COMPLAINT AGAINST A LAWYER Return your completed form to: Aisharna State Bar Disciplinary Commission P. 0. Box 671 Montgomery, AL 36101~067l NAME AN I) ADDRESS OF NAME AND ADDRESS OF ATTORNEY La rra bee Whitfield Last N,arne First Name 251 Harvard Street, Suite 9 Address jwlarrabee?verlzon.net AGAINST WHOM YOUR COMPLAINI IS MADE Moore, Roy Stewart Last Name, First Name Ei-mail Address Brookline, MA 02446 City, State, ZIP Code 617-566-3670 'i"e1ephone Number(s) I 0 Name Relationship of Person Who Can Always Contact You Teiephone Number(s) On what date did the alleged ethics Violation occur? Name of Law Firm Where Attorney is Employed 1185 Gap Road Address Gallant, Al. 35972 City, State, ZIP Code (?256) 57o-o725 'l'elephone N?umbert's) Various Dates in November 2017, other What was your fee arrangement with the attorney? Not Applicable COMPLAINT INSTRUCTIONS: I. If you havea complaint against more than one attorney, use-a SEPARATE complaint form for each, attorney, with the details and relevant exhibits attached to each separate complaint if you are filing more than one complaint, do not combine you: complaint details: or your exhibits into one document, 01.111ake a speci?c comment about a complaint ?led against another attorney, or it will be returned to you We will not accept complaints against law firms. 2. Send youi complaint with an or. icinal notarized signature. We will not accept a copy of your signature. 3. State speci?cally, on each individuai complaint, what the attorney did or failed to do which you believe constitutes unethical conduct, and when it occurred. 4. Attach COME of. any receipts, contracts, or other documents which. are important to the cemplaint, to the back of each individual complaint. Keep your own original documents. 5 Please, do not bind your complaint. Type or write your complaint legibly in ink so it can be copied.? 6. You may add more pag es to this form if necessary 7 If you believe that drugs, alcohol 01 mentai disability affected the lawyer representation, please state what tacts support your beliei 8. lhis nutter is con?dential at this stage of the proceedings, until the I.)iscipiinary Commission or Board has acted 9 The Alabama Bar Association does not represent you in this matter but acts to investigate complaints on behalf of the Supreme Court of Alabama. If there 1s a court case related to your complaint, please provide the. case- name and file number and the lawyer representing you? DETAELS OF YOUR COMPLAINT prlam your complaint in your own words. Include the foliowingz. all important dates times, places, and. court ?le. numbers. Please be advised we cannot return documents submitted to this of?ce. You should retain a copy of all materials you submit. Do not send cassette tapes unless requested by the Bar to do so. The Alabama State Bar cannot be held responsible for lost, misdirected or damaged documents The attorney has engaged in the following misconduct: .1. Numerous instances of sexual assault. 2.Witness intimidation. November 20W 3. Threats to file baseless litigation November 2017 4. NotOrious and public lying to cover: up sex crimes misconduct 5 Disregarding a federal iniunction. 6. interference with legal process 7. Other activities that demonstrate dishonesty and unfitness to practice law. ATTACHED COMPLAINT FOR FURTHER DETAILS. Ihe attorney you are ?ling the complaint against will receive a copy of your complaint and may be asked to respond to your allegations. I hereby certify that the information i am providing is true and accurate to the best of my knowledge and that land voluntarily appear and testify to the facts in the complaint it?called. upon by the Alabama qltate Bar ewe/m Name (sign-attire)? bate: Mil/w [(51 Sworn to anq?sulis?mped before me this ?Rae/25%, 4 (I 2?20 -. a Not ARY rennin 49:5 5 MY COMMISSION EXPIRES: December 25. 2026 i . . .o'vgguff1311,. lir?ll?t 5.9" ??irtation? THE DISCIPLINARY COMMISSION OF THE ALABAMA STATE BAR IN THE MATTER OF: ROY STEWART MOORE ) ) ) ) COMPLAINT INTRODUCTION 1. This is a complaint against Roy Stewart Moore (“Moore”). It is based on information and belief, including reports in the Washington Post, AL.com and other reliable media outlets. 2. Moore is licensed to practice law in Alabama and is a lawyer subject to the disciplinary authority this jurisdiction. Moore has previously been disciplined for misconduct in the course of his activities as a judge. 3. During the course of his career as an attorney, prosecutor, and District Attorney, Moore has engaged in predatory sexual activity. This predatory sexual activity has included sexual activity with minors as young as 14, sexual assault, attempted rape, sexual harassment, and sexual abuse. 4. Moore initiated a sexual encounter with Leigh Corfman in 1979, when she was 14 and he was 32. Moore knowingly lied in November of 2017 when he falsely denied that he engaged in sexual activity with Corfman and when he claimed to have "never known" Corfman and "never had any contact with her". 5. December 1977 or January 1978 Moore imprisoned, sexually assaulted and attempted to rape Beverly Young Nelson. Moore intimidated Nelson at the time, telling her, "You're just a child, I'm the district attorney. If you tell anyone about this no one will ever believe you." Moore rejected Nelson's accusations. "I can tell you without hesitation, this is absolutely false," Moore said. "I never did what she said I did. I don't even know the woman. I don't know anything about her." Moore’s claims were lies. In fact, Moore came into Nelson’s workplace and signed her yearbook in December 1977. 6. Also in 1977, Moore sexually harassed Gena Richardson by forcefully kissing her without her consent. Richardson was 18 years old at the time. 7. While he was in his 30s, Moore engaged in sexually predatory activity, including sexual harassment, in the Gadsen Mall in which he attempted to initiate sexual contact with minors/teenagers. Becky Gray complained to her employer that Moore was sexually harassing her by making unwanted sexual advances. As a result, Moore was banned from the Gadsen Mall. 8. In 1991, Moore sexually assaulted Tina Johnson. Johnson visited Moore (now married) in his law office for a legal matter. Moore engaged in unwanted sexual behavior and "grabbed" Johnson’s buttocks as she left. 9. As of the date that this complaint was filed, there are at least 8 women who have made credible sexual assault, sexual harassment or sexual misconduct complaints against Moore. There are numerous other additional witnesses who provide corroboration of these allegations. 10. In November of 2017, acting through his attorney, Moore threatened to file suit against the Washington Post and the Alabama Media Group (al.com) for their truthful and accurate reporting about Moore’s sexual misconduct. The reporting about these events by the media outlets was protected first amendment activity. The threatened suits were frivolous, insubstantial, wholly without merit and made in bad faith. If Moore files the suits, it will be an abuse of process and malicious prosecution. Moore’s activities in this regard are akin to witness intimidation. -2- 11. Moore’s accusers are witnesses that have relevant testimony for the Senate Ethics Committee and the Senate Judiciary Committee if he is elected. 12. Moore has made statements, directly and through his attorney, with the purpose and effect of threatening and intimidating his accusers and other witnesses against him, including reporters and other individuals in the news media. 13. On September 30, 2016, Moore was found guilty of six charges involving judicial misconduct and was suspended for the remainder of his term, slated to end in 2019. 14. The charges included: disregarding a federal injunction, demonstrated unwillingness to follow clear law, abuse of administrative authority, substituting his judgment for the judgement of the entire Alabama Supreme Court, including failure to abstain from public comment about a pending proceeding in his own court, and, interference with legal process and remedies in the United States District Court and/or Alabama Supreme Court related to proceedings in which Alabama probate judges were involved. COUNT 1 VIOLATION OF RULE 8.4(b) BY COMMITTING CRIMINAL ACTS 15. The allegations in the preceding paragraphs are incorporated by reference as if fully set forth. 16. Moore violated Rule 8.4(b) of the Alabama Rules of Professional Conduct by engaging in criminal conduct that reflects "adversely on the lawyer’s honesty, trustworthiness or fitness as a lawyer in other respects. -3- COUNT 2 VIOLATION OF RULE 8.4(c) BY CONDUCT INVOLVING DISHONESTY, FRAUD, DECEIT OR MISREPRESENTATION 17. The allegations in the preceding paragraphs are incorporated by reference as if fully set forth. 18. Moore engaged in conduct involving dishonesty, fraud, deceit or misrepresentation in violation of Rule 8.4(c) of the Alabama Rules of Professional Conduct. COUNT 3 VIOLATION OF RULE 8.4(d) BY ENGAGING IN CONDUCT THAT PREJUDICIAL TO THE ADMINISTRATION OF JUSTICE 19. The allegations in the preceding paragraphs are incorporated by reference as if fully set forth. 20. Roy violated and continues to violate Rule 8.4(d) of the Alabama Rules of Professional Conduct by engaging "in conduct that is prejudicial to the administration of justice." WHEREFORE, the complainant respectfully requests the Disciplinary Commission of the Alabama State Bar to fully investigate the facts and violations described in this complaint and that it duly, expeditiously and properly enforce the Alabama Rules of Professional Conduct. Respectfully submitted, ______________________________ J. Whitfield Larrabee Law Offices of J. Whitfield Larrabee 251 Harvard Street, Suite 9 Brookline, MA 02446 (617) 566-3670 -4-