Prima Facie Evidence of Professional Misconduct

In re Harry L. Roen, Esquire · Fla. Bar No. 164797

SEEREERAM v. SAITH · CASE NO. 2023-DR-004193-O · NINTH JUDICIAL CIRCUIT, ORANGE COUNTY, FLORIDA · COMPILED BY DEVO SEEREERAM, Ph.D., P.E. (PRO SE)
The Same Record, in Three Chapters
Three separate proceedings, bound by one throughline — the suppression of a self-represented litigant. Read the connected chapters:
⚖️ How the System Really Works — Must See
The 5 Rings That Protect Judges and Trap Honest People
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Executive SummaryWhat this record is, and what you will find in it

This is not a divorce grievance, and it does not ask anyone to relitigate a divorce. It is a documentary record of how one attorney — Harry L. Roen, Esquire — turned the machinery of a single case into an integrated shield: attorney-client privilege, protective-order practice, proposed orders, fee litigation, and witness preparation, used to keep conduct that meets the threshold for the crime-fraud exception from being examined at all. Every point is drawn from the filed court file in Seereeram v. Saith and the related criminal, civil, trust, and federal proceedings, and organized so a reader can verify it against the underlying document. Where the compilation draws a conclusion from those documented facts, it is stated as the compiler’s view of the disclosed record.

▸The Unfolding — Five Years in Thirty Minutes
October 2021 – July 2026 · the cast of the case, rebuilt for every date · dissolve time-lapse
The whole case, in thirty minutes — before you read a word of the record. The same five-tier chart — joined by escalation cards for the appeals, Bar, JQC and federal fights — rebuilt for every date across the full timeline, from the October 2021 arrest to the June 2026 jail motion, nearly five years. One column never changes — Hal Roen, who from January 2024 occupies two tiers at once (counsel for the Wife and her de-facto guardian). The other column churns: the Husband cycles through three attorneys and then represents himself (White → Manes → Otero → pro se). And the bench never stops turning — four judges on the divorce alone (McCarthy → Tennis → Deen → Jackson), stacked on top of the criminal, civil, 6th DCA, Florida Supreme Court and federal courts he is forced to chase. The late entries surface on one side only — the crime-fraud-tier counsel, the revolving experts, and the witness who resolves to “Ana Hirsch — name was not legal.” One side accretes; the other dissolves.
▾ Download the full chart sequence (PDF) — all 71 charts, each with its own chart page plus a separate narration page (142 pages total), if you’d rather read the record than watch.
The subject is not a novice. Mr. Roen was admitted to The Florida Bar in October 1973 — more than fifty years of practice — and he teaches Family Law in the legal-studies program at Seminole State College. The conduct documented here was undertaken by a practitioner who knows the Rules Regulating The Florida Bar as well as anyone in the State, and who instructs others in this very field of law. Nothing here can be explained by inexperience.
The hearing at the center of it — May 8, 2025. The crime-fraud question was noticed, briefed, and ready for an evidentiary hearing — both sides filed bench memoranda and witness lists. In twenty-one minutes, the Court granted opposing counsel’s protective orders and declared the attorney-client privilege “sacred.” When the Petitioner asked to be heard, the Court answered: “I’ve already ruled. There is nothing more to say.” The Court did not reject the crime-fraud showing after reviewing it — it foreclosed the showing before reviewing it. That foreclosure is why this record is public.
41
Predicates
10
Thematic Clusters
20
Bar Rules Implicated
1973
Year Admitted

How each predicate is built

The compilation is not argument — it is structure. Each of the 41 predicates is assembled the same way: the documented facts, with citations to the filed record; a mapping to the specific Rule(s) Regulating The Florida Bar implicated; and, where applicable, a crime-fraud-exception analysis under United States v. Zolin and Fla. Stat. § 90.502(4)(a). Each predicate is independently sufficient to support relief in its forum. The reader is invited to test each one against the cited document.

What you will find — the ten clusters

Live Privilege Invocation & Crime-Fraud Ripening
Predicates 40 · 41 · 17 · 36
The June 3, 2026 blanket privilege invocation over non-privileged source-of-funds questions — why the crime-fraud issue is live today.
Fee-Motion Fraud & the Coercive Settlement Demand
Predicates 9 · 10 · 20 · 15 · 32
A sworn fee affidavit sourced from concealed liquidation, validated by a conflicted "independent" expert; a $3M demand letter with § 836.05 exposure on its face.
Mental-Health Plea Substitution & Witness-Reversal
Predicates 1 · 35 · 5
A documentary plea-term substitution and a coverage-counsel reversal, sheltered by counsel; self-contradiction across two depositions.
Witness Coaching, Intimidation & Evasion
Predicates 18 · 25 · 16 · 28 · 3 · 39
The most reader-legible conduct: witness coaching, a false "wiretapping" accusation counsel knew was baseless, and a UPL-pretext threat.
Financial Disclosure, Source-of-Funds & Asset Concealment
Predicates 12 · 33 · 2 · 4 · 7 · 13 · 6
Counsel-supervised fraudulent financial affidavits, asset-location obstruction, the children's-529 depletion, and the tax-nonfiling admission.
Manufactured / Backdated Loan Documents
Predicates 11 · 37
Backdated loan instruments connected to the litigation; the $50,000 transfer to a dissolved entity with backdated agreements.
Vulnerable-Client Exploitation & Representation Inception
Predicates 26 · 22 · 23 · 38
A coercive retainer at the origin of the representation; direct, continuing notice of client impairment; the "twice-paid divorce" comparator.
Trust, Property & Jurisdictional Foreclosure
Predicates 34 · 31 · 14 · 30
Two false equity-interest allegations and an $11M instanter demand; a Verified Motion filed without the Trust instrument; Article-I suppression.
Litigation-Process Coercion & Procedural Posture
Predicates 29 · 19 · 27 · 21 · 24 · 10
A sustained contempt-and-incarceration campaign against a compliant pro se litigant; fabricated citations; posture misrepresentations.
Notice-and-Continuing-Knowledge Layer
Predicate 8 (with 22–23)
A 47-letter crime-fraud-exception notice campaign met with counsel's continuing silence — the knowledge element under every cluster above.
The Candor Capstone
June 3, 2026 representation
Counsel represented in writing that the Court barred discovery directed to him on privilege grounds. No order, by any judge, on any date, did so.
He knew all along — in his own public words. In March 2026, the same Mr. Roen — appearing as counsel for the ex-husband of the Orlando woman charged with firing on Rihanna’s Los Angeles home — volunteered to TMZ that the opposing party had been “Baker Acted” (involuntarily committed to a psychiatric facility) and tied it to her loss of child custody, treating a Florida mental-health record as relevant and newsworthy. Yet sixteen months earlier, handed his own client’s signed, open-court, court-ordered mental-health condition, he insisted nothing short of a “court RULING or ORDER or JUDGMENT” could count. A “Baker Act” is an involuntary commitment — less formal than a court-ordered plea condition. By his own public statement, he knows exactly what such a record means.
Living document. The Prima Facie is revised almost every day as the record develops; the current version and date appear on its cover page. Any subject reviewing it should always check the cover for the latest version.

Where to go from here

▸ Tab 02 — Roen in His Own Words collects the most damaging admissions, quoted verbatim from his own emails.
▸ The full report — all 41 predicates with their record citations and Bar-rule mappings — is in Tab 03 (Full Prima Facie), where each point can be verified against the document it cites.

Designated channel; opportunity to correct. Any correction or correspondence should be directed to Mr. Dennis Miller at dennis@devoeng.com. A subject who believes any item is inaccurate is invited to submit a written correction, which will be reviewed against the record and, where warranted, the item revised or removed. Nothing here is offered for settlement purposes.

The Admissions, VerbatimRoen in his own words

The most damaging evidence here is not the compiler’s characterization — it is Mr. Roen’s own words: on the certified record, and in his own filings and emails. Each card sets what he said in one forum against what he said in another. Every quotation is verbatim and is reproduced in full, with its citation, in the Prima Facie (Tab 03).

Every quote below is his. We just put them next to each other.

Nineteen documented contradictions — what he said in one forum, set against what he said or did in another. Tap any line to jump to it.

01
June 27, 2024 · one deposition
“Am I a thief?” — then “the Judge would eat him for lunch”
On the record — paid from a disabled child’s 529

“So essentially you’re saying I’m a thief?” — “Yes.”

“…paying me my retainer with stolen property?” — “Yes… an attorney cannot accept commingled money that he knows is stolen.”

Hal Roen / Dr. Seereeram, June 27, 2024 Tr. 19:5–12

Minutes later — and admitted in writing

“the Judge would ‘eat him for lunch’… It is an alert and not a threat.”

Hal Roen, Filing #203916204 (Aug. 2, 2024)

Told his fee came from a disabled child’s college fund, counsel didn’t answer the charge — he named the judge as the threat. He invoked Judge Tennis by name, suspended the deposition, and later admitted the remark in his own filing, calling it a “Baby on Board” alert. It led to JQC charges against Judge Tennis, now before the Florida Supreme Court (SC2025-1438). (The moment that triggered the suspension — his first reading of Devo’s April settlement offer — is in the deposition excerpts below.)
02
The same witness · the same month
“I’m not her lawyer” — then her lawyer, seven days later
Under oath — April 9, 2025 deposition

“Are you representing Ms. Hofer?” — “No, sir. I’m representing Ms. Saith.”

Witness: “I only met Hal not that long ago…” — a call lasting “two minutes, three minutes.”

Hofer Dep., Apr. 9, 2025 Tr. 15, 21, 30

His own record — the NOA and the bill

Notice of Appearance for Ms. Hofer, filed April 16, 2025 — seven days later.

Sworn timesheet: “April 24, 2024: Office conference with client and witness, Annie Hofer” — 1.0 hour.

Hal Roen, Filing #221139653; fee-order timesheet

He swore he wasn’t her lawyer and had barely met her — then entered as her counsel a week later, while his own billing showed an in-person office conference a year earlier. Even on the record he conceded, “I just gratuitously gave her some free legal advice.” Defending the timesheet, he placed the 2024 meeting “more than 2 weeks subsequent to” the 2025 deposition — and never corrected the year. (Second Supplemental Notice of Lack of Candor, Filing #240833117, Feb. 3, 2026.)
03
The same lawyer · whose counsel is he?
His personal attorney for one hearing — carried as the wife’s “lead,” billed to the Husband
What he filed — May 5, 2025

Mark Rabinowitz appears “for the limited purpose of representing Hal Roen, Esquire, at the May 8, 2025 hearing.”

Notice of Limited Appearance, Filing #222397381

What Roen puts on his own fee order

In the proposed order Roen drafted, he lists “Mark Phillip Rabinowitz, Esquire, Lead” as the wife’s counsel — while the same motion’s body concedes Rabinowitz was retained “to represent him [Roen].”

Then he bills the Husband $2,500 for him.

Roen’s proposed fee order, Sept 4–5, 2025; carried onto every Judge Jackson order

In the fee order he drafted himself, Roen designates his own personal lawyer as the wife’s “Lead” counsel — then asks the Husband to pay for him. Rabinowitz’s only appearance was a limited one to represent Roen personally, and Roen’s own motion concedes he was retained “to represent him” — yet Roen carries him as the wife’s “Lead” on the proposed order and across Judge Jackson’s docket, folding his $2,500 into the $10,000 he seeks from the Husband. All quotations of record; full citations in the source file and the Prima Facie.
04
The same week · served Monday, “trial time” by Friday
Served sworn questions about himself — and 72 hours later, “discovery’s over”
Served on him, personally — March 4, 2025

27 pages of sworn interrogatories to “Respondent’s Attorney, Hal Roen,” answerable “under oath within thirty days,” including:

“Did you receive any portion of your legal fees from the withdrawn 529 funds?” · whether he billed “more than $50,000” against §825.103 (taking >$50k from an impaired senior = first-degree felony) · “Did you report any gold or non-cash payments as income on your tax filings?”

Interrogatories to Attorney Hal Roen, Filing #218038690

His answer — inside 72 hours

Mar 6 — moves to quash them (Protective Order #218230978). Mar 7 — serves a Notice for Trial certifying the cause “at issue,” discovery done. Mar 21 — withdraws it (#219349456); denied moot July 11, 2025.

Husband’s same-day objection, Filing #218323657

Block the discovery, and certify there’s nothing left to discover — two doors out of the same room, opened the same week. Served with sworn questions aimed not at his client but at him — a felony fee, a fee from a disabled child’s stolen 529, his own taxes — he had thirty days to answer. Within seventy-two hours he had moved to quash them and certified the case ready for trial. The Husband’s objection: it is “contradictory and improper to request a trial scheduling while simultaneously seeking to limit discovery access.” All of record; full citations in the Prima Facie, §III ¶12c.1.
05
The same shield · eighteen months later
Asked where the money came from — “I’m exercising the right to not respond”
The question — June 2, 2026

A yes/no: did any of the ~$647,900 cash in the Oct–Nov 2025 Wisconsin real-estate round-trip (his dual-represented witness-client, co-grantor Thomas Mueller) originate from Mrs. Saith?

Source-of-Funds Confirmation Demand to Hal Roen, June 2, 2026

His answer — June 3, 2026, 7:38 AM

“please treat this as my exercising the right to not respond based on the attorney/client privilege. Also do not attempt the non-responses as an acquiescence to your questions, there is no acquiescence.”

Hal Roen email, June 3, 2026 (Prima Facie, Predicate 40)

You cannot assert privilege over a communication that does not exist — so the invocation is his own written confirmation that source-of-funds communications with his clients exist. A one-word “no” would have ended it for free; he chose privilege instead — which only exists if the communications do. It is the same shield he built in March 2025 to dodge the crime-fraud interrogatories (card 04) — one continuous refusal, eighteen months apart. All of record; full chain in the Prima Facie.
06
The same exchange · April 10, 2025
“You just… vanished into privilege” — “I am doing as the canons of ethics dictate”
The summary put to him — 1:41 PM

Told the Wife was committing marital funds to a dissolved-entity scheme (Prosperity for Life), and that counsel would neither stop her nor object:

“You didn’t protect her. You didn’t stop her. You didn’t approve. You just… vanished into privilege.”

Dennis C. Miller to Hal Roen, Apr. 10, 2025

His answer — 2:02 PM, same day

“it is a mischaracterization that I did not protect her, that I did not stop her, that I just vanished into the privilege. I am doing as the canons of ethics dictate — to zealously represent my client.”

“I am a professional… and am entitled to be treated accordingly.”

Hal Roen to Dennis C. Miller, Apr. 10, 2025

Confronted that he stood aside while his client committed marital money to a dissolved-entity scheme, he didn’t deny it — he called it “zealous representation” and demanded respect. The Florida Supreme Court holds the opposite: “zealous advocacy… is not an excuse for any type of misconduct.” (Prosperity for Life: Predicate 11/37; both emails of record.)
07
Deep insecurity · hidden in “standard” interrogatories
“Name every lawyer who’s spoken about me” — and everyone you might tell next
On the docket — 4:07 PM

At 4:07 PM he filed a clean “Notice of Service of Standard Interrogatories” with the court — with no interrogatories attached. One minute later, at 4:08 PM, he emailed the Husband the actual set — still labeled “standard” — carrying a custom Section 8(b) that never reached the court’s docket, set off by one line in a letter: that “not a single respected attorney has stepped forward to support your handling of this case.”

Notice of Service of “Standard Interrogatories,” Filing #219485370 (Mar. 24, 2025)

All seven questions — sworn, verbatim

i.  “Who are the colleagues you refer to?… be specific… by name.”
ii.  “On how many occasions have you had communications… to discuss this case?”
iii.  “Have the colleagues or attorneys you refer been contacted by you or someone on your behalf?”
iv.  “Of the colleagues you refer to, how was contact made with them?”
v.  “What… caused you to contact any particular lawyer?”
vi.  “what is it that you say to them about Hal Roen?”
vii.  “Do you have other colleagues or lawyers in mind to contact in the future? If yes, please list them.”

Roen’s interrogatories, Section 8(b)(i)–(vii)

A lawyer of nearly fifty years used sworn discovery — mislabeled as “standard” — to demand that a pro se opponent name every attorney who had spoken about him, count the conversations, trace how each was reached, and report what was said. The clean “standard” notice went on the court’s record; the custom, retaliatory questions went out a minute later by private email and never did. It is not a discovery request — it is a tell. Caught and placed on the record in the Petitioner’s Judicial Notice, Filing #219511913 (Mar. 25, 2025).
The document at the center. The signed, open-court plea form (August 15, 2022) imposed “Mental Health Eval & Treatment” — the twelve-month condition the State Attorney demanded. The typed Order of Probation sent to enforce it silently dropped that term and substituted “drug and alcohol evaluation,” so the treatment was never performed. Mr. Roen was retained eight days after the plea and built four years of litigation on the version that omitted the condition. The plea’s own drafting attorney, Jason Bankowitz, confirmed it under oath (May 1, 2025): reading the October 12, 2022 letter into the record, the condition “was on the signed plea… [but] did not make it into the court order”; he first testified the open-court oral plea “would be controlling,” then reversed to claim the typed order “overrides” it. (Watch it in Tab 04.)
08
The same “evaluation” · sixteen months apart
“A recent evaluation proves she’s fine” — then the letter the State had thrown out
Letter to Dr. Seereeram — February 11, 2025

“She has been evaluated by a professional… and found her to not suffer or have the mental issues you complain of. So please stop doing that.”

A year earlier he had filed that the “same mental evaluation will be provided to the Court”; pressed to produce it, he wrote “get the court to order… you can’t always get what you want.”

Hal Roen, letter Feb. 11, 2025; Mot. to Enjoin ¶4 (Mar. 4, 2024); corr. Apr. 28, 2025

Compelled to produce — July 21, 2025

He handed over two pre-charge defense letters: “Ms. Saith has not yet been formally charged… I did not have a copy of the arrest affidavit… not there… for treatment.”

Dr. Danziger to defense counsel, Feb. 13 & Aug. 5, 2022; produced at Filing #227717870

The court ordered her into twelve months of mental-health treatment. He told the family court a “recent evaluation” proved she needed none — and, when finally compelled, produced a pre-charge letter from a doctor who didn’t have the arrest report, to prove it. Those letters’ “no treatment” opinion was the very one the State rejected when it imposed the plea condition ten days later. (Full chain in the Prima Facie, Predicate 5.)
< 5 hours
of one-on-one contact, total
The contact behind the diagnosis. Mr. Roen pronounced his client mentally sound — and told the husband who had been her partner since their 1977 courtship, some 48 years, to “stop” saying otherwise. Yet from his first contact with her (Aug 23, 2022, eight days after her probation began) to the last call in the record (Nov 8, 2023), his actual one-on-one contact with his client totaled at most ~285 minutes — under five hours — across 31 brief phone calls (texts and one-minute disconnects excluded) and two office meetings. Mediation, depositions, and hearings are not counted; those are adversarial proceedings with others present, not private client time.
Charmaine Saith’s carrier phone records (321-230-6777) and Mr. Roen’s own sworn timesheet, Filing #230534891.
09
The same attorney · three weeks apart
“The best evidence is the record of the proceedings in the courtroom” — then “the typed plea overrides it”
Hofer deposition — April 9, 2025

Asked what was actually said in open court, Mr. Roen invokes the best-evidence rule for the courtroom record:

“I object. The best evidence is the record of the proceedings in the courtroom, Doctor.”

Hofer Dep., Apr. 9, 2025 Tr. 73

Bankowitz deposition — May 1, 2025

His own witness swears the typed order (Exhibit 3) overrides the open-court plea (Exhibit 2) — and Roen shelters it:

Bankowitz: “Exhibit 3 overrides Exhibit 2… Absolutely.” — Roen: “You don’t have to say anything else, Mr. Bankowitz.”

Bankowitz Dep., May 1, 2025 Tr. 63

The open-court plea (Exhibit 2) — stamped “filed in open court” — is the one carrying “Mental Health Eval & Treatment.” Mr. Roen called the courtroom record the “best evidence” when it suited a witness’s memory — then, three weeks later, let his own witness swear the typed order that dropped that condition “overrides” it, and cut the witness off rather than correct him. Both depositions are in Tab 04; full citations in the Prima Facie.
10
The same evaluation · sworn in March, unread until July
He swore in March 2024 that an evaluation found her fine — his own bill shows he hadn’t read one until July
Sworn to the court — March 4, 2024

“…causing Wife to be forced to submit to a mental evaluation… Same mental evaluation will be provided to the Court upon a proper proceeding. However, it must be assumed that Wife would not pursue such a strategy if the results of said mental evaluation were less than satisfactory.”

Wife’s Verified Motion to Enjoin, ¶4 · Filing #193220536

His own fee-affidavit timesheet

The first “Review psych analysis” entry anywhere in his billing is dated July 30, 2024. As of the March 4, 2024 sworn motion, he had reviewed no evaluation at all.

Roen fee-affidavit timesheet · Filing #230534891

He swore, under oath, that a recent evaluation already existed and vouched for its favorable results — about a report his own billing record says he wouldn’t read for four more months. When finally compelled to produce it (July 2025), he handed over only the two 2022 Danziger criminal-plea letters — the very “she’s fine” opinion the State had already rejected when it ordered her into twelve months of treatment. Verified against his own timesheet; full chain in the Prima Facie, Predicate 5.
11
The same attorney · mental health, both ways
“Only a court ruling counts” — then volunteering it to TMZ
To Dr. Seereeram — November 18, 2024

Handed his own client’s signed, court-ordered mental-health condition, he says it counts for nothing:

“what i am asking you for is for a court RULING or ORDER or JUDGMENT…”

Hal Roen, email, in Seereeram v. Saith

To a national outlet — March 2026

For a different client, he volunteers the opposing party’s mental health unprompted:

She “was previously ‘Baker Acted’… placed in a psychiatric facility against her will.”

Hal Roen to TMZ, re: the Rihanna-home shooting

A “Baker Act” is an involuntary commitment — less formal than the court-ordered plea condition he called meaningless. When the record was his client’s, nothing short of a judgment could count; when it was the other side’s, he offered it to a tabloid. A court order about his own client: meaningless. A stranger’s psych history for a tabloid: free of charge. (TMZ, Mar. 9–10, 2026; counsel’s correspondence of record.)
12
The same gold account · eight months apart
$1.41M “all marital” — then, $692K lighter, “go subpoena it yourself”
Under oath — June 27, 2024

“This is where all my money is held… 1,411,644.82… All of it is marital.”

Charmaine Saith, June 27, 2024 Tr. 47:8 / 48:11–14

Discovery response — March 17, 2025 · ~$692,388.65 gone

“he is certainly able to Subpoena those records… at his own expense.”

“No such ‘explanation’ document exists.”

Hal Roen, Filing #218955835 ¶15 & ¶7 (Mar. 17, 2025)

Half the marital gold vanished — and “no such explanation document exists.” She swore the account held $1,411,644.82, all marital; $692,388.65 was liquidated during the Standing Order; asked where it went, counsel told the Husband to go subpoena it himself, “at his own expense.”
13
The same deposition · where the millions are held
The witness was ready to tell — counsel stopped her
April 1, 2024 — asked where her money is

The witness turns to her lawyer: “Can I tell him this?”

Charmaine Saith, Apr. 1, 2024 deposition

Counsel intervenes

Roen: “Can I have a few minutes with my client?” — then, after the recess: “the last deposition ended with an objection as to the location of her moneys.”

Hal Roen, same deposition

Even the witness was prepared to disclose where her assets were — until counsel called a recess and intervened. He confirmed on the record that a prior deposition had “ended with an objection as to the location of her moneys.” The Husband’s motion to disqualify charges him with “directly advising the respondent to withhold the location of her assets.” (Filing #204001707, Aug. 5, 2024.)
14
The same attorney · eight weeks apart
“No sanctions” for missing court — then a motion to jail him for it
Open court — December 9, 2025

“I’m not seeking sanctions for his failure to appear… him not being here causes the hearings… to go much quicker.”

Hal Roen, Dec. 9, 2025 Tr. 9:16–19

Filed motion — February 4, 2026

“Husband cannot avoid the authority of the Court by just opting out of attending… incarcerated in the county jail.”

“I’m going there, Judge. Don’t be surprised when you see that.”

Writ of Bodily Attachment, Filing #240962066 ¶6 (Feb. 4, 2026); Feb. 9, 2026 Tr. 21:14

Same absence. Opposite demand. It was “no sanctions” when it sped his hearings along — and the county jail once the judge offered him a notice-cure path. The entire time, that absence was covered by a standing, acknowledged waiver of appearance (July 9, 2025) his own motion concedes (¶3).
15
One signed letter · May 4, 2026
“$3 million… agree not to reveal matters within the family — and don’t tell the courts”
The demand

Over his own signature, on a letter captioned “Personal and Confidential,” Mr. Roen demands the Husband agree the Wife “receive $3 million,” by a noon May 8, 2026 deadline.

Hal Roen letter, May 4, 2026

The price, and the gag — verbatim

“Charmaine will forego the award of attorney fees that is pending before the Judge, as well as she will agree to not discuss or reveal matters that have occurred within the family…”

…the offer “is confidential and privileged and cannot be shared with anyone, including the courts.”

Hal Roen letter, May 4, 2026 (Prima Facie, Predicate 32)

Pay $3 million, drop the pending fee fight, stay silent about “matters within the family” — and hide the offer from the court. A signed writing conjoining a multimillion-dollar demand, a silence condition, and an instruction to conceal it from “the courts” carries Fla. Stat. §836.05 (extortion) threat-structure on its face. Fifty-six minutes after the deadline lapsed, his office asked chambers to set the fee “Entry of Orders” hearing. Malice/intent is a fact question reserved to the tribunal; the text is quoted of record.
16
The same attorney · two years apart
“Depositions are concluded” — until he wanted one
2024 — Roen shuts depositions down

Wife “already deposed twice… no meaningful reason” — court: depositions are “not meant to ‘fix’ factual errors from prior depositions.”

Roen’s objection & Order DENYING add’l depos (Jul. 25, 2024); 6th DCA affirmed (6D2024-1575)

2026 — Roen wants them back, for himself

“…require Husband to attend and to respond to questions at a deposition.”

Hal Roen, Filing #249231704 (May 29, 2026), set for hearing

“The discovery mechanism he personally killed in July 2024 should now be exhumed for his exclusive benefit.” Roen won an order denying more depositions and the 6th DCA affirmed it — then, two years later, with none taken by either side since, moved to reopen the very mechanism he shut down. — Petitioner’s record-preservation notice, May 11, 2026.
17
The same attorney · just over a year apart
The 529 was the kids’ money — until it was his retainer
Settlement correspondence — June 7, 2023

As opposing counsel, he affirms the 529 fund is the children’s — to be used for them:

“the purpose of the children’s money being taken from the 529 plan and put into an IRA — especially if the parties are agreeing that it is the children’s and will be used for child purposes…”

Hal Roen, quoted verbatim by the husband’s then-counsel, June 7, 2023

Deposition under oath — June 27, 2024

Once that fund is shown to be the source of his own retainer, he disputes the children own it:

“what authority has determined that the 529 moneys were not available to be used by Ms. Saith?”

Hal Roen, Dir. Exam. of Dr. Seereeram, Tr. 19:13–15

He called the 529 the children’s money when it cost him nothing — and disputed it once his own fee was paid from it. In the same exam he framed the stakes himself: “I have accepted representation of your wife in her paying me my retainer” (Tr. 19:7–9).
18
The same client · two lawyers, two choices
One lawyer saw her condition and walked — the other filed in eight days
The first lawyer — walked away

Her first divorce counsel quietly withdrew, declining to file the case after evaluating her condition.

Inference of the Florida Bar Complaint, RFA 24-9414

The second lawyer — eight days into probation

Mr. Roen was retained eight days after the Wife began felony probation and filed immediately — without disclosing her felony conviction, her active probation, or the court-ordered mental-health treatment condition, and never contacting her probation officer.

Florida Bar Complaint, RFA 24-9414 (May 7, 2025)

“If she was mentally impaired… who first saw it? And what did they do?” The answer is in the record: “The first lawyer saw it — and walked away. The second lawyer saw the money — and filed anyway.” (Florida Bar Complaint, RFA 24-9414; the first counsel’s reason for withdrawing is the Complaint’s inference, not a quoted statement.)
19
March 6, 2025 · Filing #218230978
Asked what the crime-fraud exception is — he described the wrong rule
In his sworn Motion for Protective Order

“…the lawyer is able to disclose those confidential communications without the client’s consent if the lawyer believes that a future crime is to be committed or if the client is about to kill or cause great bodily harm to someone.”

Hal Roen, Wife’s Motion for Protective Order · Filing #218230978 (Mar. 6, 2025) ¶8

What the crime-fraud exception actually is

An evidentiary rule that strips privilege from communications made in furtherance of a crime or fraud — past or ongoing — whether or not the lawyer knew.

United States v. Zolin; Clark v. United States; § 90.502(4)(a), Fla. Stat.

Asked to answer the crime-fraud exception, the wife’s own attorney described the future-crime disclosure rule (Fla. Bar Rule 4-1.6) instead — a different doctrine entirely — weeks before the May 8 hearing on his own conduct. It is not an isolated slip: an estimated 85–99% of Florida attorneys have little or no working exposure to the crime-fraud exception. Here, the one whose conduct put it in issue answered by describing the wrong rule. (Prima Facie, Predicate 17; consensus estimate, median of 23 AI models — illustrative, not a measurement.)

Also — verbatim, in his own emails

“I…committed some ethical transgression by not filing a notice of related cases identifying my client’s misdemeanor criminal charge. I do not share that sentiment… apologize? - i won’t. Withdraw…? I won’t. File an amended ‘notice of related cases? I won’t.”
Hal Roen · email · February 21, 2025
He filed the divorce without disclosing his client’s criminal probation and its court-ordered mental-health condition. Confronted, he acknowledged the omission as an allegation — and refused, three times, to cure it.
“the purpose of this letter is to have you cease your continued railings and defamatory attacks… seeking relief from the court restricting your communications with me.”
Hal Roen · email · February 21, 2025
A pro se litigant’s documented, certified-mail candor letters were recast as “defamatory attacks,” met with a threat to obtain a court order silencing them — and, days later, a threat to have the court award attorney’s fees against him for writing them.
“according to your logic if a doctor requests blood work on a patient to determine if they have cancer or diabetes, the merely seeking to have that test done is enough proof that in fact the patient has the affliction.”
Hal Roen · email · November 18, 2024
Counsel did not address the open-court plea form as a court record. He recast a court-ordered condition as a mere request — and changed the subject.
“she has not been served and he knows she is in Singapore - i don’t want to have to go to a deposition knowing the day before that it will not take place.”
Hal Roen · email · April 8, 2025 · re: Sabrina Saith deposition
The only blood-relative eyewitness to the August 15, 2022 plea meeting fled to Singapore. Opposing counsel confirmed it in his own writing — four days after opposing the motion that would have secured her remote testimony.
“you have defamed and slandered me but all have been done while protected under the veil of a court filing. Should you expand your attack and continued slandering me, you will expose yourself to taking on liability… I will take full advantage of those rights available to me.”
Hal Roen · email · June 1, 2026 · on learning of a public-record website
Told a pro se litigant intended to publish a documentary website about him, counsel’s answer was a written threat to sue — to move the criticism out from “the veil of a court filing” so he could “seek redress… in the courts.” A threat of litigation to suppress protected speech.
“suggesting that a person do certain things and their failure not to do them will result in some conduct… could be considered or deemed extortion. I am not sure since he is pro se, that he is aware of that legal concept.”
Hal Roen · email · January 16, 2026
He labeled the opponent’s demand letter possible “extortion” — the same day he filed his retaliatory contempt motion — adding, “i will do none of the suggested things he demands of me.”
“this is the first time i have ever actually filed myself through the efile system. I realized that i did not include Dr. Seereeram in the certificate of service… i will do better next time.”
Hal Roen · email · July 14, 2025
A lawyer of nearly fifty years, the wife’s counsel for a year, conceding in writing that he had never used the court’s e-filing system — and had botched service in the process.
“He continuing to do so will cause me to see to have the court award attorney fees to be paid by Dr. Seereeram to me.”
Hal Roen · email · February 26, 2025
A threat to shift his own fees onto a pro se opponent for the act of sending correspondence — correspondence that was documenting the fraud, asset-concealment, and tax-evasion allegations he “rejected and denied.”

Also — verbatim, in his own motions

“Wife did successfully complete probation and the Court granted her request for an early termination… ended with the Wife pleading to a misdemeanor and receiving probation — a normal course of conduct in criminal cases.”
Hal Roen · Filing #222525931 · May 6, 2025
“Successfully complete” quietly writes out the one thing that never happened — the court-ordered mental-health evaluation and treatment that was the plea’s central condition. Early termination is recast as completion.
“Husband’s… conduct is outrageous, inappropriate, unnecessary and vexatious… designed to require Wife to expend her funds and assets to defend herself so that she will deplete said monies and then not be able to defend herself against Husband at all.”
Hal Roen · Wife’s Motion for Temporary Attorney’s Fees · Filing #219952086 · Mar 31, 2025
He accuses the pro se opponent of a scheme to drain the wife’s funds — in the very motion asking the court to make that opponent pay his fees.
“Husband is relentless. He will not take ‘no’ for an answer… To the lawyer who refused to agree with him about an order of court or a plea form prevailing, he has initiated a bar complaint.”
Hal Roen · Wife’s Motion to Require Depositions Before a Special Master · Filing #222525931 · May 6, 2025
A Bar complaint documenting his own conduct is recast as mere retaliation for disagreement.
“When Husband stated that he believed the Wife to be emotionally or mentally unstable, Husband was questioned as to whether or not he believed himself to be emotionally or psychologically unstable…”
Hal Roen · Wife’s Objection to Husband’s Recusal Motion · Filing #203916204 · Aug 2, 2024
Confronted with the court-ordered mental-health condition, counsel’s move was to suggest the accuser is the unstable one.
Every quotation above is reproduced in full, in context, with its filing-level citation, in the Prima Facie (Tab 03). A subject who believes any quotation is inaccurate or out of context is invited to submit a written correction to Mr. Dennis Miller at dennis@devoeng.com.
On the record · what he heard, and what he blocked

These are excerpts from his client’s own two depositions — April 1 and June 27, 2024 — verbatim from the certified transcripts, with the reporter’s page and line numbers. They matter to his conduct in two ways. First, sitting feet away, he heard a witness who could not recall her own prior divorce, her children’s whereabouts, the year of her first marriage, or what mediation was — yet he kept litigating against her husband and formed his own contrary view of her capacity. Second, when opposing counsel asked where a marital asset was held, Mr. Roen told her not to answer. Nothing below is paraphrased.

Highlighted = the witness’s own words of confusion / memory loss Slate cards = Mr. Roen directing her not to answer
Mr. Roen directs her not to answer — the marital gold & silver
Deposition 1 · April 1, 2024 · p.20:12–25

QCurrently, where — how is the gold and silver held?

AI have it in a safe place.

QAnd where’s that?

ROENYou don’t have to answer that.

QWhere? Identify the account.

ROENIt’s a safe place.

On the asset bought with the ~$700,000 Fidelity joint account, counsel instructs the witness not to say where it is — no privilege asserted.
Deposition 1 · p.27:2–24 (the standing objection)

ROENShe has indicated … she’s not wanting you to know where the location of the gold and silver is. … So let’s forego this dance around where the gold is. She doesn’t want you to know, and you want to know, so just have the judge rule.

ROENWe’ll just have a standing objection to every question you want to ask as to where the location of the asset is, who’s holding it, if it’s in a bailment, any questions along that line.

ROENWhy do you need to know that?

QIt’s a marital asset.

A blanket standing objection to every question about where the marital gold and silver is held — and he asks opposing counsel why he needs to know.
Deposition 2 · June 27, 2024 · p.71–72

QWhat was the name of that person?

AI won’t tell it right now.

ROENNo. No. You already used — said his name. What was it?

AWho?

ROENThere was a David someone and a Maha Rijioki (phonetic).

AMaster Lama Rasaji. Yeah.

QMr. Rasaji, is that his legal name?

AYeah.

When her memory fails mid-answer — “Who?” — counsel supplies the name for her; she then affirms that a spiritual title, “Master Lama Rasaji,” is his “legal name.”
What he heard her say — Deposition #1 (April 1, 2024)
Deposition 1 · p.7–8 (her own prior divorce)

QHave you previously filed for divorce?

AYes.

QAnd when was that?

ADuring the term, I don’t know. Maybe a — maybe a year-and-a-half ago.

QDo you remember what date, month, and year that was you filed?

ANo. … No, I can’t remember. I can’t remember, but it was prior to — prior to Hal, maybe by about six months.

She cannot recall when she filed her own prior divorce — only that it was before she retained Mr. Roen.
Deposition 1 · p.7:18 (her children)

QAnd where do they currently live?

AI don’t know where [my daughter] is currently, and my husband told me that [my other daughter] lives in New York.

She does not know where her own daughter lives, and relies on her husband for the other.
Deposition 1 · p.20–21 (the gold she lives on)

QDo you know how much you have in gold and silver?

ANo.

QDo you have an approximate amount —

ANo.

QAnd how much have you sold of it?

AI don’t remember. I sell as I need.

She cannot quantify — even approximately — the gold and silver she says she lives on.
Deposition 1 · p.31–32 (her taxes)

AFor the 2020 tax return, I never quite finished … because there was a tax liability, and I had no intention of paying it.

QAnd — what was the amount?

AI don’t remember.

She cannot recall the size of her own tax liability.
Deposition 1 · p.33–34 (her first marriage)

A… divorced, I think it was 1990, 1991. Somewhere around there.

QDo you recall what year that was?

A1990, I think. … I don’t remember the exact year.

She is unsure of the year of her own first marriage and divorce.
Deposition 1 · p.38 (does not understand the questions)

QDo you have any premarital assets? … Premarital to 2008?

AI’m not sure I understand that question, now.

AHe’s — I’m not sure what he’s trying to get at.

She repeatedly cannot follow plain questions about her own assets.
Deposition 1 · p.55–56 (her own bank statements)

ADeposit from — for 50,000? No, I can’t remember where this came from.

AWell, I used the money to buy something. I don’t remember. … I can’t remember these transactions in detail.

AI can’t remember the details of that transaction. I don’t know about what MoneyLine is.

AI can’t remember. I cannot remember. That’s the truth. I don’t remember.

Asked to identify six-figure deposits and withdrawals in her own account, she answers “I cannot remember. That’s the truth” — and suggests her daughter may have made them.
Deposition 1 · p.63 (“a very traumatic year … under probation”)

QIt didn’t just appear, like, out of thin air, right?

AThis was a very traumatic year for me because I was under probation … It was a very difficult time, and I can’t remember the details of these transactions.

QSo you initiated all these deposits?

AThat would probably be true, yes.

She ties the memory gaps to the year she was under criminal probation — the same court-ordered mental-health period that recurs throughout this record.
What he heard her say — Deposition #2 (June 27, 2024)
Deposition 2 · p.64–65 (the mediation)

QDo you recall the date of your last mediation in your divorce?

AThe last mediation?

ROENYou have to answer.

AI don’t know. I can’t remember. What was the mediation?

ROENWhere we met to try and negotiate a settlement.

ABut we didn’t physically meet, right? That was done online?

She does not remember the mediation occurred — or what the word means — and her own attorney has to define it for her.
Deposition 2 · p.65–66 (“why are we here?”)

QWhen you were served with the divorce petition, you were served with the administrative standing order?

AIs that standard? Whatever I was served, I was served.

AI don’t understand what he’s asking me. I mean, why are we here?

QYou were served with a petition for dissolution of marriage —

AWell, clearly something has happened, we’re here now. … So I guess the answer would be yes.

She asks “why are we here?” and answers by inference about her surroundings rather than from memory.
Deposition 2 · p.67 (the “land trust”)

QWhat is a land trust?

AWell — The investment where we’re going to have the lamasery.

QThe entity Prosperity For Life, LLC, is the land trust?

ANo. The arrangement is a land trust.

QAre you aware that that entity is closed?

ANo. I — we meet once a week.

Circular, non-responsive answers about the entity she wrote a $50,000 check to — she cannot keep the company, the investment, and the “arrangement” distinct.
Deposition 2 · p.69 (marital funds & Randy Dean Lillard)

QDo you know who Randy Dean Lillard is?

ANo.

QYou’ve never heard of that name ever?

ANo.

QSo the $50,000 … those are marital funds, correct?

ANo. Well, that’s my funds now.

QWere they marital funds at any point?

AWell, I don’t know. I don’t know if they were marital funds.

She denies ever hearing the name Randy Dean Lillard — the counterparty later named on the loan agreements used to explain this same $50,000 — and gives contradictory answers in consecutive lines about whether the money was marital.
Deposition 2 · p.71 (she turns to her lawyer)

AWhy is he asking me all of these questions? Why are we going down this rabbit hole?

OTEROCharmaine, can you please answer the questions.

AI’m speaking with my lawyer.

ROENHe’s allowed to ask you the questions.

AProceed, Mr. Otero.

In the middle of the husband’s counsel’s questioning she turns to Mr. Roen as if in private — “Why are we going down this rabbit hole? … I’m speaking with my lawyer” — and resumes only after he tells her to.
And in his own deposition — Devo’s Deposition #2 (June 27, 2024): the April settlement offer
Devo Deposition 2 · p.51–52 (the April offer, opened for the first time)

DEVOGo to settlement offer, Hal, and I want you to read it to yourself…

OTERODid you find it, Hal?

ROENI did not.

OTEROYou want me to send this to him?

ROENWell, this flash drive was just delivered to me this week.

DEVONo. It was — we sent it to you before…

OTERONo, I sent it to you —

ROEN[reads the offer] … Did you see this, Charmaine?

SAITHI don’t know.

ROENLet’s go off the record for a few minutes, please.

(Brief recess taken.)

ROENThis deposition has not been completed as of today, and I am suspending it…

(Deposition suspended, 1:35 p.m.)

Devo’s sweeping settlement offer had been on the flash drive since April; here Mr. Roen opens it for the first time — both Devo and his own counsel correct Roen’s “just delivered this week.” The moment he reads it he turns to his own client — “Did you see this, Charmaine?” (“I don’t know”) — and instantly goes “off the record.” When the record resumes he does not continue — he suspends the deposition at 1:35 p.m. and never finishes it. (It is the same flash drive he would later, in his October 2025 contempt motion, treat as never received — see the Lack of Candor tab.)

Charmaine Saith Depositions #1 (Apr 1, 2024) & #2 (Jun 27, 2024) and Devanand Seereeram Deposition #2 (Jun 27, 2024), certified transcripts (Landmark Reporting, Inc.), pages/lines as cited. All witness and counsel statements verbatim; bracketed ellipses mark omitted intervening words only. Gray takeaways are the compiler’s reading of the record, not adjudicated findings.

The Full ReportPrima Facie Evidence of Professional Misconduct

The complete compilation — all 41 predicates, organized into the ten clusters summarized in Tab 01, each with its documented facts, record citations, and Bar-rule and crime-fraud-exception analysis. Every factual assertion is cited to the filed record so the reader can verify it independently.

575 pages41 predicatesfully bookmarkedupdated almost daily
▸  Open the Full Prima Facie (PDF)
Opens in a new tab — this page stays open behind it. In the reader, use the sidebar / outline (the bookmarks icon) to jump between the 41 predicates; Download and Print are in its toolbar. The version and date are printed on the cover page.

The Depositions, on VideoWatch him work

Filings and transcripts are one thing; watching counsel operate in real time is another. Below are the certified video depositions in which Mr. Roen examines, objects, coaches — and, in one, suspends the proceeding. Nothing is edited; each is the complete record. Page-and-line citations to the moments described are in the Prima Facie (Tab 03).

01Jason Bankowitz — Deposition
May 1, 2025 · examined by Dr. Devo Seereeram, pro se · certified video record
What to watch: the attorney who wrote and signed the plea form testifies he did not know the client (“Know her, no”) and had “no idea what’s in her file.” He reads the October 12, 2022 letter into the record — the mental-health condition “was on the signed plea… [but] did not make it into the court order” — then reverses himself on the controlling question: early on he swears the open-court oral plea (Exhibit 2) “would be controlling,” but by the end claims the typed order (Exhibit 3) “overrides” it — then abruptly ends his own deposition.
02Ana Hofer (now Hirsch) — Deposition
April 9, 2025 · 1 hr 31 min · examined by Dr. Devo Seereeram, pro se · certified video record
What to watch: Mr. Roen says he does not represent the witness (“No, sir. I’m representing Ms. Saith”), then concedes he gave her “free legal advice,” tells her “Say yes,” and instructs her “Don’t give him anything” when she’s asked for her phone log — seven days before he files a Notice of Appearance as her counsel.
03Charmaine Saith — Second Deposition
June 27, 2024 · examined by Carlos Otero, Esq. (for the Husband) · certified video record
What to watch: the gold-account admission — “this is where all my money is held… 1,411,644.82… all of it is marital” — Mr. Roen’s mid-answer coaching (“you did good”), the off-the-record recess the moment the witness is asked where her assets are, and the close where he calls it “the second meaningful deposition” and declines a third.
These are the complete, unedited certified video records. A subject who believes any characterization above is inaccurate is invited to submit a written correction to Mr. Dennis Miller at dennis@devoeng.com.

The Quiet SwapThe plea — signed in open court vs. what was typed up

📕 The Plea — what was signed in open court vs what was typed up

On August 15, 2022, the Defendant Charmaine Saith entered a plea in open court before The Honorable Judge Tanya Davis Wilson (Ninth Judicial Circuit, Division 15) in State of Florida v. Charmaine Saith, Case No. 2021-CF-013577-A-O. The prosecutor-and-defense agreed terms were captured on the standard Plea (S) Form in counsel's handwriting (Exhibit 2 below), with one of those terms reading “mental health eval & treatment.” The Defendant initialed every clause across all four pages, the Defendant signed at the foot, the Defense Counsel Jason C. Bankowitz (Florida Bar No. 657387) signed, the Asst. State Attorney Brian C. Hagner (Florida Bar No. 1015863) signed, and the form was sworn to, signed, and filed in open court in the presence of The Hon. Judge Tanya Davis Wilson. On that signing, the open-court terms became the Court's order.

The typed Order of Probation entered the same day (Exhibit 3 below) carried over the Anger Management term, the firearms forfeiture, the costs — but did not contain the mental-health-evaluation term. In its place, a drug-and-alcohol evaluation term appeared that was not in the signed and court-ordered plea.
The crux: this is not a simple omission — and it is not even an equivalent substitution. The oral plea's term was “mental health eval & treatment” (mandatory, no qualifier). The typed Order's substituted term is conditional and waivable: “if treatment is deemed necessary… unless waived by the court.” Mandatory MH-eval-and-treatment was traded for optional D&A-eval-only. The chain-of-custody question on the Pro Se Motion to Judge Kevin Weiss (July 15, 2024) sharpens accordingly: who altered the Court's signed order — substituting “drug & alcohol” for “mental health” — between the sworn, signed, and open-court-filed Plea Form on August 15, 2022, and the typed Order of Probation entered the same day? The court did not order disclosure.
📜
The two documents — side by side, as filed
Exhibit 2 (left): the Plea (S) Form, signed and initialed in open court · Exhibit 3 (right): the typed Order of Probation entered the same day
Hal Roen denies validity
EXHIBIT 2 Oral Plea (Plea Form, hand-written, filed in open court)
Exhibit 2 — handwritten Plea (S) Form, August 15, 2022, filed in open court. Section 2A 'The prosecutor and I have agreed to the following' lists: W/H; 12 mos s/p; Ø firearms/ammo; forfeit seized firearms; mental health eval and treatment; Anger mgt; costs; Ct 1: NPP.
Section 2A — “The prosecutor and I have agreed to the following” reads, in counsel's handwriting: W/H; 12 mos s/p; Ø firearms/ammo; forfeit seized firearms; mental health eval & treatment; Anger mgt; costs; Ct 1: NPP.
EXHIBIT 3 Typed Order of Probation (entered same day)
Exhibit 3 — typed Order of Probation entered August 15, 2022. Conditions: 12 months supervised probation; Anger Management within 10 months; no firearms or weapons; Drug and Alcohol evaluation within 10 months if treatment deemed necessary; forfeit seized firearms; $27 per month payment plan. No mental-health-evaluation term appears.
Conditions enumerated: 12 months supervised probation; Anger Management; no firearms/weapons; Drug and Alcohol evaluation — expressly conditional and waivable on the face of the Order: “You must undergo a Drug and Alcohol evaluation and, if treatment is deemed necessary, you must successfully complete the treatment within 10 months… unless waived by the court.” Forfeit firearms seized; $27/month payment plan. The mental-health-evaluation term is absent.
🔎
The diff — what was on the plea form, what made it into the Order, and what didn’t
Left: each handwritten phrase from Section 2A transcribed and plain-Englished · Right: each plea term compared against what appears in the typed Order, with status
Transcription — the handwritten plea, term by term
ElementHandwritten textPlain English
AdjudicationW/HWithhold adjudication
Term12 mos s/p12 months supervised probation
WeaponsØ firearms/ammoNo firearms or ammunition
Forfeitureforfeit [scratched word] seized firearmsForfeit the seized firearms
Treatment #1mental health eval & treatmentMental-health evaluation AND treatment
Treatment #2Anger mgtAnger management
MoneycostsCourt costs
Count 1 dispositionCt 1: NPPCount 1 (felony aggravated assault) — Nolle Prosequi
The diff — oral plea vs typed Order, row by row
TermIn oral plea?In typed Order?Status
Withhold adjudication✓✓ (“Adjudication Withheld”)match
12 months supervised probation✓✓match
No firearms/ammo✓✓match
Forfeit seized firearms✓✓match
Mental health eval & treatment✓✕ — ABSENTOMITTED
Anger management✓✓ (“within 10 months”)match
Costs✓✓ ($27/month payment plan)match
Count 1 Nolle Prosequi✓✓ (“Nolle Prosequi (NC)”)match
Drug & Alcohol evaluation✕ — NOT in oral plea✓ — PRESENT but optional: “if treatment is deemed necessary… unless waived by the court”ADDED · OPTIONAL
🖋
The Signatories — by whom this was court-ordered
Pages 2, 3, and 4 of the four-page Plea (S) Form, August 15, 2022 · per-clause initialings (pages 2-3) and the open-court signature page (page 4) — the file-stamp on page 1 is reproduced in Exhibit 2 above
PAGE 2 OF 4 Per-clause initialings — items 5–14
Page 2 of the four-page Plea (S) Form, August 15, 2022. Defendant Charmaine Saith's initials (CS) appear on items 5 (Plea Understanding), 6 (Charges/Defenses/Penalties), 7 (Voluntariness), 8 (Deportation), 9 (Education), 10 (Competency), 11 (Enhanced Sentence), 12 (Prison Releasee Reoffender), 13 (Criminal Punishment Code), and 14 (Time Served).
The Defendant's initials appear on every clause — items 5 through 14 — including item 10 Competency: “I am not under the influence of any drugs, alcohol, medication, or narcotics… I am not suffering from any physical or mental problems that would affect my understanding of these proceedings.”
PAGE 3 OF 4 Per-clause initialings — items 15–26
Page 3 of the four-page Plea (S) Form. Defendant's initials appear on items 15 (Early Release), 16 (Attorney Fees), 17 (Civil Commitment), 18 (Driver's License), 19 (Supervision Tolling and Costs), 20 (DNA), 21 (Sentencing Date), 22 (Collections Court), 23 (Hearing Presence), 24 (Seal/Expungement), 25 (Appeal), and 26 (Defendant's Certification).
The Defendant's initials continue on items 15 through 26, closing with item 26 — Defendant's Certification: “I have read every word in this Plea(s) form, have discussed the contents with my attorney(s), and fully understand it.”
PAGE 4 OF 4 SWORN, SIGNED, & FILED in open court
Page 4 of the four-page Plea (S) Form. The page heads with: 'SWORN TO, SIGNED, AND FILED IN OPEN COURT in the presence of defense counsel and the Judge.' Below: Defendant's signature (Charmaine Saith); Deputy Clerk in Attendance line; Certificate of Defendant's Attorney(s) and Prosecutor — signed by Defense Counsel (Florida Bar No. 657387, Jason C. Bankowitz) and Prosecutor (Florida Bar No. 1015863, Brian C. Hagner); DNA Inquiry Addendum signed by Defense Counsel, Defendant, and Prosecutor, dated 8/15/22.
“SWORN TO, SIGNED, AND FILED IN OPEN COURT in the presence of defense counsel and the Judge.” Below: the Defendant's signature, the Defense Counsel's signature (Fla. Bar No. 657387 — Jason C. Bankowitz), the Asst. State Attorney's signature (Fla. Bar No. 1015863 — Brian C. Hagner), and the DNA Inquiry Addendum signatures — all dated 8/15/22.
Why this matters: the four-page Plea Form is itself the Court's instrument. By signing it, The Hon. Judge Tanya Davis Wilson made the agreed terms the Court's order — and the form was “sworn to, signed, and filed in open court.” The typed Order of Probation entered the same day was supposed to be the transcription of that court order, not a re-negotiation. The substitution of “drug & alcohol” for “mental health” therefore is not a deviation from a private bargain — it is, on the face of the documents, an alteration of the Court's signed order.

A second integrity note from the signatures themselves: the typed Order of Probation (Exhibit 3) names David Bigney as appearing counsel for the Defendant; the signed Plea (S) Form (Exhibit 2 / page 4) bears the signature and Florida Bar No. of Jason C. Bankowitz as Defense Counsel of record. The same Jason C. Bankowitz later appears as a witness in the related civil dissolution (May 1, 2025 deposition — see Tab 04, Watch Him Work) and is the subject of Florida Bar complaint RFA 25-12168.
A third integrity note — the initial on the altered Order. The typed Order of Probation (Exhibit 3) bears no signature from defense counsel and none from the State Attorney. Defense counsel Jason C. Bankowitz testified under oath that the typed Order was “generated by the court clerk” — “I do not believe that the judge is sitting up there taking the plea and typing the document… the clerks are in there to generate those documents and the judge signs them” (Bankowitz Tr. pp. 58–59) — that he could not identify the signature as Judge Wilson’s (“I have no idea what Tonya Davis Wilson’s signature looks like”), and that his own signature is not on the Order (Tr. p. 59).

The only mark the altered Order carries is therefore an initial of the kind used by the clerk’s office on clerk-generated orders — not a signature personally affixed by Judge Wilson to terms pronounced in open court; defense counsel could not authenticate it as her signature. The consequence: the substitution of a drug-and-alcohol evaluation for the open-court term “mental health eval & treatment” — a term the Judge never pronounced — was given the force of a court order by an initial placed on a document the clerk generated, with no attesting signature from either counsel of record. Who entered the substituted term, and on whose authority Judge Wilson’s initial was applied to it, are the open questions raised — and never answered — in two separate demands: the July 15, 2024 Motion to Request Chain-of-Custody Documentation (before The Hon. Kevin Weiss) and the March 12, 2025 Request for Investigation and Chain-of-Custody Inquiry to the Clerk of Court, copied to the FDLE Public Corruption Unit — the latter expressly asking whether the Judge personally reviewed the order or whether “the signature stamp was applied without proper authorization.” Neither produced disclosure or a response of record.

Why a substitution like this ordinarily goes undetected — and why this case is the exception. Routine sentence reductions issue on clerk-generated orders bearing an applied initial, with no independent check that the typed order matches the plea taken in open court. The structure holds because such a change has no aggrieved party: the defendant benefits from the lighter, waivable condition and never compares the two documents. It is a process an error — or worse — would pass through unnoticed, because in the ordinary case no one looks. This is the rare case in which someone did — the objector is not the defendant but a family member who sought the very mental-health treatment that was removed — and the discrepancy surfaced only because, for once, a person with the opposite interest read the open-court plea against the typed order side by side.
🏛  Florida law
When the typed Order conflicts with the open-court plea, the open-court plea controls.
The controlling Florida doctrine is settled and longstanding. Where a written sentencing order conflicts with the oral pronouncement made in open court, the oral pronouncement prevails —
  • Williams v. State, 957 So.2d 600, 602 (Fla. 2007) (“It is well established that where there is a discrepancy between the written and oral pronouncements of a sentence, the oral pronouncement prevails.”)
  • Justice v. State, 674 So.2d 123, 125 (Fla. 1996) (same)
  • Ashley v. State, 850 So.2d 1265 (Fla. 2003) (defendant entitled to enforcement of the plea bargain as orally agreed in open court)
  • Fla. R. Crim. P. 3.172 — plea acceptance is an open-court act; the plea form is sworn to, signed, and filed in open court
  • Fla. R. Crim. P. 3.800(a) — sentences that do not conform to the open-court pronouncement may be corrected at any time
On the documents above, Exhibit 2 is the open-court plea (sworn to, signed, and filed in open court, August 15, 2022); Exhibit 3 is the typed Order entered the same day. Under Williams, Justice, and Ashley, Exhibit 2 controls wherever Exhibit 3 conflicts with it — including on the mental-health-evaluation-and-treatment term.
Mr. Roen's posture inverts this rule. Mr. Roen accepts the typed Order (Exhibit 3) as the operative authority for the post-plea probation period and the April 20, 2023 termination of probation; he denies the validity of the open-court Plea Form (Exhibit 2) as a basis for the present claims. That posture treats the derivative as authoritative and the original as dubious — the opposite of what Williams, Justice, and Ashley command. See Tab 02 (Roen in His Own Words) for the contemporaneous record of that posture.
The bottom line
The mental-health evaluation and treatment that the Court itself ordered on August 15, 2022 — sworn, signed, and filed in open court by The Hon. Judge Tanya Davis Wilson, the Asst. State Attorney Brian C. Hagner (Florida Bar No. 1015863), the Defense Counsel Jason C. Bankowitz (Florida Bar No. 657387), and the Defendant herself — was never delivered to Mrs. Saith.
The typed Order of Probation that the Florida Department of Corrections enforced did not require it. And what was substituted in — the Drug and Alcohol evaluation — was optional and waivable on the face of the Order itself (“if treatment is deemed necessary… unless waived by the court.”) The substitution therefore did not even guarantee a comparable evaluation. When the Petitioner asked Probation Supervisor Sneider St. Fleur about it on October 5, 2022, the reply was: “the previously-provided document is a plea form, not a court order.” A rushed online “ART session” with newly-licensed (June 2022, nine months experience) Patricia A. Houchin on March 27, 2023 was offered to fill the gap — the only record of it is a $230.73 debit-card charge. The April 19, 2023 hearing on early termination went forward on the typed Order; on April 20, 2023, probation was terminated. The mental-health evaluation and treatment bargained for in open court were never received.

The Petitioner filed the Motion to Reopen Case Due to Clerical Error and Incomplete Probation Requirements on July 12, 2024 and the Motion to Request Chain of Custody Documentation on July 15, 2024 (both before The Hon. Kevin Weiss, presiding 2024). Neither was ruled upon.
🛡️
Related exhibit — the Article I trust consequence of this same mental-health record
The documented incapacity at the center of this tab is the trigger the Saith-Seereeram Family Revocable Trust placed first — and a divorce court compelled its reversal
ARTICLE I Revocation of Removal (Mar. 6, 2024) & the Article I Removal of Trustee (Mar. 1/4, 2024) — side by side
Two instruments of the Saith-Seereeram Family Revocable Trust side by side. Left: Revocation of Removal of Trustee, executed March 6, 2024 by Devanand Seereeram, reciting it was made against the opinion of Devanand, who firmly believes his wife Charmaine Saith has serious mental health issues and is incapable of acting as a trustee, and executed pursuant to the court order entered March 5, 2024 by Judge Diana Tennis. Right: Removal of Trustee and Acceptance by Successor Trustee, executed under Article I, removing Charmaine Saith as Co-Trustee on the Grantor's opinion of her incapacity and seating Indrani Seereeram as successor Co-Trustee.
Why it belongs here: Article I of the Trust — placed first in the instrument — lets either Grantor, on his or her own opinion and without a physician and without a judge, treat the other as “unable to properly handle his or her own affairs” and seat a successor co-trustee. On March 1/4, 2024 Dr. Seereeram exercised that power (right) — removing Charmaine Saith as Co-Trustee on his opinion of her incapacity, the same mental-health record this tab documents, and installing his sister Indrani Seereeram. On March 5, 2024 Judge Diana Tennis entered an order; on March 6, 2024 Dr. Seereeram executed the Revocation (left), which states on its face that it was done “against the opinion of Devanand… pursuant to the court order.” The objection is preserved in the instrument itself — he did not recant; the reinstatement was compelled.

Exhibit — The Manufactured “Loan Agreements”

Two backdated instruments — for a loan to an entity dissolved 54 days before the check — tendered April 29, 2025 to characterize the Nov 15, 2023 transfer of $50,000.

Seereeram v. Saith, Case No. 2023-DR-004193-O — Ninth Judicial Circuit, Orange County, FL

SECOND AGREEMENT · typed, logo · dated Nov 23 2024
Typed second loan agreement dated Nov 23 2024
FIRST AGREEMENT · handwritten · dated Nov 10 2023
Handwritten first loan agreement dated Nov 10 2023

How to read the three dates

Date written on the documentRight: “Nov 10, 2023” (handwritten)Left: “Nov 23, 2024” (typed)
Date both signatures were signedRight: 11-10-23Left: BOTH signed March 13, 2025 — ~16 months after the transfer, ~110 days after the date the page bears, and one day after Husband told Wife there would be no settlement (trial)
First disclosed / filed with CourtApril 29, 2025 (both, attached to Wife’s Supplemental Response)
File timestamp on the right scanFilename 20240415_105114.jpg → digital timestamp Apr 15, 2024, on a page dated Nov 10, 2023 (true creation date reserved for forensic examiner)

Field-by-field discrepancies

FieldFirst Agreement (11/10/2023)Second Agreement (11/23/2024)Why it matters
Loan amount$50,000$55,000The $5,000 increase = exactly 10% interest on $50,000 for one year — i.e., interest manufactured on paper, though no payment was ever made.
Interest rateBlank10%, compounded annually (written in)Rate appears only on the later version.
FormatHandwritten on a generic templateTyped, with Prosperity for Life logoTwo materially different instruments for one transfer.
Lender print-name fieldBlank“Randy Lillard”Signed for Prosperity by the very person Wife swore under oath (June 27, 2024) she “did not even know.”
Lender name / addressMisspelled & incorrect / incompleteCorrectIdentifying details corrected only on the later version.
Signature date11-10-23BOTH signatures dated March 13, 2025Second agreement signed ~16 months after the transfer and ~110 days after the date it bears.
Term“Until 2030”“Until November 23, 2030”Term made specific only on the later version.
Counterparty statusProsperity for Life LLC administratively dissolved Sept 22, 2023Reinstated Aug 7, 2024 (with missing 2023–24 reports)Both agreements run with a DISSOLVED entity — the dissolution was 54 days BEFORE the Nov 15, 2023 check; reinstatement came only after the Fla. OFR investigation began June 6, 2024.

Anchors (record, Roen Prima Facie v0.95, Predicates 11 & 37): Mediation collapsed Oct 17, 2023, 13:54 PM EDT. Transfer: $50,000 check to Prosperity for Life LLC, Nov 15, 2023 — 54 days after the entity was administratively dissolved (Sunbiz, Sept 22, 2023). Wife testified June 27, 2024 she did not know Randy Dean Lillard. Both agreements first disclosed/filed Apr 29, 2025 (Wife’s Supplemental Response). Second agreement signed Mar 13, 2025 — one day after settlement breakdown (¶ P37.16). Counterparty under Fla. Office of Financial Regulation inquiry (OFR #122961, opened June 6, 2024); Husband’s Bench Memorandum (Filing #222513407, May 6, 2025) ¶ 3.

Color key:factual discrepancylegal note

Open the full sworn timesheet in its own tab ↗

The Trust OverreachHe blocked a protective trust clause that has nothing to do with money — before he had read the report he swore existed

The Saith-Seereeram Family Revocable Trust was settled on March 10, 2008 — fifteen years before this divorce. Its very first article, Article I, is a private family safeguard: if one spouse can no longer handle their own affairs, the other may seat a trusted relative as a co-trustee check. It moves no money. It transfers no property. It strips no one of liberty. Mr. Roen moved to block that safeguard — and the record shows he did so months before he had reviewed the mental-health evaluation he had already sworn to a court was complete and favorable.

$0
Money Article I moves
(it is a trustee-succession safeguard, not a distribution)
0
Physicians or judges Article I requires at stage one
(only "the opinion of the other Grantor")
~4 months
Between blocking the clause (Mar 4, 2024) and first reviewing any psych report (Jul 30, 2024)

Pillar 1 — Article I is protection, not property

Article I — the first operative article of the 2008 Trust — provides, verbatim:

"If either Grantor dies or is adjudicated to be incompetent or in the event that such Grantor is not adjudicated incompetent, but by reason of illness or mental or physical disability is, in the opinion of the other Grantor unable to properly handle his or her own affairs, then and in that event Indrani Seereeram shall serve with the other Grantor as Co-Trustees hereunder."

Read it for what it is. The trigger at stage one is "the opinion of the other Grantor" — no court adjudication, no physician's certificate, no incapacity hearing. The consequence is equally modest: a sister, Indrani Seereeram, is seated with the other Grantor as a co-trustee. Because co-trustees must act unanimously, Indrani is a built-in check — not a path to control, and not a path to anyone's money. Article I changes who watches the assets, never who gets them. Separate property keeps its character under Article II — it “shall retain its character as separate property of the Grantor who transferred” it, subject to the trust’s own terms — so a change of trustee under Article I does not alter who owns it.

Pillar 2 — Roen moved to block it

On March 4, 2024, Mr. Roen filed a Verified Motion to Enjoin (Filing #193220536) seeking to freeze the Petitioner's invocation of this Article I safeguard. To do it, he demanded the very thing Article I was written to make unnecessary — a prior formal adjudication of incapacity — recasting a private, court-free family mechanism as something that required the court's permission. The Petitioner had simply exercised the power the instrument plainly grants: on March 1, 2024 he seated Indrani Seereeram as successor Co-Trustee on his own opinion of his wife's condition. Mr. Roen's motion existed to stop a safeguard, not to protect an estate.

Pillar 3 — He blocked it before he had read the report

The same March 4, 2024 Verified Motion vouched, under oath, that a recent, satisfactory mental evaluation of his client existed and was in counsel's hands. It was not. Mr. Roen's own sworn fee timesheet (Filing #230534891; retyped at Doc. 0279) contains no entry reviewing any psychological analysis before July 30, 2024 — the first such line is dated July 30, 2024, "Review psych analysis," 0.30 hours, roughly four months later. He bills in tenths of an hour and did bill the review when it finally happened — so the absence of any earlier entry is his own record's admission: he swore to the favorable results of a report he would not read for another four months, and on that footing moved to block a protective clause that turns on no report at all.

And the “evaluation” never materialized as a current report. The only document Mr. Roen ever produced as the promised “mental evaluation” — tendered July 21, 2025, and only after a court order (July 11, 2025) compelled it — was a pair of letters by Dr. Jeffrey Danziger dated February 13 and August 5, 2022: criminal-defense evaluation letters written for Mrs. Saith’s defense attorney, the first before charges were even filed. They were not a recent psychiatric evaluation, and their “no treatment” conclusion was the very opinion the State Attorney rejected — ten days after the August 5 addendum, the August 15, 2022 plea imposed twelve months of mandatory mental-health treatment. So the “satisfactory” evaluation Mr. Roen swore was in hand in March 2024 did not exist — and what he produced in its place was a 2022 pre-plea defense letter, not the current evaluation he had represented.

The documented sequence

  • Mar 1, 2024 — Petitioner invokes Article I, seating Indrani Seereeram as successor Co-Trustee (no court, no physician required at stage one).
  • Mar 4, 2024 — Roen files the Verified Motion to Enjoin (#193220536), blocking the safeguard and swearing a "satisfactory" mental evaluation already existed.
  • Mar 5, 2024 — Judge Diana Tennis enters an order.
  • Mar 6, 2024 — Petitioner executes a Revocation, reciting on its face that it was done "against the opinion of Devanand… pursuant to the court order." The objection is preserved in the instrument; the reinstatement was compelled.
  • Jul 30, 2024 — Roen's first timesheet entry reviewing any psych report appears — ~4 months after he swore one existed.

The instrument itself — scenario review

Below is the full Trust, article by article, with a side-by-side reading of what happens if the Article I safeguard stands versus if the court blocks it. Note throughout that Article I never reaches the husband's separate property — the dispute Mr. Roen manufactured was never about who gets the money.

Open the full trust analysis in its own tab ↗

Exhibit — the Article I removal and its court-compelled revocation

ARTICLE I Revocation of Removal (Mar. 6, 2024) & the Article I Removal of Trustee (Mar. 1, 2024) — side by side
Two instruments of the Saith-Seereeram Family Revocable Trust side by side. Left: Revocation of Removal of Trustee, executed March 6, 2024 by Devanand Seereeram, reciting it was made against his own opinion pursuant to the court order entered March 5, 2024 by Judge Diana Tennis. Right: Removal of Trustee and Acceptance by Successor Trustee, executed under Article I, removing Charmaine Saith as Co-Trustee on the Grantor's opinion of her incapacity and seating Indrani Seereeram as successor Co-Trustee.
What it shows: On March 1, 2024 Dr. Seereeram exercised the Article I power (right) — seating his sister Indrani Seereeram as successor Co-Trustee on his own opinion of his wife's condition, exactly as the instrument allows, without a physician and without a judge. After Mr. Roen's March 4 motion, Judge Diana Tennis entered an order on March 5, 2024, and on March 6, 2024 Dr. Seereeram executed the Revocation (left), which states on its face that it was done “against the opinion of Devanand… pursuant to the court order.” The objection is preserved in the instrument itself — the reinstatement was compelled, not chosen.

Sources: Saith-Seereeram Family Revocable Trust (settled Mar. 10, 2008), Article I and Articles II, IV–V. Roen's Verified Motion to Enjoin, Filing #193220536 (Mar. 4, 2024). Roen's sworn fee timesheet, Filing #230534891; retyped at Doc. 0279 (first psych-review entry Jul. 30, 2024). Order, Hon. Diana Tennis (Mar. 5, 2024). Revocation of Removal of Trustee (Mar. 6, 2024). All filings sourced to the Florida e-filing portal, Case No. 2023-DR-004193-O.

A plain-language guide
Legal Misconduct & Dishonesty

Courts and bar rules use a ladder of terms for dishonesty — from an honest mistake up to corrupting the court itself. The deeper the color, the more serious. This tab is about lack of candor — the mildest rung of dishonesty — though several entries in the list below climb much higher.

Non-Deceptive Errors
No clear dishonesty
1
Negligence / Carelessness
A sloppy mistake or omission, with no intent to deceive.
2
Poor Judgment
An unwise decision; should have known better.
Deceptive / Improper Conduct
Some form of dishonesty
Darker = more serious ↓
3
Lack of Candor◀ THIS TAB
Not fully open or truthful; important facts left out.
4
Non-Disclosure / Failure to Disclose
Withholding information that should be revealed.
5
Misleading Conduct
Creates a false impression by wording, tone, or omission.
6
Misrepresentation
A false or misleading statement, or a half-truth.
7
Bad Faith
An improper motive or a lack of fair dealing.
8
Dishonesty
Knowingly untruthful conduct, or intent to deceive.
9
Deceit / Deceptive Conduct
Intentional trickery or a plan to mislead.
10
Fraud
Intentional deception for gain, or to cause harm.
11
Perjury
Lying under oath; false sworn testimony.
12
Suborning Perjury
Causing another person to lie under oath.
13
Obstruction of Justice
Interfering with the legal process — hiding evidence, tampering, witness intimidation.
14
Fraud on the Court
A deliberate scheme that corrupts the judicial process itself.

A lawyer’s duty of candor to the tribunal (Fla. Bar Rule 4-3.3) forbids false statements of fact or law to a court, and requires correcting them. Mr. Roen has stated that duty himself, on the record:

In his own words — his stated standard
Concession A
“The Canons require lawyers to have candor and to be truthful to the Court. A lawyer cannot intentionally mislead the court. The obligation of candor with the court is a stronger obligation than that of confidentiality of a client’s communication with the lawyer.”
Mrs. Saith, through Mr. Roen — Filings #240747344 & #240962066
Concession B
“As a member of the Florida Bar, I’m obligated to have candor with the Court. And failure to have candor with the Court subjects me to potential sanction from the Court or from the Bar.”
Mr. Roen, under oath at deposition — quoted in Notice of Record Preservation, Doc 0299

Measured against his own standard, the record holds 0 distinct candor problems below, each stated as He represented versus The record, ranked by how directly his own sworn motion, timesheet, or deposition supplies the contradiction. Each maps to a Predicate in the Full Prima Facie (Tab 03). Contentions from the record, not adjudicated findings.

Tags: ● tagged “candor” the filing itself uses the word / cites Rule 4-3.3  |  ○ untagged a candor-type falsehood not labeled as such  |  ⚠ verify verbatim exact words still to be pulled from the cited transcript before this line goes public.

Scope note. This tab is limited to candor — false or uncorrected statements made to a court or under oath. Other documented misconduct that is not candor — witness coaching and intimidation, the contempt-and-incarceration campaign, fee-source and asset-concealment issues — lives in the other tabs, so “Lack of Candor” means exactly what it says.

Sources: the Prima Facie (Tab 03, 41 predicates); Mr. Roen’s sworn Affidavit of Attorney Fees / timesheet (#230534891); his deposition and hearing transcripts; and the filed Notices of Attorney Lack of Candor (Docs 0279, 0284, 0286, 0292, 0299). Items marked ⚠ are awaiting verbatim confirmation from the cited transcript and should be verified before publication. Facial date inconsistencies are stated as documented fact; native-file metadata and signature authentication are reserved for a forensic examiner.

Open the orders summary in its own tab ↗

Open the attorney-representation chart in its own tab ↗

Open the contract analysis in its own tab ↗

Principal & Agent · The Closed SystemBeyond Prima Facie

The other tabs build a prima facie case — a first showing of misconduct. This tab asks a harder question, and it is the Petitioner’s central legal theory. Tab 12 names the instrument; Tab 13 names its legal consequence. On January 22, 2024, Mr. Roen had Mrs. Saith execute a replacement retainer containing Article III: “the ultimate determination shall be solely and independently that of the Attorney,” and the client and attorney “shall not be considered equal voices or participants.” In the same instrument, counsel’s hourly rate rose from $375 to $450. From that date forward Mr. Roen stopped being a messenger and became a principal whose agent’s acts he owns. Every substantive act after January 22, 2024 is either authorized by the contract he wrote — in which case he owns it under principal-and-agent law — or it is unauthorized, in which case it is a nullity. There is no third box.

This tab sets out the Petitioner’s legal theory — argument and contention drawn from the documentary record. It is not adjudicated findings, and it is not legal advice.

The trap, in one line: If Mr. Roen embraces Article III, he owns the post-contract acts under principal-and-agent law. If he disowns it, those same acts are unauthorized — a nullity under Nehleber and Bursten. Every escape route below tries to find a third box. None exists.
The hinge · how little contact preceded total control
Aug 2022 – Jan 2024
At most approximately 4¾ hours of one-on-one client contact across 17 months — Mr. Roen’s own sworn timesheet figure.
→
Jan 22, 2024
Article III signed — “the ultimate determination shall be solely and independently that of the Attorney” — 10 days after the $2.5 million civil-conversion suit (No. 2024-CA-000316-O, filed Jan 12, 2024) was filed against Mrs. Saith; rate raised to $450/hr.
→
After Jan 22, 2024
Everything substantive now falls under the contract’s umbrella of control.

Contact-time figure is drawn from Mr. Roen’s own sworn timesheet (Affidavit of Attorney Fees, Filing #230534891) and is corroborated by Mrs. Saith’s carrier phone-and-text records. See the contact-time analysis in the case file.

Before Article III: ~4¾ hrs of contact, $375/hr.
The instrument: rate to $450/hr in the same paper that stripped her decisional voice.
After: 18+ months of filings, depositions, fee affidavits & contempt cycles — all within the clause.
Two boxes — and no third
Box A · Authorized by Article III

If the act was within the “sole and independent” authority he wrote for himself, then as a matter of principal-and-agent law he is responsible for it. He owns it.

orno third box
Box B · Not authorized

If the act was outside that authority, then under Nehleber v. Anzalone (345 So. 2d 822) a lawyer has no implied or apparent authority over a client’s substantive rights — unauthorized acts are a nullity — and under Bursten v. Green (172 So. 2d 472) any such authority must be “clear and unequivocal.” The burden of showing it lies on the party enforcing the agreement. Sharick v. Se. Univ., 891 So. 2d 562 (Fla. 3d DCA 2004).

Every post–Jan 22–2024 act lands in Box A or Box B. The Petitioner’s position is that Mr. Roen must pick one — item by item.

Box A′ · The phantom third box — “Article III governs and it shields me.”

It forecloses itself. A retainer provision that conflicts with Rule 4-1.2(a) is void as against public policy. Chandris, S.A. v. Yanakakis, 668 So. 2d 180 (Fla. 1995). Article III therefore cannot be enforced for the attorney’s protection — only against him, as the attribution of his agent’s acts to himself. “Embrace and shield” is not a box that exists.

Agency-ownership ledger · pick a box, item by item
The post-contract actBox A — if authorized by Article IIIBox B — if he disowns it
The “Prosperity for Life” loan documents (Nov 2023 / Nov 2024 versions)Tendered to recharacterize a $50,000 marital transfer — within the agency he assumed.Unauthorized act on the client’s substantive rights → nullity under Nehleber/Bursten.
The financial affidavit / tax-return positionsSubstantive declarations of fact made while he was the “ultimate determination.”A financial affidavit is not “strategy”; if not his to direct, it cannot bind — nullity.
The Old Glory Bank transfers (gold → crypto)Asset movements in the matter he controlled and billed under.If outside his authority, he cannot have superintended them — yet he billed the period.
The $1.4M gold account — first surfacing in the June 2024 depositionSurfaced at his table, as counsel of record, under Article III.A lawyer cannot disclaim an asset that materialized in his own deposition.
The ~$800K gold depletion after the March 31, 2025 written noticeContinued representation + billing after written notice of the scheme.Post-notice acceleration is the crime-fraud predicate (below), not a defense.
See it in action · the tax return he had her file

That “tax-return positions” row above isn’t hypothetical — here’s the real one, and the timing is the whole thing. Article III made Mr. Roen the “ultimate determination” on January 22, 2024. Nine months later, on October 23, 2024, Mrs. Saith’s 2021 tax return got filed — on the Petitioner’s account, at Mr. Roen’s direction — and it was a fake. That’s not leftover history from before the contract. It’s a brand-new act filed inside the window where, by his own clause, he was running the show.

Two numbers, and neither one is real
Affidavit he drafted (Sept 8, 2023): possible IRS liability sworn at — $100,000
Return he had her file (Oct 23, 2024): tax she actually paid — $13,316
Her actual 2021 income: ~$923,000

The sworn number and the filed number aren’t even in the same ballpark — and both are fiction, because the real income was close to a million dollars. A $13,316 tax bill on ~$923K of income doesn’t happen by accident. You have to build it.

And building it is exactly what the return did. The Petitioner spelled out all five fabrications in writing and put them in the court record — Filing #226901217 (the “Batch 3” correspondence compilation, E-filed July 9, 2025), at pp. 127–129. Roen never answered it:

The five made-up items — $762,056 worth

• The “Hurricane Sally” dodge — $100,000. A $100K retirement withdrawal got claimed as a federal disaster distribution (Form 8915-F, FEMA DR-4564-FL) to skip the 10% penalty and spread the tax over three years. Catch: she lives in Orlando. Sally never hit Orlando. There was no disaster.
• The hidden retirement cash-outs — $142,564.31. She pulled about $242,564 out of retirement accounts and only reported $100,000 of it (that same fake disaster distribution) — leaving $142,564 unreported. The trick: $277,531 of IRA money got stamped a tax-free “rollover” when it was really cashed out and spent.
• The kids’ college money — $506,963. Half a million pulled from the children’s 529 funds, reported like it barely counted — for “kids” who are 24 and 30 and not in school.
• A $500 “dependent” credit for those same grown children.
• $12,029 in medical bills she never had.

Now put it back in the two boxes. This return is a post–Article III act, so it lands in Box A or Box B like everything else: if the contract gave him the call, he owns the fraud; if it didn’t, the whole position is a nullity. And “I didn’t know” doesn’t fly — his own timesheet bills a “letter to client” on October 22, 2024, the day before the return was filed, with the subject blacked out. That’s the difference this whole tab is about: a taxpayer cheating on her own is one thing — tax fraud run through a lawyer who wrote himself into the driver’s seat is another.

Petitioner’s contention from the documentary record — the 2021 return, the Sept 8, 2023 affidavit, Mr. Roen’s timesheet, and the court-filed correspondence (Filing #226901217) — not adjudicated findings. The affidavit listed the $100K as a possible/contingent IRS liability (labeled “2020”); the fraudulent filed return is tax-year 2021. “At Mr. Roen’s direction” rests on the timing and the redacted Oct 22 letter, not an admitted statement.

Every exit is walled · the nine dodges
✗ walled

1. “I was just following my client’s instructions.”

He drafted Article III to negate this — it says he is the determination, not a follower. And ~4 hours of contact cannot have produced granular instructions on a $2.5M action, a tax return, and structured transfers.

✗ walled

2. “Article III governs strategy, not substantive decisions.”

The clause says “the running and handling of the client’s legal matter,” not tactics. Rule 4-1.2(a) reserves objectives to the client; Article III inverts that. Affidavits and tax returns are facts, not strategy.

✗ walled

3. “I didn’t know about the underlying fraud.”

The March 31, 2025 written notice put the scheme on his desk; the $1.4M gold surfaced in his own deposition; and a self-appointed “sole” decision-maker carries a heightened duty of inquiry, not a scrivener’s ignorance.

✗ walled

4. “She signed it. She had capacity.”

Capacity was already in question on the record — Windle declined the representation in 2021 on capacity grounds, and the Aug 15, 2022 plea adjudicated a mental-health-evaluation-and-treatment condition. A retainer provision that conflicts with Rule 4-1.2(a) the way Article III does is void as against public policy, regardless of signature. Chandris, S.A. v. Yanakakis, 668 So. 2d 180 (Fla. 1995). And under settled fiduciary principles, a transaction between a fiduciary and the person owed the duty — executed mid-representation, in the same instrument that raised the fiduciary’s own rate — is presumptively voidable, with the burden of fairness on the fiduciary. Signature triggers the scrutiny; it does not cure the conflict.

✗ walled

5. “Privilege blocks inquiry into all this.”

The crime-fraud exception, §90.502(4)(a), removes the privilege on a prima facie showing the client used the lawyer’s services in furtherance of a crime or fraud — the showing this record makes. (See box below.)

✗ walled

6. “I’ll withdraw and clean my hands.”

Withdrawal is not a time machine: it does not unmake the billing, the Article III period, the filings, or the fee request. And Rule 4-1.16(a) withdrawal is mandatory when continued representation would violate the Rules — so timing the exit now is itself an admission the trigger has fired. It does not escape the predicate; it confirms it.

✗ walled

7. “An independent expert says my fees are reasonable.”

The Petitioner contends the fee expert — Damon Weiss, Esq. — is not arm’s-length: a documented prior Roen–Weiss fund-transfer relationship of record (Broadbent, Filing #195813353) and a contemporaneous motion to disqualify the Weiss firm (Filing #192458931). Without independent reasonableness testimony, the $100,015 fee request is tested against Rosen v. Rosen, 696 So. 2d 697 (Fla. 1997), and §61.16, Fla. Stat.

✗ walled

8. “The husband is vexatious; this is retaliation.”

A party who rested on the record (Conditional Waiver, July 9, 2025) and appears defensively since the Aug 2024 withdrawal does not fit the Rosen “harass / frustrate / delay” factor. The label dies on the docket.

✗ walled

9. “Even if Article III is shaky, she ratified the acts by continuing.”

Ratification requires full knowledge of the material facts — the general Florida rule, stated in Frankenmuth Mut. Ins. Co. v. Magaha, 769 So. 2d 1012 (Fla. 2000) (a public-contract case, cited only for that principle). The concealed-liquidation pattern, the backdated loans, the $1.4M gold account first surfacing at the June 27, 2024 deposition, and the March 31, 2025 notice mean the client never had that knowledge — and the capacity overlay (Dodge 4) forecloses it independently.

The overlay that strips the privilege
Crime-fraud exception — §90.502(4)(a), Fla. Stat.
“There is no lawyer-client privilege … when [t]he services of the lawyer were sought or obtained to enable or aid anyone to commit or plan to commit what the client knew was a crime or fraud.”

The exception turns on a prima facie showing that the client used the lawyer’s services in furtherance of a crime or fraud — and the word in the standard is prima facie, which the other tabs already satisfy. The Petitioner’s contention is that the record supplies it: a retainer placing the attorney in “ultimate determination”; written notice on March 31, 2025 of an ongoing scheme to convert traceable marital assets into untraceable cryptocurrency through a non-reporting bank; and continued billing and filings after that notice, including an ~$800K depletion of the gold position.

Consequence: within its scope, the privilege does not shield the knowledge timeline — so Mr. Roen cannot use privilege to seal off what he knew and when. And on June 3, 2026, Mr. Roen invoked blanket attorney-client privilege over non-privileged source-of-funds questions; that invocation was filed of record the next day (Filing #249628116, June 4, 2026). On counsel’s own words, the communications the privilege is meant to shield are the communications the crime-fraud exception is meant to reach.

The frame that closes the system
Read together, the boxes have no exit: embrace Article III → he owns the agent’s acts; disown it → every substantive filing is a nullity; claim privilege → crime-fraud strips it; claim ignorance → the March 31, 2025 notice rebuts it; claim consent → the mid-stream-amendment doctrine and the capacity record shift the burden to him; withdraw → withdrawal concedes the predicate. That is not a prima facie case. The Petitioner’s contention is that it is a closed system.

The same analysis is set out in the Petitioner’s Prima Facie at § 26.12 (the Principal/Agent Umbrella) and the § V-E 35-row attribution map.

Sources & authorities: Jan 22, 2024 Contract for Legal Services, Art. III (verbatim); Fla. Bar Rules 4-1.2(a),(d) & 4-1.16; Nehleber v. Anzalone, 345 So. 2d 822 (Fla. 4th DCA 1977); Bursten v. Green, 172 So. 2d 472 (Fla. 2d DCA 1965); Chandris, S.A. v. Yanakakis, 668 So. 2d 180 (Fla. 1995); Doe v. Evans, 814 So. 2d 370 (Fla. 2002) (general fiduciary-duty principle; a clergy case, cited only for that principle); §90.502(4)(a), Fla. Stat. (crime-fraud); Rosen v. Rosen, 696 So. 2d 697 (Fla. 1997) & §61.16, Fla. Stat. (fees). Case citations and the statute text were verified against public legal databases. Everything on this page is the Petitioner’s legal theory and contentions — argument, not adjudicated findings — and is not legal advice.

The Children’s Money — a $506,963 college fund, and five versions of whose money it was

Two college-savings accounts — 529 plans set up for the parties’ two daughters, seeded by the children’s grandfather in 2007 and funded by the Petitioner — were emptied into the mother’s personal checking account in February and March 2021. The figures below are printed on the Truist #4011 bank statements; the quotations are verbatim from the depositions, Mr. Roen’s correspondence, and his filing. The Petitioner’s contention is narrow: the money was the children’s, and Mr. Roen described it differently each time the description mattered.

On June 7, 2023 Mr. Roen spoke of the 529 money as still “the children’s … to be used for child purposes.” The bank statements show both accounts had already been emptied 821 days earlier. Over the next twenty months his characterization shifted — to “all hers,” to a question his client could not answer, to “the accounts have been closed” — but never back to a straight answer about whose money it was.
The fund, and what left it — from the bank record
2007·12·10

The grandfather’s seed gift

Check #3873 from the Petitioner’s firm, memo “Ramjass Seereeram gifts to [the two daughters].” Establishes the 529s as the children’s — funded by the grandfather and the Petitioner, not marital cash.

2021·02·17

Elder daughter’s 529 — emptied

Truist #4011 statement line: “Electronic/ACH Credit — Vgi 529 ACHDeposit ****6364,” $287,307.17, into the mother’s personal checking.

2021·03·08

Younger daughter’s 529 — emptied

Statement line: “Electronic/ACH Credit — Vgi 529 ACHDeposit ****6423,” $219,655.92. The same week, jewelry charges clear from the same account.

Total withdrawn from the two children’s college funds: $506,963.09 — printed on the #4011 statements, by date and source account number. (At his deposition the Petitioner rounded this to “$509,000.”)
Five versions of whose money it was
12023·06·07

“It is the children’s … used for child purposes” — intact

“…not sure what the purpose of the children’s money being taken from the 529 plan and put into an IRA — especially if the parties are agreeing that it is the children’s and will be used for child purposes…”Hal Roen, settlement correspondence, June 7 2023 — 821 days after both accounts were emptied.
22024·04·01

“They’re all hers”

“She’s — if you have specific questions about any of the transactions, go ahead… but she’s given you carte blanche — they’re all hers.”Hal Roen, Charmaine Saith Deposition, Apr 1 2024 — on the #4011 account that received the 529 deposits.
32024·06·27

Blocks the question

“I’ll object. That calls for a legal conclusion… You can answer it if you are able.”Hal Roen, Charmaine Saith Deposition, Jun 27 2024 — objecting each time the witness was asked whether the 529s were the children’s or gifted to them.
42024·06·27

“Not available to be used by Ms. Saith?”

“…who has — what authority has determined that the 529 moneys were not available to be used by Ms. Saith?”Hal Roen, deposing the Petitioner, Jun 27 2024. The Petitioner’s answer: “They belong to the children. They never belonged to her.”
52025·02·24

“The accounts have been closed … subpoena it yourself”

“Wife does not have access to any 529 Account statements as the accounts have been closed. Husband may certainly Subpoena said records from any account holder at his own cost.”Hal Roen, Wife’s Response to Notice to Produce, Filing #217445521, Feb 24 2025 — conceding closure, disclosing no location or records.
How Roen was paid — from the same #4011 account

Two $10,000 checks paid Mr. Roen, both drawn on the same SunTrust account ending #4011 — the account that received the children’s 529 deposits, titled jointly in the elder daughter’s name.

2022·08·30

Check #3688 — $10,000 to Hal Roen

Drawn on SunTrust account ending #4011. This payment predates Mr. Roen’s June 7 2023 concession — included for completeness, not for the knowledge point.

2024·02·05

Check #3812 — $10,000 to Hal Roen, memo “retainer”

Same #4011 account; endorsed “For Deposit only … HAL ROEN PA.” This payment lands eight months after Mr. Roen called the funds “the children’s” (June 7 2023) and three weeks after the Jan 12 2024 civil complaint that detailed the 529 conversion.

The Petitioner’s contention. Under Florida’s lowest-intermediate-balance rule (Wiand v. Lee; In re Bifani), commingling is not a cleansing event — disbursements from an account funded substantially with converted funds are traceable, in proportion, to the tainted portion. The Petitioner contends Mr. Roen accepted fees traceable, under that rule, to funds he acknowledged in June 2023 were the children’s converted 529 proceeds — the knowledge supplied by his own statement, the tracing by the #4011 records and these canceled checks. Because the engagement is a divorce, not a criminal defense, the narrow § 1957(f)(1) fee safe harbor does not apply. Whether this occurred, and in what amount, is a question for forensic accounting and the court — it is not adjudicated here.

Sources: Truist #4011 account statements (Exhibits 1–2, May 8 2025 Crime-Fraud-Exception Hearing); canceled checks #3688 (Aug 30 2022) and #3812 (Feb 5 2024) payable to Hal Roen, drawn on SunTrust #4011; grandfather’s check #3873 dated Dec 10 2007 (Exhibit 15); Charmaine Saith Depositions (Apr 1 2024; Jun 27 2024); Devanand Seereeram Deposition (Jun 27 2024); Hal Roen settlement correspondence (June 7 2023); Wife’s Response to Notice to Produce (Filing #217445521, Feb 24 2025). Legal framework: Fla. Stat. §§ 812.019, 896.101, 90.502(4)(a), 90.803(18); Fla. Bar Rules 4-1.2(d), 4-1.15, 4-8.4, 5-1.1; Caplin & Drysdale v. United States, 491 U.S. 617 (1989); Wiand v. Lee, 753 F.3d 1194 (11th Cir. 2014). All quotations are verbatim from the record; check numbers, account numbers, and dates are printed on the instruments and statements. Everything on this page is the Petitioner’s contention drawn from the documentary record — not adjudicated findings — and is not legal advice. The children are not named.

The $1.4 Million Omission — the affidavit Hal Roen drafted, and what it left out

On September 8, 2023, Mrs. Saith filed her sworn Family Law Financial Affidavit (Long Form) over Mr. Roen’s certificate of service. His own billing shows he built it personally across three work sessions that August (08/07, 08/17, 08/31). The document swore to $0 monthly income, listed the joint Truist #4011 checking at just $4,703, and marked $0 in liabilities. On the same day it was signed, the Petitioner’s forensic reconstruction from her own bank records shows she held, off the affidavit, on the order of $1.4 million in gold plus more than $1.3 million in other moved funds.

The omission was not caught by Mr. Roen’s drafting, by his client’s oath, or by any later “supplement.” It was caught by the Petitioner the night before the October 17, 2023 mediation, reading the storage-fee lines on her own statements. The gold account did not surface on the record until her June 27, 2024 deposition — at $1,411,644.82, which she testified was “all marital.” Between September 2023 and that deposition, the affidavit was never amended to add it. The Petitioner’s contention is that an affidavit counsel drafted from his client’s own worksheet, omitting a seven-figure marital asset and left uncorrected for months after the omission was exposed, is not an inadvertent error.
How the hidden gold was proven — off her own bank statements

The gold account (APMEX #2225707) appears on no affidavit. It did not have to. APMEX bills a small quarterly storage fee — about 0.12% of the metal it holds — and that fee posts as a line item on Mrs. Saith’s own Truist #4011 statements. The holdings reverse-solve directly from the fee:

stored gold  =  storage fee  ÷  0.0012 The Feb 28, 2022 storage charge of $1,599 ÷ 0.0012 ≈ $1.33 million in gold then on deposit — recovered with no cooperation from the affidavit at all.

The purchase side confirms the same scale, independently: $1,120,777 into APMEX gold Feb–Nov 2021 (about 614 oz), $717,000 in a single month (Nov 2021), total purchases over $1.4 million through Jan 2022, plus more than $90,000 in gold jewelry. Two independent methods — the storage-fee back-solve and the purchase tally — land on the same figure the deposition later confirmed to the penny: $1,411,644.82.

What the affidavit hid — the Petitioner’s reconstruction
Vanguard + Fidelity moved out and converted to gold$1,338,963.09
Cash withdrawn from communal funds$107,925.00
Debit-card spending on personal use (jewelry, dance, clothing)$29,231.09
IRS refund retained$25,000.00
Residence / household expenses charged to communal funds$118,498.65
Total documented claim≈ $1,821,274.52
!2023

Liquid gold cash-outs around the signing — still left off

Two gold liquidations to cash cleared just before the affidavit was sworn: Aug 1, 2023, ≈$19,400 and Sep 12, 2023, ≈$19,200 — four days after the affidavit. Cash proceeds in hand at signing, not listed. The clearest single indication, the Petitioner contends, that the omission was not an oversight.

The other half — the IRS line the same affidavit did fill in

The gold was what the affidavit left out. Here’s what it put in. On the very same sworn form (page 11), under “possible liabilities,” Mr. Roen’s affidavit carried one tax entry — “IRS 2020 — $100,000” — and marked $0 in actual liabilities. That was the entire tax disclosure. No mention that Mrs. Saith had stopped filing returns, and no hint that roughly $923,000 of 2021 income was sitting unreported.

Sworn on the affidavit (Sept 8, 2023):  a “possible” IRS bill of  $100,000 Actually filed a year later (Oct 23, 2024):  tax paid  $13,316 A vague six-figure “maybe” on the affidavit — then, once a return was finally filed under Mr. Roen’s direction, a fake one that paid $13,316 on close to a million dollars of income. The affidavit didn’t overstate the tax problem or understate it — it papered over it.

This is why it sits in crime-fraud territory, not “sloppy paperwork.” The same lawyer touched both ends of the tax thread: he drafted the affidavit that shrank a felony-scale tax fraud into a $100K footnote (Aug 2023), and a year later the fraudulent 2021 return was filed on his watch (Oct 2024). The full breakdown of that return — the phantom “Hurricane Sally” disaster claim and the rest, $762,056 of it, now in the court record at Filing #226901217 — is laid out in Tab 13 (Beyond Prima Facie).

The $100,000 was listed as a possible/contingent liability, labeled “2020”; the fraudulent filed return is tax-year 2021. “Under Mr. Roen’s direction” is the Petitioner’s contention from the timing and a redacted Oct 22, 2024 client-letter entry on Mr. Roen’s own timesheet — not an admitted statement.

Discovered, surfaced, never corrected
2023·10·17

Discovered the night before mediation

Reading the APMEX storage-fee lines on her own statements, the Petitioner identified the concealed gold the night before the Oct 17, 2023 mediation and presented the first evidence of dissipation there. Mediation reached total impasse.

2024·06·27

Surfaced at deposition — “all marital”

Read directly off the account statement marked as Exhibit 2: “$1,411,644.82.” Asked why it had not been disclosed earlier: “…spoke to Hal about certain things and he showed me everything is going to be okay.”Charmaine Saith Deposition, June 27 2024, Tr. p. 47–48 (Mr. Roen present and on the record).
2023→2024

The affidavit was never amended

No amended Long-Form affidavit adding the gold was ever filed after the omission was known. Under Florida’s continuing duty to supplement mandatory financial disclosure, the Petitioner contends the September 2023 affidavit was not a one-time event but a sworn filing left false and uncorrected through the period Mr. Roen pursued fees, contempt, and incarceration.

The Petitioner’s contention. An affidavit prepared by counsel across three documented work sessions, from the client’s own financial worksheet, that nonetheless omits a seven-figure marital asset provable from the client’s own produced statements — and that is never corrected once the omission is exposed — is, in the Petitioner’s contention, the prima facie signature of a knowingly false sworn filing, not an inadvertent omission. Whether it was knowing, and to what consequence, is a question for the court. It is not adjudicated here.

Sources: Mrs. Saith’s Family Law Financial Affidavit (Long Form), filed Sept 8 2023 (Filing #181387486), over Mr. Roen’s certificate of service; Mr. Roen’s billing entries of Aug 7, 17, 31 2023; Truist #4011 account statements and the APMEX storage-fee lines (annotated in the Petitioner’s Financial Claim Against Charmaine Saith, Vols. 1–2; pattern analysis Vol. 4); APMEX Account #2225707 statement marked Petitioner’s Exhibit 2 (June 27 2024 deposition); Charmaine Saith Deposition (June 27 2024, Tr. 47–48). The 0.12% / ÷0.0012 storage-fee method is the Petitioner’s forensic reconstruction, to be corroborated against the APMEX fee schedule of record. All dollar figures are the Petitioner’s computation from produced records; the $1,411,644.82 deposition figure is read verbatim from Exhibit 2. Everything on this page is the Petitioner’s contention drawn from the documentary record — not adjudicated findings — and is not legal advice. The children are not named.

179 Days in Jail — how “I’m not seeking sanctions” became a demand for 179 days behind bars

On June 23, 2026, Mr. Roen asked the Court to jail Devo for 179 days. Six months earlier, on the record, he said he was not seeking sanctions for Devo’s absence — because it made the hearings go faster. Between those two dates, the demand escalated from nothing to one day short of six months — against a man who had already withdrawn his petition, waived his appearance, and filed a certificate of compliance with the very order the jail request is built on.

Dec 9, 2025 — on the record:
“And I’m not seeking sanctions for his failure to appear because him not being here causes the hearings with you to go much quicker.”Mr. Roen — CMC transcript, Dec 9 2025, p. 9:16–19
179
DAYS JAIL
June 23, 2026 — six months later:
“Wife seeks from this Court an order incarcerating Husband in the county jail for 179 days or until the terms of a purge can be complied [with].”Wife’s Motion for Contempt, Filing #251014916, June 23 2026
Where it started — what Devo filed first (Oct 2025)

The contempt cycle did not begin with any misconduct by Devo. It began five days after he filed a motion for summary judgment that would take the Trust out of the marriage entirely — and with it, the premise of Mr. Roen’s three years of litigation.

Oct 242025

Devo — Motion for Summary Judgment: the Saith-Seereeram Family Revocable Trust is non-marital #234370168

A dispositive motion that, if granted, removes the Trust from the marital estate altogether — and with it the premise of the injunction. This is the filing that changes the stakes: if the Trust is non-marital, three years of litigation against it collapses.

Oct 292025

Wife / Roen — Motion for Contempt #234677231

Five days after the MSJ, the first contempt motion arrives — asserting Devo failed to produce financial documents. (His own sworn timesheet had already billed for reviewing documents “provided by husband on 2nd flash drive” — see the Lack of Candor tab.)

December 9, 2025 — the pivot
Dec 92025

Court reserves; Roen expressly declines sanctions

“And I’m not seeking sanctions for his failure to appear because him not being here causes the hearings with you to go much quicker.”Mr. Roen, CMC transcript Dec 9 2025, p. 9:16–19

The Court ordered production (bank statements 7/1/23–10/2025) and reserved on any sanction. As of that hearing, counsel was on record wanting no sanction and treating Devo’s non-appearance as a convenience.

The escalation — no sanctions → 179 days
Dec 9 ’25
No sanctions
“I’m not seeking sanctions… him not being here causes the hearings to go much quicker.”
Dec 11 ’25
Arrest + 48 hrs
Counsel’s Notice of Hearing (#240048085) warns of “a writ of bodily attachment for your arrest” and 48-hour jail — language attributed to “THE COURT”; at the Feb 9, 2026 hearing the judge said she had not authorized it.
Jan 16 ’26
Retaliatory contempt
A second contempt motion (#239652607) filed within 95 minutes of Devo’s Notice of Attorney Lack of Candor (Prima Facie Predicate 19).
Feb 4 ’26
Writ of bodily attachment
Wife’s Motion for Issuance of Writ of Bodily Attachment (#240962066) — formal machinery for an arrest.
Jun 23 ’26
179 days jail
Motion for Contempt (#251014916): incarcerate “in the county jail for 179 days or until the terms of a purge can be complied” — plus a standing weekly case-management conference so the Court may “more closely monitor” the case — for contempt of the March 5, 2024 Trust injunction, the same order Devo had moved to declare void. 179 is one day short of six months.
Why 179 — and not 180

The number is not arbitrary. Criminal contempt is a crime like any other: when the punishment runs more than six months the accused has a constitutional right to a jury trial; at six months or less the charge is “petty” and a single judge decides it alone. Bloom v. Illinois, 391 U.S. 194, 201–02 (1968); accord Aaron v. State, 284 So. 2d 673 (Fla. 1973). 179 days is one day under that line — the most jail a court can impose for criminal contempt without ever empaneling a jury.

The “or until the terms of a purge can be complied with” clause does not open the jury door — it bolts it from the other side. A sanction a person can end by complying is civil coercive contempt, and civil contempt carries no jury right at any length, because the contemnor is said to “hold the keys to the jail.” Int’l Union, UMWA v. Bagwell, 512 U.S. 821, 827–29 (1994). So read as civil, the request reaches no jury because civil contempt never does; read as criminal — a fixed 179-day term — it reaches no jury because 179 is under the six-month line. Drafted as both at once, it forecloses a jury under either characterization.

Capped and conditioned that way, the matter never reaches a jury. None is empaneled — so none is shown the sworn timesheet, the financial data, or the de-facto guardianship. It is the most incarceration that can be demanded while keeping that door shut.

Nor is this obscure law to the lawyer who wrote the motion. Contempt is the family-law bar’s everyday enforcement tool, and the six-month cap is the guardrail it drafts against — the Florida Supreme Court’s own leading example of where the jury line bites is “domestic relation matters.” Aaron v. State, 345 So. 2d 641, 643 (Fla. 1977). A number like 179 — not “six months,” not “180” — is one a fifty-year practitioner arrives at on purpose, by subtracting a single day from the line.

Petitioner’s contention. 179 is a deliberate figure — the maximum jail counsel can seek while keeping the entire record before a single judge rather than a jury of the community. Whether any contempt occurred, and how the motion should be characterized, is for the Court; nothing here is an adjudicated finding.
What makes the demand extraordinary
Aug 72024

Devo withdrew his Petition #204182415

He is not the one seeking relief from the court.

Jul 92025

Devo filed a Notice of Conditional Waiver of Appearance #226936923

His non-attendance is not defiance — it is a waiver of record, the very absence Roen called a convenience on Dec 9, 2025.

Mar 82024

Devo complied with the Trust order

He filed a Certificate of Compliance within the order’s five-day window; the Court entered no finding that the Trust’s terms or status were ever altered. The order enjoined altering a trust, not ordinary spending from a personally-titled account.

Whosetrust

The escalation follows Devo telling the Court the Trust’s only beneficiaries are the two children

The 179-day motion seeks contempt of the March 5, 2024 injunction over the Saith-Seereeram Family Revocable Trust. Devo placed on the record that the Trust’s only beneficiaries are the parties’ two children — a trust that runs to the children, not to either spouse. The incarceration demand intensified after that point was made.

Neverruled

Two motions would pull the Trust out of the marital estate — no order has been entered on either

Two of Devo’s filings would remove the Trust from the divorce entirely: the Motion to Declare the March 5, 2024 Order Void for Lack of Subject-Matter Jurisdiction (#233817170, Oct 16, 2025) and the Motion for Summary Judgment that the Trust is non-marital (#234370168, Oct 24, 2025). No written order has been entered on either. The void motion sat unruled for 207 days; the summary-judgment motion was orally denied on Feb 9, 2026 — with the Court stating it had not reviewed the motion or the response — yet was never reduced to a signed order, so under Florida law the Trust’s marital / non-marital status remains unresolved. Mr. Roen has litigated the Trust as a marital asset across the roughly four-year dissolution fight, and now seeks 179 days’ jail on that same unresolved foundation.

¶4concedes

The motion complains of an account it admits is not the Trust’s

The order enjoined altering the Trust. The motion alleges Devo moved funds in Vanguard #5872 — yet its own ¶4 concedes #5872 is titled solely to “Devanand Seereeram” individually, not to the Trust. The one account the order actually governed (#0112) the motion concedes was down to $1.00 by Dec 31, 2021 — before the petition and before the order existed. A trust-injunction contempt built on a non-Trust account reaches conduct the order does not.

The larger picture. A demand to jail a litigant for six months is the most serious relief short of trial. Here it escalated — from counsel’s own on-record statement that he sought no sanction, to a request for 179 days — against a party who had withdrawn his petition, waived his appearance of record, and complied with the order in question, and while that order’s validity sits unresolved. Petitioner contends the incarceration campaign functions as coercion and retaliation, not enforcement. Whether any contempt occurred is for the Court; nothing here is an adjudicated finding.

Sources: Wife’s Motion for Contempt (Filing #251014916, June 23 2026); CMC transcript, Dec 9 2025 (Landmark Reporting, Inc.), p. 9; Cross-Notice of Hearing (Filing #235800311, Nov 14 2025, enumerating the Oct 2025 motion sequence); Wife’s Motion for Contempt (#234677231, Oct 29 2025); Retaliatory Contempt Motion (#239652607, Jan 16 2026); Notice of Hearing (#240048085); Wife’s Motion for Issuance of Writ of Bodily Attachment (#240962066); Devo’s Notice of Withdrawal of Petition (#204182415, Aug 7 2024); Notice of Conditional Waiver of Appearance (#226936923, July 9 2025); Order Enjoining Husband … (Filing #193295225, March 5 2024, Judge Tennis) and Certificate of Compliance (March 8 2024). Legal framework: Bloom v. Illinois, 391 U.S. 194 (1968); Int’l Union, UMWA v. Bagwell, 512 U.S. 821 (1994); Aaron v. State, 284 So. 2d 673 (Fla. 1973) and 345 So. 2d 641 (Fla. 1977); Fla. R. Crim. P. 3.840; § 38.22, Fla. Stat. All quotations are verbatim from the cited record; filing numbers and dates are from the Florida Courts E-Filing Portal. Everything on this page is the Petitioner’s contention drawn from the documentary record — not adjudicated findings — and is not legal advice.

Sealing the Record — how evidence of the judge’s own ethics violations was almost hidden, with counsel’s help

Every other tab on this site documents Mr. Roen’s conduct toward his client, the opposing party, or a witness. This one is different in kind. On August 12, 2024, a pro se litigant put primary-source evidence of the presiding judge’s own Canon 7 political-contribution violations into the public court file. Two hours and forty-five minutes later, Wife’s counsel moved to seal it — “for the protection of the judicial branch.” The next morning, in chambers and without a hearing, the judge “reserved” that sealing motion for trial in the very same order that refused to step aside — a disposition that, by rule, made the record presumptively confidential without any finding at all. Nearly two years later, the Florida Supreme Court answered the question of how serious that buried record was.

August 12–13, 2024 — what was attempted

Counsel moved to seal the litigant’s FEC-sourced Canon 7 evidence; the presiding judge — whose own contributions were the subject — reserved the seal for trial and denied recusal in one two-line order.

July 2, 2026 — what the Supreme Court found

The Florida Supreme Court rejected the agreed public reprimand as too lenient, holding it “would impose a suspension and fine” on Judge Tennis for that same contribution conduct.

The two-hour, forty-five-minute sequence
Aug 129:48 AM

Devo files his Final Motion to Recuse Judge Tennis — Canon 7 violations #204482114  [open the original PDF]

The motion documents, from primary-source FEC data, 913 political contributions totaling $29,154.76 (Jan. 26, 2017–Jan. 31, 2021) made in the judge’s own name, occupation listed “JUDGE,” employer “STATE OF FLORIDA” — the largest documented sitting-judge violation of Florida Code of Judicial Conduct Canon 7A(1)(e) in the public record. It was the third recusal motion; the prior two were denied “legally insufficient.”

Aug 1212:33 PM

Roen moves to seal it — 2 hours 45 minutes later #204508525

The motion asks that the filing “be sealed… to prevent public access” under Fla. R. Jud. Admin. 2.420(c), “for the protection of the judicial branch,” calling Devo’s motion an “unnecessary, unwarranted and shameless diatribe” offered up for “titillating reading.”Motion to Seal, Filing #204508525, Aug 12 2024  [open the original PDF]

The motion identifies none of the confidential-record categories Rule 2.420(c) enumerates, no statute, and no compelling interest — only that public criticism of a sitting judge, drawn from public FEC data, should itself be hidden.

Aug 1310:53 AM

Judge Tennis, in chambers, no hearing — one order, two rulings #204590429

“The Motion to Seal filed 8/12/2024 is RESERVED FOR TRIAL. The Motion for Reconsideration filed 8/12/2024 is DENIED.”Order on Outstanding Pleadings, Filing #204590429, Aug 13 2024  [open the original PDF]

In a single instrument the judge (a) refused to step aside from a case now containing evidence of her own violations, and (b) took the one step that shielded that evidence from public view.

Aug 15~10:00 AM

The letter is hand-delivered to the Chief Judge

Devo delivered a letter to Chief Judge Lisa T. Munyon setting out the contribution record and attaching a printout together with a step-by-step guide for verifying it on the Federal Election Commission website. 913 contributions totalling $29,154.76 between January 26, 2017 and January 31, 2021 — a span of 1,466 days. That is one political contribution every 1.6 days, for four years, averaging $31.93 each. Not a handful of cheques; a standing arrangement running continuously while she presided.

Aug 1512:23:51 PM

Judge Tennis grants the disqualification she had denied forty-seven hours earlier — 2 hours 24 minutes after delivery #204794462

“The Motion for Reconsideration is GRANTED. The Motion for Disqualification is GRANTED. This case will be re-assigned.”Amended Order on Motion for Reconsideration Filed 8/12/2024, Filing #204794462, Aug 15 2024 — signed Judge Diana M. Tennis, Circuit Judge  [open the original PDF]

Three sentences, over her own signature. No findings, no reasons, no hearing — and nothing had happened in the case since the Aug 13 denial. No new motion, no new filing, no argument. The only intervening event was the letter. Note also the form: this is an amended order. A judge who reconsiders enters a new order and explains why; amending the original replaces the denial rather than reversing it.

Aug 1512:28:50 PM

The administrative reassignment follows — five minutes and nine seconds later #204795117

An Order of Reassignment for Unified Family Court, signed by the Administrative Judge, moved the case from Div 38 to Div 31 under Fla. Fam. L.R.P. 12.003 and cancelled all hearings previously set. The stated ground is routine consolidation; it mentions neither recusal nor the order entered five minutes before it. The reassignment executed Judge Tennis’s own disqualification order — it did not substitute for one.  [open the original PDF]

The rest of the seal motion — in his own words

The “shameless diatribe” line is not the only one. Mr. Roen titled the motion, in his own running footer, “Motion to Protect Judiciary and to Seal” — and the body escalates from there. Each quotation below is verbatim from Filing #204508525.

“Were it not for the protections of filings in legal proceedings to be beyond a person being held responsible for defamation and spewing false and venomous statements, he otherwise would be subjecting himself to a civil suit for damages.”Motion to Seal ¶6 — Filing #204508525, Aug 12 2024
“Husband has filed and put into a public record a document full of irrelevant and mean-spirited allegations that attack one of our basic foundations of this society – the judiciary.”Motion to Seal ¶7
“Husband’s filing is irrelevant, disrespectful, and accomplishes nothing more than his displeasure and mere venting. There is no need to have the judicial system lowered to his childish and boorish conduct. No good will come to anyone to allow this pleading to remain available for viewing by anyone who should choose to read it.”Motion to Seal ¶9

The record those paragraphs dismiss as “childish and boorish” venting is the same 913-contribution Canon 7 record the Florida Supreme Court would later find warrants a suspension and fine. The motion never engages the data — it asks only that the public not be allowed to see it, and threatens a defamation suit for the attempt.

The mechanism — how “reserved” quietly becomes “sealed”

A motion to seal that is denied leaves the record public. A motion to seal that is “reserved” does something else. Under Fla. R. Jud. Admin. 2.420(d)(1)(B), the clerk may presume that a confidentiality motion not yet ruled upon will be granted, and may treat the record as confidential until further notice. By reserving — rather than denying — a motion that fell outside every category the rule allows, the disposition converted the evidence of the judge’s own Canon 7 conduct into a presumptively confidential record: no order of sealing, no findings, no hearing — the shielding accomplished by the joint operation of counsel’s motion and a two-line order.

The Supreme Court’s answer — July 2, 2026

The Judicial Qualifications Commission investigated and confirmed the same 913-contribution pattern, and the parties agreed to a public reprimand. On July 2, 2026, the Florida Supreme Court refused to accept it:

“The Court rejects the Stipulation and disapproves the proposed sanction. In addition to the public reprimand agreed to in the Stipulation, the Court would impose a suspension and fine. Should the parties agree to the imposition of a suspension and fine in addition to a public reprimand, a revised… Stipulation should be filed with the Court within 30 days… If the parties do not agree… this case will be returned for a hearing before the Judicial Qualifications Commission.”In re Judge Diana M. Tennis, Fla. Sup. Ct. No. SC2025-1438 (July 2, 2026). Couriel, C.J., and five Justices concur; Tanenbaum, J., dissents.

The significance is narrow and factual: the record Mr. Roen moved to seal “for the protection of the judicial branch” was not a “shameless diatribe.” It documented conduct the State’s highest court has now found serious enough that a reprimand alone will not do — suspension and a fine are warranted.

The rule at the center

The Florida Bar rule most directly implicated is Rule 4-8.4(f): a lawyer “shall not… knowingly assist a judge or judicial officer in conduct that is a violation of applicable rules of judicial conduct or other law.” A sealing motion that requests confidentiality for a judge’s own publicly-documented Canon 7 violations — addressed to that same judge — is, on its operative effect, the conduct that rule describes. The motion also failed to disclose the controlling public-access authorities directly adverse to it — Press-Enterprise II, Richmond Newspapers, Article I § 24 of the Florida Constitution, and Barron v. Florida Freedom Newspapers — implicating Rule 4-3.3(a)(2), and the concealment-of-bias concern engages the impartial-tribunal guarantees of Caperton v. A.T. Massey Coal Co. and In re Murchison.

Petitioner’s contention. The gravest category of lawyer misconduct is not aimed at an opponent — it is aimed at the integrity of the forum itself. Petitioner contends that counsel used a procedural vehicle within his control to help a sitting judge shield public-record evidence of that judge’s own ethics violations, at the same moment the judge refused to step aside. Whether any rule was violated is for the Bar and the courts; the judge’s discipline is the Florida Supreme Court’s to decide, and its July 2, 2026 order speaks for itself. Nothing here is an adjudicated finding as to Mr. Roen.

Sources: Devo’s Final Motion for Reconsideration of Recusal (Filing #204482114, Aug 12 2024) — PDF; Roen’s Motion to Seal (Filing #204508525, Aug 12 2024) — PDF; Order on Outstanding Pleadings (Filing #204590429, Aug 13 2024) — PDF; Amended Order on Motion for Reconsideration granting disqualification (Filing #204794462, Aug 15 2024) — PDF; Order of Reassignment for Unified Family Court (Filing #204795117, Aug 15 2024); In re Judge Diana M. Tennis, Fla. Sup. Ct. No. SC2025-1438, order of July 2, 2026. Legal framework: Fla. R. Jud. Admin. 2.420(c)–(d); Fla. Code Jud. Conduct Canon 7A(1)(e); R. Regulating Fla. Bar 4-8.4(f), 4-3.3(a)(2); Press-Enterprise Co. v. Superior Court, 478 U.S. 1 (1986); Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555 (1980); Barron v. Florida Freedom Newspapers, Inc., 531 So. 2d 113 (Fla. 1988); Caperton v. A.T. Massey Coal Co., 556 U.S. 868 (2009); In re Murchison, 349 U.S. 133 (1955); Art. I § 24, Fla. Const. All filing numbers and quotations are from the Florida Courts E-Filing Portal and the cited order. Everything on this page is the Petitioner’s contention drawn from the documentary record — not adjudicated findings — and is not legal advice. The subject of this record is Mr. Roen; the judicial-discipline findings are those of the Florida Supreme Court.

Exhibit: The Illusion of Disparity

How a two-year-old financial affidavit was placed into evidence to create a false impression of disparity — by the one lawyer who already knew, from a deposition he took himself, that it was incomplete.

1 · The old affidavit, entered by the Wife’s counsel

On September 3, 2025, the Wife’s counsel (Mr. Roen) submitted the Wife’s Financial Affidavit filed 9/8/2023 into evidence as Exhibit 3.

The Clerk’s own Evidence Control Sheet records it, below.

The affidavit relied upon was two years old at the moment it was entered.
2 · Assets disclosed at deposition (6/27/2024)

At her June 27, 2024 deposition, the Wife testified to assets the 9/8/2023 affidavit does not reflect.

“$1,411,644.82.” “All of it is marital.” Dep. 6/27/2024, p. 48 — the APMEX precious-metals account balance
“Well, I put 50,000.” “50,500, sorry. 50,500.” Dep. 6/27/2024, p. 67 l. 24 & p. 68 l. 1 — the Prosperity For Life, LLC investment, corrected by the witness to $50,500
Both figures were known to the Wife’s counsel as of June 27, 2024 — fourteen months before he entered the 2023 affidavit.
3 · Assets not reflected in the 9/8/2023 affidavit
Asset / accountAmountReflected?
APMEX gold account (precious metals)$1,411,644.82NO
Prosperity For Life, LLC investment$50,500.00NO
Disclosed at that deposition, absent from the affidavit$1,462,144.82
Over $1.4 million on the gold account alone. This figure is not a complete accounting — it is only what the Wife disclosed at the June 27, 2024 deposition. Further accounts surfaced later (see below).
4 · The result — an illusion of disparity

By relying on the outdated 9/8/2023 affidavit, counsel presented a picture of the Wife’s finances that omits assets she had already sworn to.

What was presented
Affidavit dated
9/8/2023
omits $1,462,144.82
≠
The sworn record
Assets omitted
$1,462,144.82
per her own deposition

The document itself — the Clerk’s Evidence Control Sheet

Evidence Control Sheet, Seereeram v. Saith, filed in open court September 3, 2025 - Exhibit 3, Respondent's Financial Affidavit filed 9/8/2023
Evidence Control Sheet · Case 2023-DR-4193-O · Date 9/3/2025 · Trial Clerk F. Santos · Judge/Division L. Jackson / 31 · filed in open court, Tiffany M. Russell, Clerk of Circuit Court, Orange County. Exhibit 3 — “Respondent’s Financial Affidavit filed 9/8/2023.”  [open the original PDF]

Funding trail — how the gold account was funded

The $700,000 and the gold account are the same money, not two separate assets. The total omitted is therefore $1,462,144.82 — the gold balance plus the separate LLC investment.

October 2021
$700,000
Moved from the joint Vanguard account to a joint Fidelity account, per the Wife’s testimony.
Dep. 6/27/2024, pp. 15–16
Same money, plus →
$1,411,644.82
APMEX gold-and-silver account. The Wife testified it was funded with that $700,000 together with cashed-out retirement funds — about $100,000 at Fidelity and about $176,000 at Mason Power. The $700,000 is therefore inside this balance, not additional to it.
Dep. 6/27/2024, p. 48 & p. 49 ll. 12–21
Additional asset
$50,500.00
Prosperity For Life, LLC — a separate investment acknowledged at deposition; a 10% annual return “until 2030” and an acre in a planned lamasery.
Dep. 6/27/2024, pp. 66–68

Counsel held the documentation — in her own words

Asked at the same deposition about the $700,000 moved to Fidelity, the Wife testified that the Wife’s counsel already had the paperwork:

“And Mr. Roen has that documentation should he need to provide it.” Dep. 6/27/2024, p. 16 ll. 9–10

What arrived after the sixteen-minute break

The disclosure did not come voluntarily. It came after opposing counsel stopped the deposition to confer privately with his client — and it arrived attached to the accusation that the husband beats his wife. Asked what she was afraid of: “he can be violent.” Asked “Towards you?” — “Yes.” That is an accusation of spousal violence, and it was offered as the reason the $1.4 million had never been disclosed. It is false. Four pages later in the same transcript, the witness gave a different reason — and called it “the real reason.”

10:33 a.m. — the question, then the break
Asked where her money was held, the Wife said: “Can I tell him this?” The Wife’s counsel answered: “Can I have a few minutes with my client?” The parties went off the video record. Dep. 6/27/2024, p. 45 ll. 11–25; p. 46 ll. 1–4
10:49 a.m. — back on the record, sixteen minutes later
The Wife’s counsel announced: “I’ve been authorized by my client to provide to you this summary that shows… the location of her moneys.” He handed over the APMEX statement himself. It became Exhibit 2. Dep. 6/27/2024, p. 46 ll. 5–20; p. 47 ll. 2–5
Then the number — and the explanation for hiding it
“1,411,644.82.” — “All of it is marital.” Asked why it had not been disclosed at the first deposition, the answer was: “I’ve been afraid of my husband because of his behavior, so I’ve become — spoke to Hal about certain things and he showed me everything is going to be okay.” Asked what she was afraid of: “He’s irrational, he can be violent, you know, and I’m living right next door.” Dep. 6/27/2024, p. 48 ll. 11–22
And then it was dropped
The next question was “Towards you?” — answered “Yes.” The examination then returned immediately to account withdrawals and never came back to it. The accusation was never developed, never documented, and never revisited. Dep. 6/27/2024, p. 48 l. 25 – p. 49 l. 7
Four pages later — “the real reason”
Asked why she had moved the $700,000 out of the joint account, the same witness gave an account with no violence in it at all: “After he called the police and the FBI twice, I became really afraid of him and I needed to protect myself, and this is the way that I did it. That’s the real reason why I did it.” Dep. 6/27/2024, p. 52 ll. 4–12

Thirty-seven pages earlier, in the same deposition

Before any of this, on page 11 of the same transcript, the same morning, the witness was asked about the first deposition — the one she attended at the husband’s house.

Q. …can you contrast that to you being at his house the last deposition in what appeared to be a very civil, amicable situation? A. …we never got very far in that deposition, but I would have said the same. Q. What I’m referring to is that you were at his house — A. Right. Because I wanted it to go on. Q. Do you — do you live in separate households?  —  A. Yes. Q. And were you-all being civil to each other that day? A. Yes, I can be civil to him. It doesn’t change the fact he’s a demon. Dep. 6/27/2024, p. 11 ll. 3–25
She went to his house by choice — “because I wanted it to go on” — sat through a deposition there that she agreed was civil and amicable, and confirmed on the record that the parties live in separate households. That is page 11. On page 48 she is too frightened of his violence to have disclosed a bank account, and places herself “living right next door.” Same witness. Same transcript. Same morning. Thirty-seven pages apart.

October 15, 2021 — asked by a deputy, on camera, at the time

There is no need to argue about whether the husband was ever violent. Law enforcement asked her directly — in October 2021, the exact period she would later describe as the time she was too afraid to disclose her assets — and it was recorded on three body cameras, synchronised to the same second.

DEPUTY: So… did somebody hit you yesterday? “No. No, nobody hit me.” DEPUTY: Okay, so it was just… verbally… CHARMAINE: He has been verbally abusive, yes. Body-worn camera, October 15, 2021 — second camera 06:51–06:59; first camera 07:01–07:09

Her friend and realtor of twenty-seven years, present throughout, said the same thing to the deputies — twice:

“No, she never said she got hit.” “Somebody called me on the phone saying ‘a battery’ and I said, ‘No, there’s no battery. Where are you getting that?’” Body-worn camera, October 15, 2021 — 07:24 and 07:32

The deputies reached the same conclusion on the spot — “it sounds like a verbal, she never got hit” · “Never got hit” · “We misunderstood. Sorry… we’re confused.” They told her the remedy for verbal abuse was to go to the courthouse and seek an injunction: “one way you can fix that is to go down to the courthouse and get what’s called an injunction.”

She was told by police, on camera, exactly how to obtain a protective injunction — and never obtained one. Not that week. Not in the five years since. Because on the day it was asked and answered — in front of three deputies, a witness, and three body cameras — the answer was “Nobody hit me.” And she did not leave it there: with the deputies she completed and signed a written complaint that day — “Just put right here that you want to prosecute. Initial here, initial here.” A formal complaint was made against the Petitioner on October 15, 2021. It was not a battery complaint, because by her own words to the deputies there was no battery — only what she described as verbal conduct.

It was never just the gold — and counsel’s answer was “subpoena it yourself”

The two items above are simply what surfaced at one deposition. The 9/8/2023 affidavit entered into evidence in September 2025 also does not reflect the accounts that came to light afterwards.

February 28, 2025 — the Petitioner asks
Petitioner serves a Notice to Produce seeking the account records and an explanation of the movement of the precious-metals holdings.
March 17, 2025 — counsel’s answer
The response states that no explaining document exists and that the Petitioner “is certainly able to Subpoena those records from whichever financial institution/account holder… to conduct discovery for his case at his own expense.” Wife’s Response to Notice to Produce, Filing #218955835 — ¶ 15 (and ¶ 7)
Meanwhile — roughly half the sworn gold is liquidated
Per the Petitioner’s March 2025 correspondence citing the APMEX records, $692,388.65 of the $1,411,644.82 sworn to in June 2024 was liquidated in roughly six months, leaving about $719,000 — while the marital case was pending.
October 3, 2025 — seven months later, the rest appears
An Updated Mandatory Disclosure finally produces statements for accounts including Old Glory #3248, Old Glory #9579, Truist #6250, Fidelity #8229 and #1593, Fidelity Crypto #0911, Vanguard #6630 and Amex #2002 — none of them reflected in the 9/8/2023 affidavit that counsel placed into evidence one month earlier, on September 3, 2025.
At the June 27, 2024 deposition the Wife had also volunteered, “I have the Old Glory account that’s only in my name… and I have a business account,” prompting her own counsel to interject: “I’m sorry, what account?” (Dep. 6/27/2024, p. 52) Counsel was therefore on notice of accounts beyond the gold fifteen months before he entered the 2023 affidavit as evidence of her finances.

The position counsel cannot hold both ways

This exhibit is not about the Respondent. It is about the lawyer who had all of this material and chose what to do with it. Mr. Roen has taken two positions in this case, and they cannot both be honest.

Position 1 — his client is reliable
Written to the Petitioner, February 11, 2025: “She has been evaluated by a professional… and found her to not suffer or have the mental issues you complain of. So please stop doing that.” Letter to Dr. Seereeram, Feb. 11, 2025 (see Tab 02)
≠
Position 2 — her accusation stands
In his own deposition, sixteen minutes after he stopped it, his client accuses the Petitioner of violence as the reason a $1.4 million account went undisclosed. Counsel has never corrected it, never withdrawn it, and never produced a document supporting it.
Take him at his word on Position 1 and the accusation collapses — because the same client, asked the direct question by a deputy in October 2021, answered “Nobody hit me,” and described the conduct as verbal. A reliable witness’s own disavowal is reliable too. Abandon Position 1 and a different duty arises: counsel does not build a case on an accusation he cannot vouch for. Either way, the obligation ran to counsel — and either way he did nothing.
The accusation is false — and she said so herself, to police, on camera. No domestic-violence report. No petition for protection. No injunction — though a deputy stood in her driveway and told her exactly how to get one. No arrest. No charge. No finding by any court. When the question was actually put to her, in October 2021, by law enforcement, with her friend beside her and three body cameras running, the answer was four words: “Nobody hit me.” Pressed on what she meant by abuse, she gave the answer herself: “He has been verbally abusive.” A claim that he was physically violent surfaces thirty-two months later, in a deposition, sixteen minutes after her lawyer stopped it — and lasts four lines.
And it took years to appear. She sat for a first deposition on April 1, 2024 — one hundred and twelve pages, under oath, with every opportunity. Search that transcript for “violent.” For “afraid.” For “fear,” “abuse,” “threat.” Not one of those words appears anywhere in it. Not once. Through the separation, the police calls, the pleadings, the affidavits, the first deposition — nothing. Her husband becomes a violent man for the first time on June 27, 2024, in the minutes after the gold had to be produced.
Look at when it arrives. Counsel stops the deposition the instant his client is asked where her money is. Sixteen minutes off the record. They come back, he hands over the $1.4 million statement himself, and the first thing offered to explain why it was hidden is that her husband is violent. Asked to stand it up — “Towards you?” — she says yes, and the questioning moves straight to bank withdrawals. Nobody returns to it. Not that day. Not ever. An accusation of violence that real counsel would chase for an hour was used once, for one purpose, and discarded.
It does not survive its own transcript. On page 11 she confirms the parties live in separate households and that she voluntarily attended the previous deposition at his house — “because I wanted it to go on” — in what counsel called “a very civil, amicable situation,” which she accepted: “Yes, I can be civil to him.” On page 48 she is too afraid of his violence to have disclosed a bank account, and places herself “living right next door” — the parties have not lived in the same city in over six years. And on page 52, asked why she really moved the money, she answers it herself: “After he called the police and the FBI twice… That’s the real reason why I did it.” Not violence. One transcript. One morning.
Understand what a deposition is. It is a transcript — and transcripts are read by judges. The accusation was never taken to a police station, never put in a petition, never carried into a courtroom where it could be tested and would have to be proved. It was placed in the record, in the one form that reaches a judge without ever being cross-examined. Then it was abandoned inside sixty seconds. An accusation you intend to prove, you pursue. An accusation you intend a judge to simply absorb, you say once — on the record — and walk away from.
Painting the husband as a wife-beater is the oldest play in high-asset divorce. It costs nothing to say, it cannot be disproved, and it converts the concealment of seven figures into self-defence. In the compiler’s view of this record, that is precisely what happened here. The responsibility for it is not the client’s. It belongs to the lawyer who called the break, produced the $1.4 million statement from his own file when it ended, sat through what was said next — and who has, to this day, never withdrawn it, never corrected it, and never put a single document behind it.
What this exhibit is not. It is not an attack on the Respondent, and nothing here asks a reader to judge her. Her own words are quoted only because they are the record counsel possessed and the record counsel ignored. The subject of this compilation is the attorney.

Timeline of material events

September 8, 2023
The Wife’s Financial Affidavit is prepared and dated. It does not reflect the $1,462,144.82 in assets.
June 27, 2024
The Wife testifies at deposition, disclosing the APMEX gold account ($1,411,644.82) and the Prosperity For Life, LLC investment ($50,500.00). The Wife’s counsel produces the APMEX account summary showing the $1,411,644.82.
September 3, 2025
The Wife’s counsel submits the 9/8/2023 affidavit into evidence as Exhibit 3 — fourteen months after the deposition at which he learned it was incomplete.
The point. The Wife’s counsel (Mr. Roen) entered the outdated 9/8/2023 Financial Affidavit into evidence — an affidavit he personally knew was incomplete, having produced the $1.4 million gold-account summary himself at the June 27, 2024 deposition — creating a false illusion of disparity.

Every figure above is drawn from the Wife’s own sworn deposition testimony and the Clerk’s Evidence Control Sheet. Prepared: July 24, 2026.