Chapter 2. Richard Cullen's McGuireWoods Shadow Government Exposed

 Judge Joseph Ellis and McGuireWoods Brandon Santos Collusion Exposes the McGuireWoods Shadow Government

January 25, 2023. Author- Brace Impact

      On January 13, 2023, Judge Joseph Ellis signed a Memorandum Opinion Orders for Henrico County Circuit Court Case Nos.:  

• CL21005759 Spanos v. Douglass et al.
• CL21005758 Spanos v. Vick, 
• CL21006572 Spanos v. Vick et al.
• CL22002250 Spanos v. Harris et al.

      The Memorandum Opinion Orders were drafted by McGuireWoods Counsel Brandon Santos, who was the counsel of record for the defendants James B. Comey, Howard C. Vick, William Birch Douglass, and William Hutchins. Brandon Santos represented Richard Cullen until February 15, 2022, when Richard Culled resigned from McGuireWoods to become the Chief Legal advisor to Governor Glenn Youngkin. Irving Blank was designated as defense counsel for Richard Cullen, as Cullen wanted to detach himself from James Comey and Howard Vick's obstruction of justice and bribery allegations.  

      McGuireWoods attorney Brandon Santos profile description states "Brandon’s practice focuses on advising and defending corporate and individual clients facing regulatory, administrative and criminal investigations. He has advised clients in a wide variety of matters including allegations of healthcare fraud, bank fraud, financial fraud, accounting fraud, import and customs violations, false claims, and the Foreign Corrupt Practices Act (FCPA). Part of his practice focuses on conducting internal corporate investigations". Brandon Santos is brought in when serious allegations of fraud and government corruption are charged against defendants.

     Brandon Santos is the lap dog of Richard Cullen, and was assigned to defend the McGuireWoods attorneys that were part of the 600-kilo cocaine criminal syndicate. The Defendants had colluded to support and promote a "White Nationalism doctrine", giving special legal treatment and protection to over 30 white affluent professionals consisting of lawyers, doctors and businessmen who were involved in a 600 kilo cocaine organization that operated in the Richmond area for over 10 years. Many of the white affluent professionals were clients of McGuireWoods law firm and connected to Richard Cullen. 

     Before the January 13, 2023, hearing there was a previous hearing on September 19, 2022 on the subject cases, which Judge Joseph Ellis issued an order, drafted by Brandon Santos. The September 19, 2022, order stated:

              “Plaintiff lacks standing to seek the relief requested in the Complaint, and this Court has no jurisdiction to grant the relief requested in the Complaint.”

              “It is therefore ORDERED, ADJUDGED, and DECREED that Defendants' motions are SUSTAINED, and Plaintiff s Complaint is DISMISSED with prejudice. Given this ruling, it is not necessary for the Court to rule on other motions and defenses filed by Defendants to Plaintiff s Complaint.”

              “It is further ORDERED, ADJUDGED, and DECREED that this Order is SUSPENDED until further order of this Court.”

    Please note the important sections of Judge Joseph Ellis' Order are emphasized above. 

Judge Joseph Ellis defective order errors

    On October 5, 2022, 17 days after Judge Ellis' order, Brandon Santos filed a Motion for Entry of Pre-filing Injunction to have Judge Ellis issue an order prohibiting the Plaintiff from filing further ethics complaints in the entire Commonwealth of Virginia. The Pre-filing Injunction was signed by only McGuireWoods counsel not by the other 7 Defendants counsel of record. McGuireWoods did not represent the other 7 defendants. Brandon Santos violated Va. Code § 8.01-271.1. which contained signature defects. Plaintiff gave notice to all the defendants counsel that they were required to remedy the signature defects within 21 days of written notice, Defendant's counsel never remedied the defective signatures.

     The filing of the Motion for Entry of Pre-filing Injunction violated the Virginia Supreme Court Rules of Court. The Pre-filing Injunction should have been filed separately and before the September 19, 2022, hearing date, not after Judge Ellis entered an order. The pertinent parts to Judge Ellis' order states:

• “Plaintiff lacks standing to seek the relief requested in the Complaint, and this Court has no jurisdiction to grant the relief requested in the Complaint.”
• "Plaintiff s Complaint is DISMISSED with prejudice. Given this ruling, it is not necessary for the Court to rule on other motions and defenses filed by Defendants to Plaintiff s Complaint.”

     Judge Ellis' order clearly states: 

• "...this Court has no jurisdiction" 
• "...it is not necessary for the Court to rule on other motions and defenses filed by Defendants to Plaintiff s Complaint.”

    Brandon Santos and Judge Joseph Ellis recognized the order's language and recognized two important issues; the court ruled it had no jurisdiction to hear the subject cases, thus it had no jurisdiction to hear the Pre-filing Injunction, additionally the order stated that it was not necessary for the Court to rule on other motions. Brandon Santos and Judge Ellis conspired together to violate Judge Ellis's September 19, 2022, order as they clearly violated the directive of the order which stated "...it is not necessary for the Court to rule on other motions and defenses filed by Defendants to Plaintiff s Complaint.” .

     Another important factor was that Judge Ellis order stated "...Order is SUSPENDED until further order of this Court.” Why would Judge Ellis suspend his order until further order of the Court? Brandon Santos and Judge Ellis recognized that Spanos would file a notice of appeal and have the cases heard before the Court of Appeals of Virginia (CAV), where he would be allowed to give oral arguments. Where Judge Ellis had violated Spanos's constitutional right to make arguments and give testimony in the Henrico Circuit court.

     Brandon Santos intentionally did not file the Motion for Injunction as a separate case as Spanos who resides in Greece would require that Santos serve him in accordance to the mandatory requirements of the Hague Service Convention. If Santos followed the articles of the Hague Service Convention, it would have weighed against William Birch Douglass III and William Hutchins, who were Defendants in one of the complaints filed. Douglass and Hutchins are accused of fraud concerning Spanos's Trust, having not properly serving him according to the mandatory requirements of the Hague Service Convention.

     Brandon Santos and Judge Ellis conspired together to keep the ethics complaint cases in the Henrico Circuit Court indefinitely by suspending the order. Neither Santos or Judge Ellis wanted the CAV to hear the ethics complaints, as it would further expose their unethical court procedures in the Appellate Court. The McGuireWoods shadow government is desperately trying to keep the Spanos cases from gaining exposure.

    Spanos recognized Judge Ellis and Brandon Santos plan to attempt to prevent him from filing a notice of appeal but Spanos ignored the September 19, 2022, Order stating that the order was suspended and tactfully filed a notice of appeal with the Henrico Circuit Court Clerk on October 12, 2022, 22 days after the order was entered. The Henrico Court Clerk was obligated to follow procedures and process the notice of appeal to the CAV and transmitted the court records on December 1, 2022, which the CAV accepted and confirmed the notice of appeal and records.

    On December 13, 2022, McGuireWoods counsel filed a Motion to Dismiss with the CAV on the basis that the September 19, 2022, Order was not final thus non-appealable. On December 15, 2022, Spanos filed his Objection to McGuireWoods' Motion to Dismiss based on his arguments that the order became final and that Judge Ellis's directives in his order stated that "...it is not necessary for the Court to rule on other motions and defenses filed by Defendants to Plaintiff s Complaint.”, thus all court affairs pertaining to the ethics complaints had been concluded and the order was final.