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Questions for Scott Martin 

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As the Associate Dean of Science and Technology at George Mason University you are a paid public employee drawing an approximate annual salary of $169,000.  You also have side contracts with George Mason University and operate multiple LLC's on campus paying you even more. You utilize your position and public resources for your private gain. You rely on public organizations to funnel clients to your private commercial businesses that you operate on public property (re-your email statement to Mr. Platt “they sent you to me").

1. Is any of this incorrect or in dispute?

2. Do you have any special permissions permitting those activities?

3. Absent any special written permissions is there any reason those activities should not be construed as conversion?

4. As those private commercial activities are conducted on campus utilizing public resources and subject to disclosure under FOIA/Public Records Act do you maintain records of your use of public resources for your private gain so as to provide adequate reimbursements? If not, why not?

5. In 2017 did at your suggestion in your Fairfax GMU office enter into a private, paid contract with Mr. Platt to generate work product and arrange and conduct meetings with other governmental workers/officials to further Mr. Platt's business as you were being contractually paid for?

6. Did you enter into a subsequent paid contract with Mr. Platt representing yourself as an expert and patent holder in the field of artificial intelligence relevant to Mr. Platt's revised project scope?

7. Did you represent yourself capable of generating virtual machinery? (See contract for “design, develop and refactor mock (virtual) prototype”)

8. During a teleconference with Mr. Platt where you represented yourself as a giant peach with moving lips did you, after supposedly working on Mr. Platt's behalf for nearly 2 months finally admit to having no knowledge of or expertise in the field of virtual machinery?

9. Were you corrected by your assistant James Casey on at least 2 occasions that what you purported to be a function of artificial intelligence was in fact not a function of artificial intelligence? (James Casey's exact words were “that's not AI")

10. Your single and sole work product on Mr. Platt's behalf representing nearly 2 months of yours and your assistant James Casey's efforts sent to Mr. Platt titled “Revised business model” has nothing to do with the work you were contracted to perform. Was this an attempt at redefining the contracted project due to your inability or unwillingness to perform your responsibilities written in the contract?

11. Did Mr. Platt offer you several options for just resolution?

12. Did you threaten Mr. Platt financially if he did not accept your excuses for substandard work product?

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Questions for Jody Keenan

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13.  As the Executive Director of VASBDC is it your organizations role to steer Virginia residents seeking assistance to become MEC clients and to enter into contractual relationships your organizations recommend, such as your colleagues personal  and private LLC's  being run out of George Mason University?

14.  Have any employees, workers, agents or volunteers within the Virginia Small Business Development Center ever recommended or advised those persons seeking assistance through VASBDC ever or as a matter of course recommended, steered or directed into entering into paid contractual agreements with your colleagues, staff or faculty at George Mason University?​

15.  Are there any prohibitions against this type of conduct?

16.  Are there any written permissions allowing for this?

17.  If you were to be made aware of this type of conduct, would it be your obligation to personally investigate or would you have an obligation to forward this type of matter to a Disciplinary or Investigative body?

18.  Did Mr. Platt send you a summary of events detailing the role of VASBDC in facilitating the relationship between your colleague at GMU, Dr. Martin?

19.  Did you perform an inquiry into the facts contained in the summary Mr. Platt sent you?

20.  Did you find any of the assertions in Mr. Platt's summary to be factually incorrect?

21.  As you were made aware your organization facilitated the contractual relationship between Mr. Platt and Dr. Martin, that Dr. Martin is conducting private commercial businesses on campus utilizing public resources and Dr. Martin is incorporating those affiliations in his work product, what conclusions were made by you? On what basis?

22.  Did you forward in part or in its entirety Mr. Platt's concerns to any Disciplinary or investigative body? If so, who? If not, why not?

23.  Does statutory permissions exist permitting all actions and activities described in the summary you received from Mr. Platt?

24.  Do statutes or policies exist prohibiting any of the activities described in the summary Mr. Platt sent to you?

25.  Did you make any of the findings of your inquiry public or forward to the appropriate authorities?

26.  Were any corrective measures taken by you as the Executive Director of the VASBDC?

 

Questions for Elizabeth Woodley

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27.  In your role as FOIA Compliance Officer for George Mason University, you received on multiple occasions FOIA requests from Mr. Platt. Did you fully comply with both the letter and the spirit of both FOIA and the Public Records Act on all occasions?

28.  Was your non-compliance of your own accord or were you advised to conceal public records/information? By whom?

29.  Were you contacted by the Virginia FOIA Council regarding your non-compliance with Mr. Platt's requests?

30.  You assured the Virginia FOIA Council that you would fully comply with all of Mr. Platt's lawful FOIA requests to your office. Did you?

31.  Were you subject to Disciplinary actions for your non-compliance with Mr. Platt's FOIA requests as required by the statute for each violation/occurrence?

32.  Did you ever fully comply with Mr. Platt's FOIA requests?

33.  Have you ever not fully complied with every single FOIA request that you've received as FOIA Compliance Officer for George Mason University?

34.  Have you ever been disciplined for non-compliance with a lawfully submitted FOIA request?

35.  Was it ethical for the FOIA Compliance Officer to conceal requested information/records?

36.  As Ethics Officer for George Mason University, did your concealment of public records/information put you in conflict with your role as Ethics Officer?

37.  As Ethics Officer for George Mason University, did you have a duty to self report yourself for non-compliance with lawfully submitted FOIA requests?

Questions for Frost Law 

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38.  Did Mr. Platt retain your firm and provide your firm with sufficient materials to present a viable complaint for breach of contract between himself and Mr. Martin? 

39.  Did your firm assist Mr. Platt in the preparation of FOIA requests submitted by Mr. Platt and also prepare and send in your firms name demand letters for information to both Dr. Martin and GMU house counsel and in doing so familiarize your firm sufficiently to file an effective (Non-frivolous) complaint?

40.  Did the efforts of your firm to the date of your sending aforementioned letters provide your firm sufficient familiarity to adequately represent Mr. Platt's interests as he explained to your firm?

41.  Did your firm draft the complaint to be filed on Mr. Platt's behalf include a factual account of events along with supportive documentation or did your firm self generate facts and include those verifiably false self generated facts in the complaint filed on Mr. Platt's behalf despite Mr. Platt's request that his factual account of events be included?

42.  Did you advise Mr. Platt prior to submitting the complaint your firm drafted that the Virginia OIG would not investigate any matter relating to pending litigation? If so, when? If not, why not?

43.  Did Mr. Platt on multiple occasions represent his motivations were primarily non-monetary, his goals were aimed at bringing governmental accountability, transparency and awareness to the surrounding issues?

44.  Did any member of your Law firm advise Mr. Platt that Virginia Office of Inspector General would not investigate any matter with pending litigation prior to filing a complaint?

45.  Were any members of your law firm aware of the fact Va. OIG would not investigate any matter with pending litigation?

46.  Was any member of your firm aware of sovereign immunity statutes and constraints prior to submitting the complaint your firm had drafted on Mr. Platt's behalf?

47.  Please name all members of your firm with said knowledge and an explanation of why they kept that information to themselves.

48.  Should your firm have been aware of the nature and constraints contained within sovereign immunity statutes? Did you explain those constraints to Mr. Platt prior to submitting to the court the complaint your firm had drafted on Mr. Platt's behalf? If so, when? If not, why not?

49.  Upon receipt of proof of service to the named defendants in the complaint your firm had filed on Mr. Platt's behalf, did Mr. Platt express his continuing interest to meet with opposing parties in an effort to reach a settlement?

50.  At that time did your firm suggest an alternative, arranging a meeting with a senior member of the USSBA with whom your firm was acquainted? Please identify that individual and the record of attempts of making said arrangements.

51.  Was that meeting suggested at a time when that USSBA member would be considered a represented party, and therefore inappropriate?

52.  Was there a time when such a meeting would be appropriate? When?

53.  Did that offered meeting between a senior member of the USSBA and Mr. Platt occur? Why not? Who is that yet to be named individual (Biden appointee according to Bradford Kirby).

54.  Mr. Platt sent an email specifically and individually to Glen Frost, namesake and managing partner of Frost law group with an appeal to address the several mistakes made by Chris Buck in the prosecution of Mr. Platt's case. That email was responded by Chris Buck himself terminating Frost law's representation of Mr. Platt without further discussion. Is that typical of Frost law groups business practices?

55.  On what exact time and date did Frost law group receive service for the motion for sanctions filed by Rhodes against both Frost law and Mr. Platt?

56.  On what exact time and date did Frost law (attorney of record for Mr. Platt at that time) advise Mr. Platt of said motion? Explain the discrepancy.

57.  Was the apparent concealment of the Motion for Sanctions filed by Jeff Rhodes on behalf of Dr. Martin against both your firm and 3D Systems LLC and George Platt in his individual capacity due to carelessness or a deliberate attempt to undermine Mr. Platt's ability to defend himself?

58.  If it was another example of your firms carelessness, would you consider that instance in and of itself to be legal malpractice?

59.  If your firms concealment  of the motion for sanctions was a deliberate attempt to undermine Mr. Platt's ability to defend himself was it orchestrated solely by your firm or was it orchestrated by David Gogal?

60.  Why did your firm in its drafting of the original complaint filed in the dispute between 3D Systems LLC and Dr. Martin's LLC “Elluminai” additionally name Mr. Platt in his personal capacity?

61.  In naming additionally Mr. Platt in his personal capacity did you recognize the potential for additional unnecessary exposure?

62.  As it is Mr. Cunningham's considered opinion that the complaint your firm drafted was “bloviated" “frivolous”, “took a lot of liberties in its pleadings” and the “exposure” for drafting such a defective and amateurish complaint would be Frost law’s, would you consider any of that to be legal malpractice?

63.  Did the previously described instances clearly describing legal malpractice have anything to do with Frost law's decision to conceal Mr. Platt's case file from him?

64.  Did Frost law refuse to provide Mr. Platt his case file until being ordered to by the Virginia State Bar Association?

65.  Did Frost law group hire David Gogal so that he would use his positions in the Virginia State Bar Association to influence the Virginia State Bar Association into dismissing or derailing legitimate verifiable acts of legal malpractice committed by Frost law group?

66.  When did Frost Law hire David Gogal? What was that effect?

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Questions for Rob Cunningham

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67.  Did you engage with Mr. Platt to defend against motion for sanctions only or did you agree to resolve all of the surrounding issues?

68.  Did you confine your firms representation to the motion for sanctions only?

69.  Upon review of Mr. Platt's materials did you state to Mr. Platt that your considered opinion is that he had a good faith basis in filing for breach of contract against Dr. Martin?

70.  Along with your opinion that Mr. Platt had a good faith basis in filing for a breach of contract against Dr. Martin for his non-performance of the contract, did you also state that Frost law Group had the exposure for drafting and filing a frivolous complaint that misrepresented Mr. Platt's position?

71.  Did Mr. Platt grant to you his authority to offer as settlement to resolve the motion for sanctions only a $3,500.00 sum and no more?

72.  Did you include in your negotiations to settle the motion for sanctions issue for Mr. Platt to waive any and all claims against Dr. Martin and Frost law prior to obtaining Mr. Platt's consent to negotiate on issues for which you were not retained and specifically written out of your engagement terms with Mr. Platt?

73.  Did you present your negotiated settlement agreement with Mr. Platt agreeing to pay the authorized $3,500.00 and surrendering the $5,000.00 of his money held by Dr. Martin, and dropping the breach of contract complaint (that you agreed was made in good faith and has merit) and all claims and issues against Frost law?

74.  Is $3,500.00 plus $5,000.00 plus the legitimate breach of contract complaint against Dr. Martin plus all of the verifiable wrongdoing and potential malpractice claims against frost law more than $3,500.00?

75.  Did you present the settlement you had negotiated outside the scope of what you had written authority for as “smart" and present Mr. Platt the either/or choice of accepting this or you would bankrupt him with legal fees if he did not accept?

76.  As Frost law wrote the complaint that in your words was “bloviated" and they “took a lot of liberties” with the law, that you also referred to as “frivolous", why would you negotiate away Mr. Platt's right to challenge those and other material facts of apparent malpractice committed by Frost law?

77.  Did you send interrogatories Mr. Platt had prepared himself for opposing parties and delivered to your office to any opposing parties or counsel's? If not, why not?

78.  Mr. Platt fully complied with interrogatories posed to him. Did you forward those interrogatories Mr. Platt prepared to opposing parties? Did you obtain answers to those interrogatories? If not, why not? Those interrogatories are attached.

79.  Did you negotiate away Mr. Platt's right to challenge Frost law because Frost law retained Virginia bar Association board member that was also on the Virginia bar Disciplinary committee, Mr. Gogal?

80.  Did David Gogal of Blankenship & Keith, PC., Active member of the Virginia Bar Council, Disciplinary Board member, previously serving as its Chair, exert undue influence from those roles and cause you and your firm to fail to adequately provide Duty of care to Mr. Platt's rights?

81.  If not, please explain the wildly disproportionate outcome of your negotiated settlement and your threat of bankruptcy should Mr. Platt not accept your negotiated settlement.

82.  Mr. Platt's representation with Frost law was terminated immediately by Chris Buck when he raised questions about the competence of Frost law's representation. Was there any reason for Mr. Platt to expect any different were he to do the same with Reese Broome?

83.  Would you consider the possibility your actions put Mr. Platt situationally under duress?

84.  What exactly did Mr. Platt receive for the $21,302.71 he paid to your firm?

85.  Did you give Mr. Platt your written assurance that the 2 $10,000.00 payments ($20,000.00) would be sufficient to pay his entire bill to your firm, including the $3,500.00 settlement?

86.  Can you explain the subsequent invoice for $1,302.71?

87.  For $21,302.71 your firm edited 4 discovery responses completed by Mr. Platt, failed to seek answers to Mr. Platt's legitimate questions and negotiated a wildly disproportionate settlement on Mr. Platt's behalf, is this correct?

88.  Is this the best anyone should expect from Reese Broome?

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Questions for David Gogal

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89.  Has your positions at the Virginia State Bar Association ever put you in conflict with your employment with clients you represent through Blankenship & Keith?

90.  Is there a potential for conflict in the duality of your roles?

91.  Are you familiar or aware of the several complaints Mr. Platt had made to the Virginia State Bar Association regarding the actions of Frost law Group?

92.  Did you have any role in upholding one of Mr. Platt's complaints against Frost law that resulted in Frost law being ordered to comply with the law, which at the time they were not?

93.  Did you have any role or have any knowledge of Frost law concealing aforementioned motion for sanctions against Mr. Platt in his personal capacity, 3D Systems LLC and Frost law?

94.  Did you have any knowledge of Frost law concealing Mr. Platt's case file from him until Frost law was ordered to provide his complete file by the Virginia State Bar Association?

95.  Did Mr. Platt's complaint to the Virginia State Bar Association provide you with an opportunity to market your services to Frost law?

96.  Did you have any role in dismissing Mr. Platt's subsequent complaints against Frost Law group to the Virginia State Bar Association?  Please explain.

97.  Were you at that time retained by Frost Law group?

98.  Please explain how you took on as a paying client, a Law firm that the Virginia Bar Association had at the time an active complaint against?

99.  Did Frost law Group paying you through Blankenship &Keith PC. In your private capacity present any actual or potential conflict with your current active roles in the Virginia State Bar Association? Please explain how it could not.

100.  In your roles with the Virginia State Bar Association you were made aware of the confidential contents of Mr. Platt's circumstances and basis of complaints. Did you use any of that confidential information in the formulation of your advocacy for your paying customer, the subject of those complaints, Frost law Group?

101.  Did you discuss the subject matter of those confidential complaints submitted to the Virginia State Bar Association with your paying client, Frost Law Group?

102.  Did you have any role in the concealment from Mr. Platt the Motion for sanctions filed against Mr. Platt and Frost Law group by Mr. Rhodes on behalf of Dr. Martin?

103.  When you were made aware of the fact that Frost Law group did in fact conceal said motion for sanctions from Mr. Platt, did you take any action consistent with your roles with the Virginia State Bar Association?

104.  Do you believe the duality of your roles has been inappropriate, or has least the appearance of impropriety? Please explain.

105.  If your paying client were Mr. Platt would you have achieved a different result for him? Please explain.

106.  Would that difference be the result of your concurrent Virginia State Bar Association roles?

107.  Do you see how it appears from both your web page and your actions you are selling the Virginia State Bar influence in your private practice?

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Questions for Jeff Rhodes 

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108.  Were you aware at the time of your filing a motion for sanctions against George Platt, 3D Systems LLC and Frost law for the complaint drafted and filed by Frost law group on Mr. Platt's behalf that Frost law group had terminated its representation of Mr. Platt, filed a motion removing themselves but was still listed as the attorney of record?

109.  As proof of service you provided to the court a signed affirmation that all parties have been made aware and were properly served, correct?

110.  As you were exchanging emails with Mr. Platt during this intervening time period, you indicated on your proof of service documentation attesting to email as one of your delivery methods, when did you email Mr. Platt copies of the complaint? When was the exact time and date?

111.  In your written attestation to making good faith efforts at service did you make any mention to the court of the irregular posture of the case or make any efforts at mitigation?

112.  You were either in communication with a represented party improperly or you committed a fraud against the court, claiming non-existent service. Which one?

113.  Were you acting in concert with David Gogal (representing Frost law) or were you attempting to conceal that complaint from Mr. Platt of your own accord?

114.  Your client, Dr. Scott Martin, Associate Dean of Science and Technology was arguably in material breach of a contract, a contract initiated under arguably fraudulent means. Was the concealment you were engaged with a purposeful effort to deny George Platt the opportunity to be heard?

115.  Could that be construed as a fraud to the court?

116.  Did David Gogal offer you any assurances he would direct the Virginia State Bar Association to not investigate the defects in your proof of service or improper communications with Mr. Platt?

117.  Has there been any Bar Association inquiry?

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Questions for the Virginia OIG

118.  Did your office receive the attached detail of occurrences regarding public employees operating their  own private, for profit businesses on George Mason University campuses during business hours?

119.  Did your office conduct an investigation into those described matters?

120.  Are those activities lawful?

121. What is the total value of public resources that has been redirected by faculty and staff into their private gain?

122.  How long has your office been aware of those described activities?

123.  Was your office notified by any of the other parties to the litigation that the litigation has concluded?

124.  If you were notified,  have you begun an investigation?

125.  Will you investigate these matters now or will you continue to strenuously exercise willful blindness?

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