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State of Maine v. Michael A. Doyle
Lawyers: Complaint to Overseers

February 16, 2002

Board of Overseers the Bar
P.O. Box 527
Augusta, ME 04332-0527

To Whom It May Concern:     RE: Ralph A. Dyer

I DO NOT WAIVE ATTORNEY-CLIENT PRIVELEGE IN THIS COMPLAINT

Dyer provided a draft of a letter to Diamond, dated October 4, 1996, that led Doyle to believe that its wording and subsequent conversations with Dyer that business could and should be conducted from a new or different entity Exhibit A

Dyer provided a false memo dated, October 10, 1996, that Doyle never received and which appeared in Peter DeTroy's file nearly two years after its alleged creation and was sent to Doyle by fax from VanDyke on June 9, 2000 please note that it was sent from Detroy's office on December 28, 1998 Exhibit B

Dyer's letter to the State, dated November 15, 1996 starting the FOI suit while Doyle was under investigation by the State an action that makes no sense if the October 10th memo is genuine Exhibit C

Dyer starts his aggressive stance with the State by letter, dated November 18, 1996, while he is claiming that he has warned Doyle that this is a Ponzi scheme on October 10th Exhibit D

Instead of Dyer restating his alleged "warning" he forms a strategy with Peter DeTroy and continues to mislead Doyle by memo dated November 18, 1996 Exhibit E

Dyer sends a memo dated, November 20, 1996, which lacks any restatement of his alleged warning and in a conversation, says "not to worry about the wrath of the Court that I will take care of that." Exhibit F

Dyer files FOI suit November 25, 1996 See Timeline Exhibit G

Dyer's memo dated, December 3, 1996, explains how Doyle should handle the clients when a reasonable person would expect their lawyer not to tell the clients that the "the investment is working" item "c" if Dyer had previously stated it was a Ponzi Exhibit H

Dyer's memo dated, January 9, 1997, last paragraph states "expose the investigation as a BOGUS MISUSE OF ADMINISTRATIVE AUTHORITY….COMMUNICATE WITH THE CLIENTS AND LET THEM KNOW THAT THE STATE WANTS TO INTERRUPT THEIR INCOME FOR UNKNOWN REASONS." (Emphasis added) Exhibit I

Dyer's letter to Dorsey dated, April 29, 1997, making yet another FOI request while telling Doyle everything is ok Exhibit J

Dyer's perjury in his Deposition, dated January 26, 2001, page 31 lines 10 to 25 and page 32 lines 1 to 13 Exhibit K the falsehood of his statements are verified by the public record showing 16 court filings and appearances for five months after his alleged withdrawal from this case, culminating with his appearance at a meeting at DeTroy's office in May 1997 see Timeline items 24 to 40 Exhibit G continuing in the Dyer Deposition page 6 lines 19 to 23 a false accusation of "churning an account" see Exhibit J continuing page 36 lines 1 to 22 Doyle was stunned and did not accuse the lawyers of not warning him, because at that time Doyle did NOT know that Dyer and DeTroy would lie about issuing any warnings, as their memos clearly showed they did not especially Dyer's actions after the false October 10th memo.

Dyer's perjury provided part of a series of false statements that the State used to extort two guilty pleas from Doyle based upon his need to overcome the perjury of three attorneys in this case at trial.

 
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