High Profile Richmond Attorneys Face Serious Sanctions for Fraud and Misconduct

 Prominent Attorneys and their Counsel Face Harsh Sanctions in White Nationalism Case in the Virginia Court of Appeals.

On April 28, 2023, eight prominent attorneys through their counsel in the Richmond area filed a Joint Motion to Dismiss Appeal in the Court of Appeals of Virginia. What started as a normal motion has turned into a nightmare for the eight attorneys facing ethics complaints for conspiring together to promote and support a "white nationalism" syndicate which protected white affluent professionals from being investigated and prosecuted for their role in a 600-kilo cocaine organization that operated in the Richmond area for over ten years.

The Appellant immediately filed a Motion for Sanctions against the nineteen attorneys for fraud on the court and violating the rules of the Virginia Code of Professional Conduct(VCPC), specifically Rule 8.4 Misconduct. The attorneys are listed below.

APPELLEE	APPELLEE COUNSEL
Richard Cullen and Wade Kizer	Irving Blank
Judge Lee A. Harris Jr.	Brittany McGill, Amy Hensley
Shannon L. Taylor	Theodore Brenner
James B. Comey, Howard C. Vick Jr.	Brandon Santos, Garret Hooe
Michael Y. Feinmel	William Tunner, John O’Herron
Todd Stone	S. Keith Barker
George Manoli Loupassi	Bradley Marrs

The most prominent Attorney facing sanctions is Richard Cullen, the chief legal advisor to Governor Glenn Youngkin, Cullen is listed as the organizer of the "white nationalism" syndicate which operated in the Virginia Courts for over two decades.

Other prominent attorneys include James B. Comey, Judge Lee A. Harris Jr., Shannon Taylor, Howard Vick, and numerous McGuireWoods law firm attorneys. Richard Cullen, James Comey, and Howard Vick worked together at McGuireWoods. Richard Cullen is the Godfather of James Comey's daughters.

The Motion for Sanctions states that the nineteen attorneys conspired together to commit numerous violations of Virginia Codes, Fraud on The Court, and Misconduct. A copy of the Motion for Sanctions can be viewed: Motion for Sanctions in the Court of Appeals

The violations are listed as:

VCPC Rule 3.3 Candor Toward The Tribunal

(a) A lawyer shall not knowingly:

(1) make a false statement of fact or law to a tribunal;

(2) fail to disclose a fact to a tribunal when disclosure is necessary to avoid assisting a criminal or fraudulent act by the client;

(3) fail to disclose to the tribunal controlling legal authority in the subject jurisdiction known to the lawyer to be adverse to the position of the client and not disclosed by opposing counsel; or

(4) offer evidence that the lawyer knows to be false. If a lawyer has offered material evidence and comes to know of its falsity, the lawyer shall take reasonable remedial measures.

(b) A lawyer may refuse to offer evidence that the lawyer reasonably believes is false.

(c) In an ex parte proceeding, a lawyer shall inform the tribunal of all material facts known to the lawyer, which will enable the tribunal to make an informed decision whether or not the facts are adverse.

(d) A lawyer who receives information clearly establishing that a person other than a client has perpetrated fraud upon the tribunal in a proceeding in which the lawyer is representing a client shall promptly reveal the fraud to the tribunal.

(e) The duties stated in paragraphs (a) and (d) continue until the conclusion of the proceeding and apply even if compliance requires disclosure of information protected by Rule 1.6.

VCPC Rule 8.4 Misconduct

It is professional misconduct for a lawyer to:

(a) violate or attempt to violate the Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another;

(b) commit a criminal or deliberately wrongful act that reflects adversely on the lawyer's honesty, trustworthiness or fitness to practice law;

(c) engage in conduct involving dishonesty, fraud, deceit or misrepresentation which reflects adversely on the lawyer’s fitness to practice law;

Va. Code § 8.01-271.1. Signing of pleadings, motions, and other papers; oral motions; sanctions.

B. The signature of an attorney or party constitutes a certificate by him that (i) he has read the pleading, motion, or other paper, (ii) to the best of his knowledge, information, and belief, formed after reasonable inquiry, it is well grounded in fact and is warranted by existing law or a good faith argument for the extension, modification, or reversal of existing law, and (iii) it is not interposed for any improper purpose, such as to harass or to cause unnecessary delay or needless increase in the cost of litigation.

F. Signature defects in appellate filings, including the notice of appeal, shall be raised in the appellate court where the appeal is taken. Failure to timely raise the issue of a defective signature in an appellate pleading, motion, or other paper while the case is pending before the appellate court waives any challenge to that pleading, motion, or other paper based on such a defect.

G. If a signature defect is not timely and properly cured after it is brought to the attention of the pleader or movant, the pleading, motion, or other paper is invalid and shall be stricken. A signature defect shall be cured within 21 days after it is brought to the attention of the pleader or movant. If a signature defect is timely and properly cured, the pleading, motion, or other paper shall be valid and relate back to the date it was originally served or filed.

It is questionable if the Appellees even mailed their February 27, 2023, and October 17, 2023, “Notice” to the Appellant and should be ordered to produce a certified U.S. Postal receipt or commercial delivery receipt evidencing of completing the service process on the Appellant. The Appellees recognize that the Appellant resides in a foreign country and should have taken reasonable care to assure that the Appellant received the “Notice,” as certified in their Joint Motion submitted to this Court.

Rule 1:12. Service of Papers after the Initial Process: 

All pleadings, motions, and other papers served after the initial process in an action and not required to be served otherwise, and requests for subpoenas duces tecum must be served by delivering, dispatching by commercial delivery service for same-day or next day delivery, transmitting by facsimile, transmitting by electronic mail when Rule 1:17 so provides or when consented to in writing signed by the person to be served, or by mailing, a copy to each counsel of record on or before the day of filing.

Chapter 5. McGuireWoods Commits Fraud on the Court Defending themselves from Fraud on the Court

 RVA McGuireWoods Continual Fraud on the Court exposed in Ethics Complaint case

   An ethics complaint against McGuireWoods attorneys Richard Cullen, James Comey, Howard C. Vick, William Birch Douglass III, and William Hutchens has led to more fraud on the court violations by their defense attorney Brandon Santos of McGuireWoods RVA.

   The ethics complaints filed in Henrico County Circuit Court are; CL21005759 Spanos v. Douglass et al., CL21005758 Spanos v. Vick, CL21006572 Spanos v. Vick et al., which alleged several violations of the Virginia Code of Professional Conduct, Federal and Virginia Codes, were heard on January 13, 2023, by Judge Joseph Ellis. 

   On September 19, 2022, Judge Joseph Ellis issued an order clearly stating:

              “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.”

    Judge Joseph Ellis’s order clearly states that the court has no jurisdiction in these matters, and it is unnecessary for the court to rule on other motions and defenses filed by Defendants. So then, why would Judge Ellis suspend his order until further order from this court?

   On October 5, 2022, 17 days after Judge Ellis' order, Brandon Santos devised a scheme to file a Motion for Entry of Pre-filing Injunction to have Judge Ellis issue an order prohibiting the Plaintiff from filing further ethics complaints against the entire Commonwealth of Virginia.

   McGuireWoods Brandon Santos violated Judge Ellis's order and had unethically violated the Virginia Supreme Court Rules of Court, as he comingled his Motion for Injunction with the Plaintiff's ethics complaint; Santos’s Motion for Injunction should have been filed separately and before September 19, 2022, hearing date, not after Judge Ellis entered an order. Additionally, Plaintiff should have been served according to Hague Service Convention, as Plaintiff is a resident of Greece.

    The major problem with serving Plaintiff according to the Hague Service Convention, then McGuireWoods Santos would be supporting the Plaintiff's argument in his ethics complaint filed against McGuireWoods William Birch Douglass III and William Hutchins.

   William Birch Douglass III and William Hutchens are accused of committing fraud on the court during their employment with McGuire-Woods law firm. They conspired unethically to have their client illegally removed as trustee & executor of a family trust.

      McGuire-Woods’ partners initiated a lawsuit representing both the plaintiff and the defendant. The McGuire-Woods partners knew the exact location of the trustee in Greece. They communicated with him through conference calls and postal service but did not serve him through the Hague Service Convention; instead served him at his mother’s house, who was the plaintiff.

   Greece's Protocol to the Convention of 15 November 1965 on the Service Abroad of Judicial and Extrajudicial Documents in Civil or Commercial Matters states that foreign service can only be processed through the Greek DOJ and served by only a certified service processor/court official. Furthermore, the documents intended to be served must also be translated into the Greek language and certified by the Greek Department of Foreign Affairs.

   The Trust had no provision for removal, and the petition for removal listed no financial irregularities to justify the petition. 

   The Defendants filed a Defense Pleading on September 27, 2021, in which they did not deny the allegations, only that the statute of limitations had expired for the criminal violations. Yet, there is no statute of limitations for fraud in the court, unethical misconduct, and violation of the Rules of the Virginia Code of Professional Conduct.

   The McGuireWoods partners responded in their defense pleadings that Nickolas Spanos was never a client of McGuireWoods despite evidence showing that Spanos was a client from 1992 and had issued several checks signed by Spanos to McGuireWoods law firm for over seven years. The checks are listed in Estate reports to the Henrico County Commissioner of Accounts. 

 

   

Corrupt Judges are the Problem with Virginia's Judicial System

 Corrupt Judges Tarnish the Image of Virginia's Judicial System

     The term "a few bad apples..." rings loud in the Virginia Justice system, as recent ethics complaints filed in the courts have exposed the deep state corruption that exists in the courts. Further evidence supports that there is a Virginia Shadow Government (VSG) that controls the Executive, Legislative and Judicial branches in Virginia.

     The head of the VSG is Richard Cullen, recognized for his title as the "Godfather" of the VSG, Cullen has been in charge of McGuireWoods law firm for decades and despite some leaves of absence to take high-profile positions in the DOJ, Cullen still calls the shots. Richard Cullen is currently the Chief Legal Advisor to Governor Glenn Youngkin.

     When a syndicate like the VSG controls the three branches of the government, they control the state, but when the VSG controls the Judicial branch it controls the U.S. Constitution and the Virginia Constitution, as the courts decide due process of law and this is by far the most significant article of any constitution. 

     Judge Lee A. Harris Jr. had a distinguished and unblemished career, beginning with the Henrico County Commonwealth Attorney's office and in 1992 Judge Harris was appointed to be a Circuit Court Judge with Henrico County, Judge Harris has been a Circuit Court judge for almost 30 years. Recently, over three Ethics Complaints have been filed against Judge Harris, the most significant is CL21006572 filed in the Henrico Circuit Court, Harris and eight other defendants are accused of operating a criminal syndicate in the Virginia Justice system and promoting white nationalism, which believes that white people are superior and deserve preferential treatment and legal protections. The complaint states that Richard Cullen bribed Harris to give preferential treatment and legal protection to white affluent professionals who were McGuireWoods clients and lawyers involved in a 600-kilo cocaine case involving a international fugitive. Court records show that Judge Harris and other Henrico County prosecutors conspired together to keep the fugitive in exile, so that he could not be extradited back to Henrico County to testify against McGuireWoods clients.

     John Adrian Gibney, Jr. is a federal judge on senior status with the United States District Court for the Eastern District of Virginia. He joined the court in 2010 after a nomination from President Barack Obama. Judge Gibney is facing an Ethics complaint, CL22002249, filed in the Henrico County Circuit Court, which states that Judge Gibney refused to recuse himself for conflict of financial interest, from a case he was presiding over. The case involved an ethics complaint filed against Howard C. Vick Jr., a former Henrico Commonwealth attorney who received bribes by Richard Cullen, who offered Vick a partners position with McGuireWoods law firm in exchange for his refusal to extradite a international fugitive who was the hub of a 600-kilo cocaine organization that operated in the Richmond area for over 10 years. The ethics complaint against Judge Gibney states Judge Gibney violated the Virginia Judicial Canons (VJC) and the Virginia Code of Professional Conduct (VCPC). Judge Gibney is married to Yvonne Gibney who is on the VSB Disciplinary Board panels, had direct financial conflict of interest and personal conflict of interest concerning the Vick Complaint. A motion was filed by the Plaintiff for Judge Gibney to recuse himself but Gibney refused and issued an order and memorandum in the case, which evidenced Gibney's conflict of interests.

     Joseph J. Ellis retired in 2019 from the 15th Judicial Circuit, where he presided in Spotsylvania County. Judge Ellis currently works for Juridical Solutions, specializing in Alternate Dispute Resolution through mediation services. The Supreme Court of Virginia appointed Judge Ellis to preside over three ethics complaint cases (CL21005758, CL21005759, CL21006572) pending in the Henrico County Circuit Court, the ethics complaints are against McGuireWoods attorneys, judges, prosecutors and government officials who conspired together to violate the RICO act and constitutional rights. An ethics complaint, CL22006233, was filed in the Henrico Circuit Court against Judge Ellis violated the Virginia Judicial Canons (VJC) and the Virginia Code of Professional Conduct (VCPC) concerning Conflict of Financial Interests and violating Title 18 Section 242, Deprivation of Rights.

    All the circuit court judges in the Henrico County Circuit Court have recused themselves from hearing and cases concerning international fugitive Nickolas Spanos and the 600-kilo cocaine case, which alleges bribery by Richard Cullen to public officials for financial and political gain. Furthermore, all the U.S. District court judges of the Eastern District of Virginia have recused themselves from presiding over the Judge John Gibney ethics complaint case and a U.S. District court judge from Maryland had to be specially appointed to the Spanos-Gibney case.

    In any "rotten apple" situation, the only remedy is to separate the bad apples from the good apples, which appears to be the case concerning corrupt judges.

Chapter 4. Judge Joseph Ellis ignores Virginia Statutes & Superior Court Rulings

 McGuireWoods Corruption Surfaces in Judge Ellis Rulings on Virginia Court's Jurisdiction in Attorney Disciplinary Cases

   The Court of Appeals of Virginia Opinion on December 6, 2022, in Virginia Retirement System v. Joan S. Shelton Va. App. 434 (2022) authored by the Honorable Judge Mary Bennett Malveaux clearly states: 

• “[a]n agency does not possess specialized competence over the interpretation of a statute merely because it addresses topics within the agency’s delegable authority.” 
• “[w]hen the language of a statute is unambiguous, [courts] are bound by the plain meaning of that language.” 
• “[W]hen the General Assembly has used specific language in one instance, but omits that language or uses different language when addressing a similar subject elsewhere in the Code, we must presume that the difference in the choice of language was intentional.” 

     The CAV Opinion directs the Trial Courts to strictly adhere by Virginia codes and not to deviate from the language and prohibits it to be interpreted in any other manner than what the codes states.

     Judge Ellis' order on September 19, 2022, and the Memorandum Opinion/Order on January 13, 2023, intentionally ignored:

• Virginia Supreme Court Rule 13-2 Authority of the Courts:                 

     "Nothing in this Paragraph shall be interpreted so as to eliminate, restrict or impair the jurisdiction of the courts of this Commonwealth to deal with the disciplining of Lawyers as provided by law. Every Judge shall have authority to take such action as may be necessary or appropriate to protect the interests of clients of any Attorney whose license is subject to a Suspension or Revocation." 

• U.S. Supreme Court v. Consumers Union, 446 U.S. 719, (1980):         

   “Appellant Virginia Supreme Court, which claims inherent authority to regulate and discipline attorneys, also has statutory authority to do so. Pursuant to these powers, the court promulgated the Virginia Code of Professional Responsibility (Code) and organized the Virginia State Bar to act as an administrative agency of the court to report and investigate violations of the Code. The statute reserves to the state courts the sole power to adjudicate alleged violations of the Code, and the Supreme Court and other state courts of record have independent authority on their own to initiate proceedings against attorneys.”

• Virginia Statutes on Virginia Court's jurisdiction and authority concerning attorney disciplinary cases in the Virginia Courts:      

§ 54.1-3915. Restrictions as to rules and regulations:

    "...“nor shall it promulgate any rule or regulation or method of procedure which eliminates the jurisdiction of the courts to deal with the discipline of attorneys.”

          § 54.1-3910. Organization and government of Virginia State Bar:

              "...The Virginia State Bar shall act as an administrative agency of the Court for the purpose of investigating and reporting violations of rules and   regulations adopted by the Court under this article."

• SCV opinion disseminated in Moseley, 273 Va. 688 (2007):

           “A court has an inherent power to discipline and regulate attorneys practicing before it. This power, since the judiciary is an independent branch of government, is not controlled by statute. Thus, the court's authority to discipline attorneys and regulate their conduct in proceedings before that court is also a constitutional power derived from the separation of powers between the judiciary, as an independent branch of government and the other branches.  

     “This inherent and constitutional power is essentially acknowledged in Code § 54.1- 3915, which prohibits the promulgation of any rule or regulation or method of procedure which eliminates the jurisdiction of the courts to deal with the discipline of attorneys.”

         The January 13, 2023, Memorandum Opinion was unethically drafted by McGuireWoods Brandon Santos for Judge Joseph Ellis; Judge Ellis violated several Judicial Canons by signing the Memorandum Opinion; giving further evidence of a judicial system corrupted by the McGuireWoods Shadow Government.

Chapter 3. Judge Joseph Ellis States Corrupt Court Officials Must Be Protected

Judge Ellis Final Order Protects Corrupt Court Officers and Judges

February 1, 2023. Author- Brace Impact

      On January 13, 2023, Judge Joseph Ellis issued his Memorandum Opinion and Order in four complaints filed in the Henrico County Circuit Court, dismissing the complaints and imposing an injunction on Nickolas Spanos from filing any further ethics complaints exposing corruption in the Commonwealth of Virginia.

     The complaints against corrupt court officials filed by Spanos were supported by hundreds of pages of evidence which included FBI reports, court documents, emails of court clerks stating that records and filings were tampered with, tampered court records sent to the Court of Appeals, Judge’s false statements, and numerous other documents that the defendants had accepted bribes in exchange for financial and political favors.

      The Memorandum Opinion was unethically written for Judge Ellis by McGuireWoods Counsel Brandon Santos, the attorney for Defendants Richard Cullen, James Comey, Howard Vick, William Birch Douglass III, and William Hutchens, who were previous attorneys with McGuireWoods law firm in Richmond, Virginia.

     The five McGuireWoods attorneys were accused of supporting and promoting a "White Nationalism Doctrine" along with seven co-defendants that gave special legal protection and treatment to the white, affluent middle to upper-class professionals who were clients attorneys of McGuireWoods law firm that were involved in a 600-kilo cocaine organization. As a result, the white, affluent professionals were protected from being investigated and charged for their role in the 600-kilo cocaine organization.

    The Plaintiff, Nickolas Spanos, had submitted evidence of FBI reports, court documents, and other evidence that exposed the McGuireWoods Shadow Government headed by Richard Cullen. Additionally, the complainant gave evidence that Richard Cullen had bribed several Henrico County Commonwealth Attorneys, Judges, U.S. Attorneys, and other court officials to obstruct justice in the Spanos cocaine case. 

    Spanos filed a Motion for Judge Joseph Ellis to Recuse Himself from hearing any of the ethics complaints. The Motion gave evidence of Judge Ellis's close financial relationship with McGuireWoods law firm, Richard Cullen, and having ex parte communications with Brandon Santos. Judge Joseph Ellis who works as a mediator for Juridical Solutions has a financial conflict of interest as McGuireWoods law firm is a client of Juridical Solutions, which Judge Ellis mediated litigation for McGuireWoods. Judge Joseph Ellis is paid $400 per hour for his mediation service and the average mediation is 30-50 hours. See link below:

https://juridicalsolutions.com/professionals/hon-joseph-j-ellis-ret-juridical-solutions-mediation-arbitration/

   Judge Ellis was ethically obligated to rule on the Motion to Recuse himself before presiding over the hearing, Judge Ellis refused to rule on the Motion to Recuse Himself and conducted the ethics complaint hearings which violated numerous judicial canons of Virginia. 

   The Memorandum Opinion and Order written for Judge Ellis by McGuireWoods defense counsel Brandon Santos has given evidence of judicial misconduct by Judge Ellis which Judge Ellis and Brandon Santos had ex parte communications on the details of the Memorandum Opinion and Order that Brandon Santos drafted for Judge Ellis to sign. The Memorandum Opinion and Order was signed at the end of the January 13, 2023, hearing, giving further evidence that ex parte communications took place between Judge Ellis and Brandon Santos.

    Despite Judge Ellis issuing an order on September 19, 2022, dismissing the four complaints filed by Spanos, Judge Ellis suspended the order to unethically allow McGuireWoods Brandon Santos to file a Pre-Filing Injunction on October 5, 2022. The Pre-Filing Injunction ordered Spanos not to file further ethics complaints in the Commonwealth of Virginia. Yet, each Virginia circuit court has jurisdiction over filings submitted to it and other courts cannot prohibit any court filing. 

    The Memorandum Opinion and Order contradicts itself throughout the Final Order and gives evidence of further corruption of judges, which states in part:

    "Upon consideration of the Motion, briefs, and presentations at oral argument, the Court determines that a pre-filing injunction is merited. In determining whether a pre-filing injunction is substantively warranted, a court must weigh all the relevant circumstances, including (1) the party's history of litigation, in particular, whether he has filed vexatious, harassing, or duplicative lawsuits; (2) whether the party had a good faith basis for pursuing the litigation or simply intended to harass; (3) the extent of the burden on the courts and other parties resulting from the party's filings; and (4) the adequacy of alternative sanctions."

How can Judge Ellis rule on the Pre-Filing Injunction which he had ruled that the Court has no jurisdiction to hear the matter further. McGuireWoods did not file a separate Motion for Injunction but filed the Pre-Filing Injunction after Judge Ellis issued an order stating that the Court did not have jurisdiction in this matter and no further rulings were necessary.      

  "First, in addition to the above-captioned cases, the Plaintiff’s history of litigation shows he has filed many duplicative, vexatious lawsuits generally alleging "ethics complaints" against various attorneys and judges in the central Virginia region."

   "Second, and to this end, Plaintiff’s "ethics complaint[s]" in these cases are intended to harass. As noted above, Plaintiff has repeatedly asserted this cause of action in circuit courts of the Commonwealth, and not once has he been successful. That is for good reason, as authorities in Virginia have long held that the Code does not afford Plaintiff standing to bring an ethics complaint in this Court."

The Plaintiff proved that he met the requirements to have standing in filing complaints against attorneys who harmed him and others by their actions and provided hundreds of pages of evidence to support his allegations. 

The Defendants in their Demurrers and Plea in Bar never denied the allegations and failed to defend themselves, only stating that their misconduct was protected by judicial and prosecutorial immunity.

     "Third, the burden on this Court and Defendants has been significant. Plaintiff’s Complaints in the above-captioned matters required the recusal of all sitting judges in the Henrico County Circuit Court. And, as noted above, Plaintiff has filed multiple suits in multiple jurisdictions across central Virginia, none of which have succeeded. Plaintiff has also extended the burden of his various baseless claims into appellate courts, where he is currently pursuing seven appeals at the state and federal level relating to the above-referenced "ethics complaints" filed in Henrico, Richmond, and Louisa. See Spanos v. Gibney, Case No. 22-2246 (4th Cir.) (removed from Spanos v. Gibney, CL 22-2249 (Henrico)); Spanos v. Vick, et al., CAV Record No. 1558-22-2; Spanos v. Vick, CAV Record No. 1554-22-2; Spanos v. Douglass & Hutchins, CAV Record No. 1553-22-2; Spanos v. Freed, et al., CAV Record No. 0706-22-2; Spanos v. Feinmel, CAV Record No. 0140-2202; Spanos v. Taylor; CAV Record No. 0139-22-2."

The Plaintiff has the right to petition the courts under the Fourteenth Amendment of the U.S. Constitution and has filed his complaints according to Virginia Statutes concerning the discipline of attorneys who violate the rules of the Virginia Code of Professional Conduct.

Even the Virginia State Bar's Deputy Intake Officer Jane Fletcher stated to Spanos through numerous letters supporting the Plaintiff's right to take civil action against attorneys who acted unethically and the Virginia Courts had jurisdiction to discipline attorneys. 

     "To this end, Plaintiff argues in his "Objections to the Defendants Pre-Filing Injunction" that his appeals of the above-captioned cases divested this Court of jurisdiction to hear the Motion. But this Court-in accordance with Rule 1: 1 of the Rules of the Supreme Court of Virginia-clearly suspended the order dismissing his Complaints with prejudice so that it would retain jurisdiction to hear the Motion. In this respect, the Plaintiff’s attempt to wield his appellate filings as a shield against the Motion further demonstrates the undue burden he has imposed on the judicial system."

How can Judge Ellis rule in his Final Order that the Court does not have jurisdiction to hear this matter, yet Judge Ellis rules on the Pre-Filing Injunction which is part of the matter and was filed after he issued his final order, even stating; "Given this ruling, it is not necessary for the Court to rule on other motions and defenses filed by Defendants to Plaintiff s Complaint.”

   "Finally, this Court has an obligation to protect the Court, its staff, the Defendants, and future defendants, from the harassment and expense of unfounded litigation, and to preserve valuable judicial resources. For these reasons, imposing a pre-filing injunction is an appropriate sanction under this case and the many similar cases Plaintiff has filed across the Commonwealth."

No, the Court has an obligation to serve and protect the public first and foremost, to insure that justice is served and to report unethical misconduct by attorneys and judges. The Court is obligated to follow the U.S. Constitution, Judicial Canons of Virginia, Virginia Statutes, and the SCV Rules of Court. Its obligation is not to protect the McGuireWoods shadow government that has created a criminal syndicate in the Virginia Judicial system.  

"It is therefore ORDERED, ADJUDGED, and DECREED that Plaintiff is enjoined from any further filings in this Court, or in any other court in the Commonwealth of Virginia without first obtaining leave from this Court. As a part of any motion for leave to file any such pleading or filing, Plaintiff must attach a copy of this Memorandum Opinion & Order and a detailed written statement explaining why such pleading or filing is materially different from the "Ethics Complaints" filed against the Defendants in the above-captioned actions."

Judge Ellis has violated his own Final Order, how can he order the Plaintiff not file further ethics complaints when he has ruled that the Court has no jurisdiction in this matter?  

Judge Ellis contradicts his own order, as he is stating that the "Plaintiff is enjoined from any further filings in this Court, or in any other court in the Commonwealth of Virginia without first obtaining leave from this Court", Judge Ellis is giving a clear message that Virginia Courts have jurisdiction to hear ethics complaints against attorney unethical misconduct, otherwise Judge Ellis would have stated that the Plaintiff is enjoined from filing any further ethics complaints in Virginia Courts as they do not have jurisdiction to hear these matters.

A footnote at the end of the order ironically states that Judge Ellis's Final Order is without standing:

    "This Court does not restrict whether another court of this Commonwealth can accept filings from Plaintiff, only that Plaintiff will face contempt in this Court for failure to comply with this Memorandum Opinion & Order or the accompanying court orders." 

    Judge Ellis is threatening Spanos with contempt of court, knowing that Spanos has 13 outstanding indictments for the distribution of cocaine and was publicly accused by the Henrico Commonwealth Attorneys’ office for being the "hub of a 600-kilo cocaine organization that operated in the Richmond, Virginia area for over ten years". The basis of the Complaints filed by Spanos is that numerous DOJ and court officials accepted bribes to refuse the extradition and prosecution of Spanos to prevent him from testifying against white, affluent McGuireWoods attorneys and clients.

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.

    

        

Chapter 1. EVIDENCE OF MCGUIREWOODS SHADOW GOVERNMENT IN VIRGINIA COURTS

 Judges' Orders Further Exposes the McGuireWoods Shadow Government Corruption

January 22, 2023. Author- Brace Impact

     After 14 months, decisions were issued concerning four complaints filed in the Henrico County Circuit Court against 10 high-profile attorneys consisting of judges, prosecutors, and high profile attorneys including Richard Cullen, the Chief Legal Advisor for Virginia Governor Glenn Youngkin.

    As alleged in the complaints filed, Judge Joseph Ellis's Memorandum Opinion and Order issued on January 13, 2023, gave further evidence that McGuireWoods Shadow Government, headed by Richard Cullen, controls the Judicial system in the Virginia Courts. No matter the crimes committed by Virginia Shadow Government lawyers and the legal arguments presented by Plaintiffs, the judges will disregard the U.S. Constitution and Rules of Court and always rule in favor of McGuireWoods Shadow Government.

    The highly controversial case forced the recusal of five Henrico County Circuit Court judges and three other judges designated by the Virginia Supreme Court.  Judge Wilford Taylor had recused himself after evidence filed in the cases proved he had ex parte communications with third parties which he reversed a previous order allowing Spanos to give testimony by two-way audio-video communications. Judge Joseph Ellis denied Spanos's Motions to appear by two-way audio-video and give testimony.

     The defendants listed in the ethics complaints are:

• Richard Cullen
• James B. Comey
• Howard Vick
• Judge Lee A. Harris
• Shannon Taylor
• Michael Feinmel
• Heidi Barshinger
• George Manoli Loupassi
• Wade Kizer
• Todd Stone
• William Birch Douglass III
• William Hutchins

    

    The Defendants filed Demurrers and Pleas of Immunity stating that their unethical misconduct and crimes were protected by judicial and prosecutorial immunity. The Defendants did not deny the allegations of bribery, obstruction of justice, destroying evidence, forgery and several constitutional violations in the complaints.  

     

     Evidence filed in the complaints depicted that McGuireWoods law firm operates the Virginia Shadow Government, headed by Richard Cullen, which controls the three branches, Judicial, Legislative, and Executive, of the Commonwealth of Virginia. The complaints further stated that McGuireWoods law firm has infiltrated the DOJ and FBI by placing McGuireWoods attorneys in key positions and controlling the manner of which the FBI and DOJ is operated.

    

     The complaints gave hundreds of pages of evidence that the 10 high profile attorneys promoted and supported a "white nationalism doctrine" which gave 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. 

    The complaints filed by Nickolas Spanos, who had been accused of being the "hub" of the 600-kilo cocaine organization, gave evidence of bribery, political favors, and a criminal syndicate that operated in the Henrico County Circuit Court. Spanos who has been protected by the Henrico Commonwealth Attorney's office and kept in exile, so that he could not testify against the affluent white professionals who were involved in the 600-kilo cocaine organization. Despite having 13 indictments for the distribution of cocaine, the Henrico Commonwealth Attorney's office has refused to extradite Spanos to Henrico County.

    The complaints gave evidence, which included FBI reports and court documents that Richard Cullen obstructed justice and bribed Henrico Commonwealth Attorneys to protect Spanos from being arrested and extradited to Henrico County to face the 13 indictments for distribution of cocaine amounting to 600 kilos. Court documents stated that Cullen, managing partner for McGuireWoods law firm, did not want Spanos prosecuted for the 13 indictments as it would lead to Spanos testifying against the affluent white professionals who were attorneys employed by McGuireWoods or clients of McGuireWoods.

     Spanos and his family were clients of McGuireWoods, under Richard Cullen's management, with estate holdings in the millions of dollars. Richard Cullen bribed Henrico County Commonwealth Attorney Howard Vick with a partners position with McGuireWoods law firm in exchange for his refusal to file an extradition request for Spanos while he was in Greece. The USA and Greece have had an extradition treaty since 1937 and Spanos had no protection from being extradited.

    On January 13, 2023, Judge Joseph Ellis issued orders for:

Case No. CL21005758 Spanos v. Vick, 

Case No. CL21005759 Spanos v. Douglass et al., 

Case No. CL21006572 Spanos v. Vick et al.

Case No. CL22002250 Spanos v. Harris et al.

   The orders dismissed Spanos's complaints stating that Spanos did not have standing and the Court did not have jurisdiction to discipline attorneys accused of violating the Rules of the Virginia Code of Professional Conduct (VCPC).

    Spanos gave evidence that Virginia Codes, Rules of the Supreme Court of Virginia, Virginia Supreme Court and United States Supreme Court cases and the Virginia State Bar dictated that only Virginia Courts have the authority and jurisdiction to discipline attorneys who violate the rules of the VCPC. Judge Joseph Ellis ignored the Virginia Legislature, Virginia Supreme Court rules, Virginia and U.S. Supreme Court opinions and Virginia State Bar letters which all supported Spanos's assertions that Virginia Courts have jurisdiction in attorney disciplinary hearings.

    Spanos filed motions for Judge Joseph Ellis to recuse himself because he violated the Virginia Judicial Canons by having a conflict of interest concerning the defendants, specifically Richard Cullen and other McGuireWoods defendants. Judge Joseph Ellis refused to address the motion to recuse himself and neglected to issue an order.

    Spanos also filed an Objection to a Pre-Filing Injunction submitted by McGuireWoods which sought to prohibit Spanos from filing ethics complaints in the entire Commonwealth of Virginia. Spanos based his objection that McGuireWoods attorneys violated Va. Code § 8.01-271.1. which contained signature defects and gave notice that they were required to be remedied within 21 days of notice by Spanos. McGuireWoods attorneys Brandon Santos, Garret Hooe, and Ellen Hubbard, had unethically signed the Pre-Filing Injunction without being authorized to represent the other 7 defendants who had their own counsel of record.

    Judge Joseph Ellis unethically neglected to rule on Spanos's Motions and issued his Memorandum Opinion and Order without addressing the two important motions filed by Spanos.

    Despite the dismissal of the ethics complaints, Judge Joseph Ellis' Memorandum Opinion and Order undeniably proves that Virginia Judges are controlled by McGuireWoods Shadow Government headed by Richard Cullen and despite the hundreds of pages of evidence proving that a criminal syndicate exists in the Henrico County Circuit Court which supported and promoted "white nationalism", Virginia's citizens are left unprotected and have no constitutional rights to file complaints in the Virginia Courts.