1. Oct. 3, 1996 Doyle returns call to Steve Diamond at the Securities Bureau at 5:50 pm. for a six minute call. Diamond states concern about Dirigo Capital Group.

2. Oct. 4, 1996 Doyle calls Ralph Dyer who advises not to give his name to State so as not to start the "meter running" with back and forth between Dyer and Diamond.

3. Oct. 4, 1996 Doyle call to Diamond at 11:05 am for nine minutes and record same. No mention of any warning for criminal or felony action against Doyle. [View Memo]

4. Oct. 4, 1996 Doyle's letter to Diamond notice that Doyle will cease all business with Dirigo Capital Group (a company owned by and controlled by Dancoes). At this point Dyer has Doyle waive attorney client privilege without disclosing that the waiver has taken place.

5. Oct. 7, 1996 Diamond sends warning letter that is not received by Doyle. Subsequent review of letter indicates no warning of criminal prosecution by the State.

6. Oct. 7, 1996 Doyle and Dancoes meet with DeTroy and leave his office together to travel to Portsmouth, NH where Dancoes sets up a new corporation and opens a new bank account at Olde Port bank and Trust. This is done under DeTroy's direction. [View Letter]

7. Oct. 10, 1996 memo from Dyer to Doyle saying the Joint Venture (JV) is a scam NOT received yet the memo is subsequently found in a file at DeTroy's by Van Dyke nearly two years after it was allegedly written. The memo is so hostile in content that no one having read the memo would put any of their money or the money of their clients into the JV. [View Memo]

8. Oct. 30, 1996 Doyle DEPOSITS $50,000 into the Joint Venture (JV).

9. Nov. 15, 1996 Dyer letter to Sullivan demanding copy of consumer complaint.

10. Nov. 18, 1996 Dyer letter to Sullivan "the Bureau is on a fishing expedition".

11. Nov. 18, 1996 Dyer memo to Doyle "Peter DeTroy and I have spoken. We are coordinating and agree on the strategy".

12. Nov. 20, 1996 Dyer memo to Doyle gain delay and wrath from the Court. [View Memo]

13. Nov. 20, 1996 DeTroy letter to Bureau of Insurance "I am unaware of, and you have not provided, any information that suggests that your inquiry is related to a 'consumer complaint' or that it relates to Mr. Dancoes' 'affairs under the license'."

14. Nov. 21, 1996 DeTroy letter to Diamond states Dancoes will cease Dirigo activity.

15. Nov. 25, 1996 Dyer files Freedom of Information (FOI) CV-96-1149 lawsuit against State of Maine while the State is investigating Doyle and Dirigo Capital. Dyer clearly indicates to Doyle that the State is wrong and that Doyle can continue to invest his money and the money of his clients. Doyle pays Dyer close to $20,000 in fees in the year leading up to this point.

16. Dec. 3, 1996 Dyer memo to Doyle states that Dyer agrees with DeTroy's five point plan to keep State at bay. DeTroy provides key advice to Doyle at this point. [View Memo]

17. Dec. 3, 1996 DeTroy's letter to Sullivan to stall the Securities Dept. investigation of Dancoes and thwart any interview of Dancoes.

18. Dec. 10, 1996 DeTroy's letter to Dyer stating that Dancoes won't testify.

19. Dec. 10, 1996 Summons filed against Maine and Van Sullivan.

20. Dec. 19, 1996 Answer and Counterclaim filed by Maine

21. Dec. 30, 1996 Motion to Dismiss Counterclaim is filed by Dyer.

22. Jan. 2, 1997 Dyer agrees to Enlarge Time.

23. Jan. 3, 1997 DeTroy letter to Dancoes "if they (clients) are forewarned, they may be less likely to cooperate with the State's effort". [View Letter]

24. Jan. 8, 1997 Maine submits In Camera.

25. Jan. 9, 1997 Dyer memo to Doyle. Dyer seeks DeTroy's advice on how to halt the investigation by the State. Dyer states the investigation "is a bogus misuse of administrative authority". [View Memo]

26. Jan. 13, 1997 Maine submits Conference of Counsel Report.

27. Jan. 17, 1997 DeTroy letter to Dancoes "I am uncomfortable in advising you concerning any further sales of what might be characterized as 'securities'...to have someone advise you in this area, you need to speak to someone with specific expertise". [View Memo]

28. Jan. 21 1997 DeTroy letter to Dancoes "we will vigorously defend against that effort".

29. Jan. 30, 1997 (approx) Doyle DEPOSITS $40,000 to JV. Total of $114,000 at this point. At this time Carol Nale purchases $10,000 of this deposit leaving Doyle at a net of $104,000.

30. Jan. 30, 1997 Dyer files to enlarge time with consent of Frankel for the State.

31. Feb. 3, 1997 Dyer's Objection to Motion by State for Summary Judgment.

32. Feb. 8, 1997 State replies to 2-3-97 filing.

33. Feb. 14, 1997 Dyer's Protection from trial request.

34. Feb. 21, 1997 Dyer's Request for Recusal answered by State.

35. Mar. 19, 1997 Frankel's request for Protection from Trial.

36. Apr. 14, 1997 Hearing before J. Brennan 1:30 pm

37. Apr. 22, 1997 State gets Summary Judgment Order.

38. Apr. 29, 1997 Dyer letter to Dorsey "There does not appear to be any logic in your proposal as described by Mariner".

39. Apr. 30, 1997 Dyer's Motion for Reconsideration.

40. May 5, 1997 State Answer to Dyer on Reconsideration. Total cost for FOI suit $5225.00.

41. May 10, 1997 approx. Thomas Reynolds buys the first Nale deposit of $10,000 paying her directly and assuming control of her contract.

42. May 14, 1997 approx. Garrett calls to say the FBI has seized his assets.

43. May 15, 1997 at 1:30 p.m. Dancoes, Doyle, Dyer, and DeTroy meet at DeTroy's conference room. During this meeting DeTroy provides detailed legal advice to Doyle which Doyle acts upon giving rise to the belief that DeTroy is Doyle's attorney also.

44. May 16, 1997 at 8:30 a.m. Doyle is referred to Richard Berne, a friend of DeTroy's, and Dyer withdraws. Doyle leaves all his files with DeTroy on this date which allows DeTroy the weekend to "clean" the file with the help of Berne.

45. Jun 1997 appox. Doyle sees DeTroy at Foreside Market. Doyle says he hasn't been to the State yet and DeTroy replies with a big smile everything is working out fine and not to worry about it.

46. Jun. 15, 1997 approx. Berne directs Doyle to give interview at State Securities office for four hours. Berne drives Doyle to Augusta and gives Doyle the idea that we have to help the bureau find out what happened to the money when Doyle sent it to Texas. Berne gives no warning that Doyle is being investigated for a crime, nor does Berne object to any question. State gives no Miranda Warning to Doyle.

47. Jul. 1997 approx. While Doyle is interviewed by the U.S. Attorney from Houston and an FBI agent over the speakerphone Berne leaves the room for about twenty minutes and instructs Doyle to continue to answer questions in his absence. The U.S. Attorney asks Doyle if she should wait until Berne returns. Doyle states that Berne considers him another victim and to continue the questions which she does. [View Dyer's Deposition]

48. Jun. 1997 to Jul. 1998 numerous discussions with Berne where Berne states that Dyer will perjure himself to save a malpractice lawsuit. Berne says Doyle will be indicted in Aug. 1998.

49. Jul. 1998 Doyle changes lawyers to David Van Dyke and is indicted.

50. Aug. 24, 1998 at the direction of Van Dyke Doyle files a Fee Arbitration Complaint against Berne. During the time from Jul until the Fee Arbitration Hearing Berne had repeatedly told Van Dyke that Doyle had hounded Berne to be taken to Augusta to be interviewed by the Securities Dept. At the Fee Arbitration Hearing the first thing Berne stated that it was his idea to take Doyle to Augusta and that was his method of conducting his practice.

51. Apr. 7, 1999 State's item "C" Homans meets with DeTroy. DeTroy falsely states that his first meeting with Dancoes was Nov. 14, 1996. Records show that Dancoes went to NH after an Oct. 7th meeting with DeTroy and Doyle. "Peter (DeTroy) told them that it certainly appeared to be a security" This contradicts his Jan. 17, 1997 letter advising Dancoes "it might be characterized as 'securities'. The balance of DeTroy's statement is false on all important points.

52. Apr. 14, 2000 Doyle enters a conditional plea of guilty to the three charges based on the false allegations made by Diamond, Dancoes, DeTroy and Dyer. Van Dyke states that it would be impossible to overcome their testimony as a group.

53. Jun. 2000 Doyle discovers the tape of the second call to Diamond and moves to vacate the conditional guilty plea. [View Call Transcript, VanDyke's Analysis, Doyle's Memo to VanDyke]

54. Aug. 3, 2000 The Forecaster runs the Dr. Long letter to the Editor that prompts Doyle to question Van Dyke about Berne's representation of Doyle and his potential collaboration with DeTroy's false statements against Doyle. Van Dyke states that a client of Berne/DeTroy named Steve Dunwoody has taken them to the Ethics Committee of the State Bar Assoc. and that Van Dyke has a client, Scott Liberty, also accusing them of "double dealing him" and Doyle would be the third all with very similar complaints against Berne and DeTroy. [View Letter]

55. Sep. 19, 2000 Van Dyke requests a copy of the Diamond warning letter dated Oct. 7. 1996, nearly four years after it was allegedly sent.

56. Oct. 4, 2000 sentencing hearing set. Postpone due to pending motion to vacate.

57. Nov. 9, 2000 at 2:00pm at Ellsworth, Maine Motion to vacate conditional guilty plea is granted.

58. Dec. 11, 2000 Doyle's trial is set to begin. AAG Amy Homans states THAT SHE DID NOT RECEIVE THE LETTER FROM THE COURT NOTIFING HER OF THE TRIAL DATE. Trial is reset for Feb. 12, 2000.

59. Jan. 26, 2001 Dyer gives Deposition and perjures himself as Berne stated he would in Jun. 1997. Dyer testifies on page 31 lines 22 to 25, regarding a conversation with Doyle in early Jan. 1997, "I told him I was very angry at what he had done. I thought that it was inappropriate given this letter to Mr. Diamond and that as far as I was concerned that I was out of this. I WASN'T GOING TO TAKE ANY MORE DEALINGS WITH HIM ABOUT THIS." This contradicts all the work done by Dyer and DeTroy to keep Doyle from the truth in items 6 and 9 to 28 and 30 to 40 above. A total of 32 court actions and memos after Dyer purports to have washed his hand of the entire program spread over a period of over five months. [View Dyer's Deposition]

60. Feb. 12, 2001 Trial set to begin and Van Dyke spends four hours convincing Doyle to plead guilty once again, which Doyle does, based on the perjured statements of DeTroy, Diamond, Dancoes, and Dyer. AAG Homans deliberately misstates that the tape-recorded phone call of Diamond clearly showed that Doyle was warned by Diamond. The tape actually was just the opposite and showed no warning at all.

61. Apr. 24, 2001 Sentencing hearing set and is postponed until Jul. 24, 2001 and restitution of $46,675 is ordered.

62. May 2, 2001 Doyle at his expense submits to a polygraph on the narrow question of whether or not Doyle was warned by Diamond. The results were inconclusive on the truthful side with a score of +2. Which indicated that Doyle was not warned by Diamond in the first phone call.

63. May 23, 2001 Doyle goes to Van Dyke's Lewiston office and reviews his file from 3:00 to 4:30pm where he finds the memos from Dyer and the letter from DeTroy ( items 11, 16, and 25 above). Which contradicts all statements made by Dyer and DeTroy against Doyle. These statements that led Doyle to plead guilty twice to a felony which was committed at the direction of Dyer and DeTroy. Doyle insists Van Dyke read the memos and Van Dyke states "that they are troublesome".

64. Jul. 5, 2001 Thomas Hallett takes over the case and files a Motion to Vacate the second guilty plea. [View Hallett Affidavit, View Doyle Affidavit]

65. Nov. 5, 2001 At the courthouse on the day of the hearing to vacate the second guilty plea Doyle refuses to sign a release for Van Dyke, protecting him from a malpractice suit by Doyle, in exchange for Van Dyke's truthful testimony. Hallett, prior to the hearing comes back into the conference room and states "we are in a very tenuous position here, we need Van Dyke's testimony very badly". Van Dyke extorts Doyle into signing the release not on the courthouse steps, but inside the courthouse just minutes before the Motion to Vacate hearing begins. [View VanDyke Affidavit, View Doyle Release]

66. Nov. 5, 2001 VanDyke signs affidavit stating: 1. I did not meet with Mr. Doyle... 2. I did not prepare written in limine motions.. 3. I did not prepare a written witness list. 4. I did not prepare a written defense exhibit list... 5. I did not meet with any defense witnesses... 6. I did not prepare a trial notebook.

67. Nov. 20, 2001 Justice Nancy Mills instead of recusing herself as she did in a prior trial with Doyle she conducts the hearing and rules against Doyle. J. Mills incorrectly cites in her order that the State prepared twice for trial. J. Mills goes on to cite that the inconvenience of the State witnesses to come to Maine to testify. Doyle stipulated to the main portion of what they would testify to at trial in his Motion to Vacate. J. Mills then cites the time lag from the guilty plea on Feb. 12th to Nov. 20th as a reason to deny the Motion. AAG Homans caused the time lag when the Court granted her Protection from Court activities from Jul 5th to Nov. 5th. [View Hallett Letter] The primary witnesses that would be called by the State at trial are lawyers in Portland that are in and out of the courthouse at least weekly. The witnesses are Diamond, DeTroy, Dyer, and Dancoes, all of which have major problems with conflicts in their statements. All of this indicates that J. Mills either did not read the file or did not understand what she read. J.Mills subsequently ignores "the law of the case" and accepts a pleas bargain in oppostion to the order of J. Pierson.

68. Nov. 20, 2001 AAG Homans knowingly extorted a guilty plea from an innocent defendant by using what she knew to be perjured proffers, depositions, and testimony from Dancoes and DeTroy when she had dated and verified material in opposition to their statements.

69. Jan. 31, 2002 Hallett begins work on second Motion to Vacate second guilty plea based on the misconduct of AAG Homans

70. March 24, 2002 Doyle is sentenced to 30 months in prison with all but 14 months suspended.

71. June 14, 2002 Appeal is filed with Law Court. [View Oral Arguments Summary, View Sentencing]

The people involved:

• Steve Diamond, Esq. the Securities Dept. contact now head of the P.U.C.
• Ralph Dyer, Esq. Doyle's business lawyer for over ten years.
• Peter DeTroy, Esq. Partner in the firm of Norman, Hanson and DeTroy which received $3,000,000 from the State Tobacco settlement.
• Denis Dancoes former associate of Doyle's who's perjury increased as his fine and sentence decreased.
• Richard Berne, Esq. A friend of DeTroy's and Doyle's first defense lawyer.
• Amy Homans, Esq. Assist. Attorney General for the State of Maine.
• David Van Dyke, Esq. A friend of DeTroy's and DeTroy's brother Ben and Doyle's second defense lawyer
• Thomas Hallett, Esq. Doyle's third defense lawyer