To: Scott Morrill, Ass’t General Counsel
Oregon State Bar-Disciplinary
5200 SW Meadows Road
Lake Oswego, Oregon 97035-0889

Pursuant to my duties as an Attorney at Law, I hereby file the following complaint regarding your bar members James S. Coon and Kimberly K. Tucker.

As I understand the facts, you have begun an investigation into their failure to communicate with a client (Complaint One). Subsequent to this complaint, they have responded to your inquiry by lying to you and attempting to deceive the State Bar Investigation and refusal to provide documents (Complaint Two)

As such, James S. Coon and Kimberly K. Tucker have violated Oregon Rules of Professional Conduct 8.1 (a) {A lawyer under investigation shall not make a false statement to the State Bar} and Oregon Rules of Professional Conduct 8.1 (c.)(2) (regarding defendant Coon and Tucker’s obligation to provide evidence of the six telephone calls made to them by the client, which they ignored.)

EJ telephoned defendants James S. Coon and Kimberly K. Tucker repeatedly, at least six times between October 2005 until the date she became totally disgusted by their failure to commutate with her on Tuesday February 9, 2006 (when she fired defendants-exhibit attached).

The last time she spoke with “an aid“ of defendants Coon and Tucker on Tuesday February 6, 2007. This person, not an attorney, gave legal advice, telling client how to proceed to obtain benefits, to this Oregon client and acted as an attorney at law, but identified herself and is and was a mere “aid”.

It is clear that once fired and once this State Bar Complaint against James S. Coon and Kimberly K. Tucker was made, that they falsified and manufactured records to falsely show that they had spoken with the client at a time after they had been fired and at a date when they had NOT in fact spoken with client.

Being sloppy in their manufacturing of evidence, defendants Coon and Tucker picked a date AFTER they were fired. Furthermore, as defendants Coon and Tucker have a duty to provide documents to the State Bar Investigation, it is indeed telling that they have NOT provided any telephone log book showing that on 2.9.07 their “aid”, not an attorney, gave legal advise to a client.

It is also a violation of the Oregon State Bar Ethics Rules 8.1 et seq for defendants to NOT provide the log book showing the six times that claimant telephoned defendants Coon and Tucker when they did not bother to respond to her reasonable inquiry. (She called repeatedly because Coon and Tucker returned NO telephone calls to her regarding the status of her case.)

Oregon Oregon State Bar v. Security Escrows, Inc., 377 P.2d 334 (Or. 1962)" ... any exercise of an intelligent choice, or an informed discretion in advising another of his legal rights and duties, will bring the activity within the practice of the profession."