finding
On the contrary, in 2012 I won in the Newburyport Superior Court (Welch, J.) a
money judgment against Pratt for unpaid legal fees she and her brother had owed
to me since 2006. That lawsuit, incidentally but very notably, spawned Pratts filing
of a number of related frivolous and, in retrospect, clearly malicious bar complaints
and even a judicial conduct complaint against me Each of her administrative
complaints or grievances was dismissed, but only after I had to spend much time
and emotion responding to them. (EXHIBIT 20, page 3)

Nadeaus first misrepresentation here is that, since the court never

acknowledged the misconduct in that earlier proceeding, it did not occur.
Indeed, knowing that the contents of my bar complaint were true, Nadeau had
sued me for defamation and money damages before, he had made the same
blanket claims in that lawsuit and he had subsequently withdrawn those claims.
Putting aside all the other stuff he did in the course of that litigation (as
described in Part E of this grievance), those three things alone represent an
abuse of the litigation process.
Nadeau counters my truthful statement about his withdrawn defamation claims
with a misrepresentation about his win in that case. Nadeau knows that the
final claim he is referencing had no connection whatsoever to his defamation
claims (incidentally, Nadeau lost on that final claim too. The court found that I
did not owe my brothers legal bill. They only awarded Nadeau a very small
award for work I had authorized after my brother fired Nadeau).
Next, Nadeau swears in his affidavit that it was his lawsuit that very notably
spawned the filing of my frivolous and clearly malicious bar complaint, when
in fact, he certainly knows that he filed his lawsuit after I filed my bar complaint.
In fact, his defamation claims make it clear that it was my bar complaint that
spawned his lawsuit. His position was that I had defamed him by filing that bar
complaint. Yet, as you, yourself, have seen from the evidence presented here: the
Nadeau Bar Complaint, Grievance 1, Page 23

dismissal of at least one of my bar grievances was based on a fraud upon the
court that was perpetrated by Nadeau.
These are sworn statements by an officer of the court who, at the time, was also
a part-time judge in the state of Maine!
2. Continuing with item 10 of Nadeaus Sworn Affidavit, Nadeau wrote: Pratt has
indeed had a history of harassing licensed professionals, and he proceeds to list
(a) an attorney who Nadeau instructed me to file a bar complaint against on
behalf of my brother; (b) Nadeau himself, who was, in fact, unethical; (c) A
property appraisal I reported because it was written by a close friend of the
person who was buying out my share of the real estate; and (d) A complaint filed
by my attorney in the above mentioned property dispute (EXHIBIT 20, pages 34). Nadeau includes this statement in his Sworn Affidavit, knowing that none of
these complaints support his claim that I have a history of harassing licensed
professionals.
3. In item 12 of Nadeaus Sworn Affidavit, he wrote regarding his intentions:
After Pratt lost the case before Justice Welch, she has written many utterly false
things about me in her book My attorney and I will highlight those falsities in
painstaking detail during the course of discovery and trial. (EXHIBIT 20, page

5)

Nadeau knew, when he wrote this, that the contents of my Book and bar
complaint were true. No amount of discovery was going to produce any
falsities for him to reveal in painstaking detail (nor did it). Furthermore,
Nadeaus knowledge of the truthfulness of my Book and bar complaint makes it
more likely than not, that he also knew that he would not be taking this case to
trial.
In fact, the only falsities that were revealed in the course of this litigation came
from Nadeau.
Submitting false evidence and statements/tampering with evidence
One of Nadeaus key claims in his lawsuit against my book/bar complaint, right up to the
end, concerned his handling of my brothers case. That portion of my 2007 bar complaint
had also been dismissed, as follows:
The facts before the panel confirm that Attorney Nadeau was hired by Donald Madore
pursuant to a written fee agreement dated November 15, 2005 concerning Mr.
Madores business contract dispute with Jim Bell and others. Attorney Nadeau
performed legal services as agreed to, but Mr. Madore failed to remain current with
legal fees and expenses and therefore did not comply with that fee agreement. Despite
repeated urgings and requests by Attorney Nadeau, necessary retainer replenishment
or fee payments were not made such that any harm caused to Mr. Madores case was
due to his inaction, not any by Attorney Nadeau. (EXHIBIT 21, page 1, paragraph 2)
Nadeau Bar Complaint, Grievance 1, Page 24

Just like The Bars earlier decision regarding Nadeaus unethical emails, this dismissal was
also based on misrepresentations that were submitted by Nadeau, as follows:
a) The legal services agreed to were that Nadeau would secure a lien on the
properties before anything else. This was reiterated numerous times by me, my
brother and even Nadeau. Despite this, a number of months and over $8,000 in
fees later, no lien was recorded. The lien was ORDERED; it just wasnt recorded.
b) Nadeau claimed that this was my brothers fault. He based this claim on an email
he sent me on August 18, 2006, where he wrote:
My office has written and called for you and Donald during the past couple of
weeks regarding his case, including the need (but lack of funds in our trust
account pertinent to Donald) to record the judges favorable restraining order
against the Bells in the Essex County Registry of Deeds. (EXHIBIT 22)

This email is yet another of Nadeaus many misrepresentations. Nadeau could

not produce one piece of evidence showing that he had written or called me or
Donaldnor had he ever made any such attempt before. All of Nadeaus
previous attempts to reach Donald came in the form of emails to menever
letters or phone calls. His emails to me were always answered within 24 hours
(just as Exhibit 22 was). Nor does there exist any correspondence whatsoever
where Nadeau is requesting a phone conversation with Donald. In Nadeaus own
words in the course of this very litigation:
Pratt also fails to inform the reader, as the trial judge found, that Pratt, not her
stupid brother, was the person who specifically instructed me from the start of
the legal representation to direct all communications regarding the progress
and needs of her brothers case to Pratts attention, not to her brothers
attention, for response. Instead, the Defendants assert in their book that I was
somehow, suddenly expected to try to locate and speak with her ghost of a
brother directly and to leave her out of the messsomething Pratt never, ever
said to me. (EXHIBIT 23, page 15, paragraph 1)

c) The issue for my brother was that other liens were being filed and, in particular,
that the opposing parties were removing equity from the properties as quickly
as they could. Confirmation of this caused Donald, me and subsequent counsel to
conclude that Nadeaus delay in recording the lien was devastating to his case.
Nadeau countered this conclusion by insisting that no liens had been filed prior
to his August 18, 2006 email claiming to have been attempting to reach us. In
fact, in this 2014-2016 lawsuit, Nadeau submitted evidence (as Plaintiffs
Exhibits 24 and 27) that no liens had been filed. His exhibits were copies of
official records from the Salem Registry of Deeds, a grantor index of all liens
recorded against the properties of the opposing parties (certified court copies of
Nadeaus exhibits are attached here as EXHIBIT 24A). In support of these
exhibits, Nadeau wrote in his Statement of Material Facts and accompanying
Sworn Affidavit:
During the time from April, 2006 when the Plaintiff was only partially retained
by [Donald] through September 20, 2006, no person or entity other than the
Nadeau Bar Complaint, Grievance 1, Page 25

Plaintiff acting on [Donalds] behalf, had caused any order of attachment or

other lien to be recorded in the Essex County Registries of Deeds against any Bell
real estate. (also included in EXHIBIT 24A)

In fact, Nadeaus Statement, Sworn Affidavit and both of his exhibits represent a
fraud upon a court. The records he submitted were not the true records from
the Salem Registry of Deeds. As you can see from the real records (EXHIBIT
24B), the two opposing parties, Caroline and Jim Bell, had taken the equity
out of all of their properties during the time that Donald I had been
repeatedly requesting a lien, as follows:
1. On 2/3/06, a $19, 777 lien was filed against one of the properties on the
record of Jim Bell.
2. On 3/2/06, Caroline Bell took out a $125,000 mortgage on the main property
in Donalds agreement with them (which represents the amount of money
Donald had invested almost to the dollar).
3. On 5/31/06, Jim Bell took out a $230,000 mortgage on another of their
properties;
4. Shortly thereafter, Jim Bell filed a homestead on one of their properties.
Nadeau knowingly adjusted his exhibits to misrepresent the true records, and
then made sworn statements that no other liens existed.
This fraud on the court doesnt just represent one small issue in an otherwise
legally sound lawsuit. Nadeaus entire lawsuit came down to TWO ISSUES: what I
wrote in my Book/bar complaint about his representation of my brothers case,
and the second issue discussed below. Whats more, this issue was founded on a
Bar dismissal that was based on the same fraud he is committing again, in
this lawsuit, which is that no liens had been filed, and that Nadeau had
been trying to reach my brother and I when, in fact, he had not.
Nadeaus attempts to hide and distort the facts of his case through this fraud
makes it more likely than not, that he knew his claim was frivolous.
Tampering with a witness:
Nadeaus second key issue in his lawsuit involved statements in The Book relating to a
medical record I saw when he entered it as an exhibit in a court proceeding. I had
commented on it very briefly in The Book, and only as it related to Nadeaus behavior (the
record diagnosed him as a narcissist and sociopath). Nadeau claimed that I lied about
what was in the record. However, the record Nadeau submittedwhich had been sealed
and stored in his court (where he presides as an elected part-time judge) completely
disappeared. This left one impartial, credible witness to testify as to the contents: an
attorney who was present in that case, Steve Candors of Kennebunk, Maine. I visited
Candors and he agreed to review the contents of the record Nadeau was attempting to
submit in lieu of the missing record, and testify as to whether or not it was the record he
saw. However, Candors changed his mind about testifying when he received a letter from
Nadeau Bar Complaint, Grievance 1, Page 26

Nadeau, sent days after Nadeau learned he was my witness. The letter, titled RE: Notice of
Claim began:
First, you are hereby provided notice of our intention to pursue a monetary claim
for consequential and punitive damage against you and your law firm concerning
your reported violations of the spirit and requirements of a certain Termination
Order of Dismissal issued by Judge Douglas of the York District Court on July 27,
2007, and of an incorporated but separately enforceable Agreement signed by you
and your former client, Lynnann Frydrych. (EXHIBIT 25, page 1, paragraph 2)

Nadeau is referring to the 2007 Agreement between him and Frydrych, which Nadeau has
breached countless times over the years, as described in Part D of this grievance (refer
back to page 13 of this grievance, item 2).
The letter continues in this vein, quoting misrepresentations from my testimony and in
general, intimidating this witness to the point where he decided not to testify (Candors is
well aware of Nadeaus litigious and retaliatory nature). The letter was a threat, and
Candors recognized it as such, as is evidenced by his email to me, where he wrote:
Bob sent me a threatening letter that made it sound like you threw me under the
bus. Until I read the deposition he references and you said you were going to send
me, I am stepping back. (EXHIBIT 26)

But as a matter of fact, Candors had been spooked, and no matter how many documents I
sent him, his fear of Nadeau (who is a judge where he practices law) overrode his desire to
help. And in fact, every lawyer I have ever spoken to in Maine is terrified of Nadeau, who
they unanimously consider a bully, and who is generally acknowledged to be someone
who will use his position on the bench to harm anyone who goes against him. In fact, he
isat this momentfacing charges of retaliation, threats and other violations from the
judicial committee in Maine.
And of course, Nadeaus notice of claim went away when Candors decided not to testify.
It is clear that this second lawsuit against me was nothing more than an attempt to
intimidate and bully me into removing The Book from publication. To further support this
claim, after two years of intense abuse, on the morning of trial, on April 16, 2016 (after a
week of reviewing hundreds of exhibits with the judge, and empaneling a jury), Nadeau
submitted a Motion to Dismiss his lawsuit against melisting extremely questionable
reasons.
The judge ruled in favor of dismissing the case, but she made it clear that she was not doing
it for his reasons or endorsing any of his claims by doing so. (EXHIBIT 27)
As a final ethical breach, Nadeau began anonymously slandering me and all of my books
online. He also started a website called MADANNOUNCER (EXHIBIT 28), through which to
slander me publicly. He also slandered the judge and posted all of the exhibits that the
judge ruled out (this was just before the trial). He was questioned about this on the
morning of trial. The judge put him under oath to ask if he was responsible for the contents
Nadeau Bar Complaint, Grievance 1, Page 27

of the website. He swore under oath that he was not, but admitted that he knew who was.
He further stated under oath, that his wife had taken it upon herself to start up the website,
adding, as a final taunt; Like Madore, she is a private citizen so she can write what she
wants. The judge asked Nadeau if he had participated in any way; Nadeau swore he had
not. The evidence at the hearing will show that he was behind it all.
Once again; Nadeaus misconduct in the course of this litigation adds insult to the injury
that was already perpetrated on Essex County Court during Nadeaus previous lawsuit
against me, and to the Bar of Overseers in Maine in 2007. All this misconduct was clearly
executed with intent. Nadeau knew that he was violating Maine Rule 3.3(a) with these
frivolous lawsuits that knowingly (1) make false statements of material fact; and that
(4) offer evidence that he knows to be false. He knew that he was violating Maine Bar
Rule 3.1(a) by bringing frivolous proceedings, with no basis in law and fact for doing so.
He knew that The Bar dismissal he based his frivolous claims on represented yet another
fraud upon the court. (Kenner v. C.I.R., 387 F 3d 689 (1968); Moores Federal Practice, 2d
ed., p. 512, Section 60.23). He knew that all of these actions represented professional
misconduct, as described in Maine Rules 8.4(a), 8.4(b), 8.4(c) and 8.4(d), by (a) violating
numerous provisions of the Maine Rules of Professional Conduct and the Maine Bar Rules; (b)
committing unlawful acts that reflect adversely on his honesty, trustworthiness and fitness as
a lawyer in other respects; (c) engaging in conduct involving dishonesty, fraud, deceit or
misrepresentation; and (d) engaging in conduct that is prejudicial to the administration of
justice.
And finally, by repeating this misconduct over and over again, Nadeau knows that he is
engaging in a pattern of behavior that makes his professional misconduct systemic.

Nadeau Bar Complaint, Grievance 1, Page 28