Meinecke and Sitz Llc.

**  [redacted]
 
 [redacted] 
[redacted]...

[redacted]
Dear Mr. [redacted]:I am responding to your letter of February 8, 2016.  The following is almost identical to the response that I sent to the grievance that CLIENT filed against me with the Wyoming State Bar.  I have simply redacted it to protect the privacy of my client. Also, there are no attachments to this response, but I will provide those at your request. CLIENT and I met for about two hours and fifteen minutes on Sunday, June 7, 2015. I met with him in my Cody office, even though I was scheduled to be in Sheridan that week, because this was most convenient for him as he had relatives in Powell, Wyoming and could stay with them prior to our meeting.  At the time I met with him, CLIENT had no residence in Wyoming. To meet his needs, I left my family on a Sunday, drove to Cody from Sheridan, and met with him at my Cody office.  I spent just over two hours with him that day.  I did not charge him for any travel time between Cody and Sheridan. At this first meeting, CLIENT provided me with several documents that he had compiled since his divorce.  Prior to meeting with me, CLIENT had represented himself in his divorce, which took place generally from April, 2013, through finality of the divorce in December of 2013, with an abundance of post divorce proceedings.  I took notes at our June 7, 2015 meeting. 
As I recall, at this initial conference, CLIENT was very confused about the status of the proceedings up to that point.  He told me there was a hearing scheduled for that coming Thursday, June 10, 2015, but he was not entirely clear on what that hearing was going to entail.  He stated that it had something to do with a Motion for Order to Show Cause, but at that meeting, he was unable to provide the exact papers that pertained to the upcoming hearing, from the documents he brought with him.   At the end of our meeting, we agreed that I would investigate the full purpose of the hearing on Thursday, request a continuance to prepare for the hearing, and represent him at that hearing.  We also came up with five things that were CLIENT’ goals when he hired me.  Those things were: 1. He wanted me to attempt to retrieve some of his personal property that he believed his ex-wife had unlawfully obtained and retained. 2. He wanted his child support reduced from $1,500.00 per month (which was the amount he had stipulated to in the Divorce Decree.) 3. He wanted me to attempt to enforce his visitation and contact with his daughters. 4. He wanted me to try to obtain information for him about his daughter’s health and well being. 5. He wanted to try to get his daughters in counseling.
At our meeting, we briefly discussed some peripheral issues he had concerning someone at the Wyoming Outfitter’s Board named [redacted], whom he believed had wrongfully failed to [redacted]w his license, along with some other issues.  He also mentioned he thought his bankruptcy attorney, [redacted] had not been truthful with him when his Outfitter’s license had been disposed of through the bankruptcy.  I informed him I do not take malpractice cases, so would be of no help if he had complaints against [redacted].  I told him that I knew an attorney named [redacted] in Powell, whom I knew had pursued cases against the Outfitter’s Board previously.  I told him I would call [redacted] to see if [redacted] might take the case, or have an idea of who could. He asked me how he could hire someone to pursue a case like that.  I briefly explained to him that a case such as that would probably be taken on a contingent fee basis, with an attorney taking a portion of any recovery at a rate of somewhere between 33% and 25%.  I specifically cautioned him that this did not sound like something that would be a $1M case, and not to get his hopes up. (I did indeed later speak with [redacted] about this case, who indicated that he would look into some ideas he was having, and get back with me.  It went no further than that.)  As you can see from one of the emails that CLIENT provided, when he questioned me about this issue, I reminded him that I had only promised to seek a referral.  (I also told him in the same email that I did not think I could find someone to take his case as CLIENT had taken on the habit of being overly dramatic, and had begun to periodically threaten to check himself into a mental institution to manipulate me, and others involved.)  Also at our first meeting, I told CLIENT that I would require a $5,000.00 retainer before I would begin working on the case.  Because it was a Sunday, I had no staff to assist me in processing the payment, so I took his credit card number and then gave it to my assistant, Stacie L[redacted]. When Stacie tried to run the credit card it was declined, several times. While working with Stacie, CLIENT was able to pay the $5,000.00 retainer, over the course of three days.  Just a few days after CLIENT made his retainer payments, Stacie left my employ and moved to Minnesota.  I do not recall that Stacie told me about the last payment on June 12, 2015 before she left my employ, so for a time, I did not recall that CLIENT had actually accomplished the entire $5,000.00 deposit.  However, Stacie had entered the entire $5,000.00 into CLIENT’ trust account, so all my hours that I billed him were taken from a $5,000.00 initial retainer.  This was reflected on each and every monthly bill that I sent CLIENT. I have in my file, transmittal letters that each bill was sent, and several of them were both sent and emailed. If you want the transmittal letters, please let me know. Because CLIENT had told me that he thought there was a hearing the following Thursday, the next day, Monday, June 8, 2015 I began examining the documents that he had brought to me.  I spent approximately two and half hours looking through what he brought, which consisted of a hand written journal that was probably 100 pages front and back (I returned the journal to him with his file, so I can’t look at it to verify that); a one inch black binder with photos and Facebook posts, and the following pleadings: 1. Pl’s Resp. To Def’s Mot. For Order to Show Cause why Pl should not be held in Contempt dated 02/12/14; 2. Order On Pending Motions dated 03/12/14;3. Order to Show Cause why Defendant should not be held in Contempt forViolating Terms of the Stip. Order Modifying Decree of Divorce dated03/12/14;4. Summons dated 06/16/14;5. Defendant’s Financial Affidavit dated 06/19/14;6. Mot. For Order for Pl to Return Def’s Personal Property & Property of [redacted] dated 11/22/14;7. Request for Hearing for Def’s Mot. For Rtn of Pers. Property and Property of[redacted] dated 11/22/14;8. Motion to Compel Discovery dated 01/29/15;9. Plaintiff [redacted]’ Response To Defendant’s Motion For Order for Pl toRtn Def’s Personal Property and Property of [redacted] dated01/29/15;10. Request for Setting on Pl’s Motion to Compel dated 01/29/15;11. Motion for Order for Subpoena Duces Tecum dated 01/31/15;12. Order Setting trial to Court - Domestic Relations dated 03/16/15;st 13. Plaintiff’s 1 Request for Production of Documents dated 04/24/15;14. Plaintiff [redacted]’s Initial  Pretrial Memorandum Pursuant to Court’s Scheduling. Order for Petition to Mod. Child Support dated 04/24/15; 15. Child Support Authority’s Initial Pre-Trial Memorandum dated 04/24/15;16. Defendant [redacted]’ Initial Pretrial Memorandum Pursuant to court’s schedulingorder for petition to Mod. Child Support dated 05/01/15;17. Confidential Financial Affidavit dated 05/04/15;18. Income Withholding for Support dated 05/07/15;19. Plaintiff’s Mot. For Sanctions against Def and Mot. To Dismiss Petition toModify/Reduce Child Support dated 05/14/15; 20. Request for Setting on Pl’s Motion for Sanctions/Motion to Dismiss dated 05/14/15; 21. Def’s Response to Pl’s Mot. For Sanctions against Def. And Mot. To Dismiss Petition to Modify/Reduce Child Support dated 05/20/15; 22. Plaintiff Pretrial Memorandum pursuant to Court’s Scheduling Order for Petition to Modify Child Support dated 5/26/15; 23. Motion for Order to Show Cause Why Pl. Should not be held in Contempt of Court for Viol. The Court’s Order by Refusing Def. Visitation Rights dated 06/03/15; nd 24. Plaintiff [redacted]’ 2 Supplement to Mot. For Sanctions/Mot to Dismissdated 06/04/15;25. Affidavit and Authority for Attorney Fees dated 06/04/15.26. Six pages of Patient Care Summary sheets for CLIENT;27. Six pages of medical records from South Sheridan Medical Center forCLIENT [redacted]; 28. 26 pages of medical records from Northern Wyoming Mental Health Center for CLIENT [redacted]; 29. 18 pages of correspondence from [redacted] that consisted primarily ofunsigned copies of the foregoing listed pleadings;30. 56 pages of [redacted] bank records for [redacted], LLC;31. 15 pages of tax return documents;32. 51 pages of correspondence from Bankruptcy Trustee [redacted] anddocuments concerning the bankruptcy of CLIENT [redacted]; 33. 75 pages of documents from Buffalo Sheriff/Police Department, all containing police reports concerning CLIENT [redacted]; These documents were all together in a green folder provided by CLIENT, in random order.  It took me approximately two and a half hours to organize the documents, review them, and give my assistant instructions to put them into five different folders. 
I was able to ascertain after review of these documents and a call to the Courthouse in Buffalo, Wyoming, that there was not a trial scheduled for the upcoming Thursday, but that there was a hearing scheduled on June 26, 2015.  I emailed opposing counsel, [redacted], and told her that I was going to enter an appearance and wanted to discuss with her a Motion for Continuance and see if I could obtain her approval.  [redacted] and I were finally able to speak on the phone on June 17, 2015, for approximately one half hour. [redacted] got me up to speed on the case, and what exactly it was that she believed were pending issues for the case, etc.  She agreed to a continuance, so that day I filed my Entry of Appearance and Request and Order for Continuance. [redacted] and I talked again the next day about some pending issues concerning outstanding discovery she had sent to CLIENT before my involvement.
The Court then ordered that the June 26, 2015 hearing would be postponed and scheduled a status conference for July 9, 2015.  On July 7, 2015, I prepared a Motion to Modify Child Support and Request for Setting consisting of five pages. It took me approximately an hour and ten minutes to prepare the documents.
[redacted] and I attended the status conference on July 9, 2015 by phone.  At said conference, [redacted], Judge [redacted] and I discussed what Motions were still pending that had been previously filed by CLIENT, and which Motions were still pending that had been previously filed by Ms. [redacted].  We came to the conclusion that the only pending Motions were CLIENT’ Motion for Return of his Personal Property, and Ms. [redacted]’s Request for Contempt and Order to Show Cause for CLIENT’ failure to pay child support.  We concluded that those two Motions would be scheduled for August 24, 2015 at 9:00 a.m.  At this conference I also discussed with the Court and Ms. [redacted] the possibility that I may file a Motion to Modify Child Support.  I hadn’t done so up to that point, because CLIENT [redacted] had previously filed such a Motion, but the Court had dismissed it as a sanction to CLIENT for not responding to discovery, and I was unclear if it had been dismissed by the Court with prejudice, or without.  I ascertained at the conference that it had been dismissed without prejudice, and it was a consensus at the scheduling conference that I could re-file therefore re-file the Motion.  Therefore, I advised CLIENT of the situation and sent the Motion to Modify that I had prepared on July 7, 2015 to him for his approval.  After obtaining his approval, I then sent the Motion to Modify for filing in Buffalo and it was filed on July 27, 2015, along with my Request and Notice of Setting. On July 20, 2015 I spent approximately fifteen minutes on a letter to the Sheridan Clerk concerning some confusion that had occurred with filing the Motion to Modify, as the case had started out in Buffalo and was then transferred to Sheridan.  I was unclear on where to send the documents once filed, as the documents were to be filed in Buffalo, but then given to Judge [redacted] in Sheridan, and I was unfamiliar with how this process worked.On August 3, 2015, I reviewed Ms. [redacted]’s Response to my Motion to Modify and Disclosure.  I spent about twenty minutes on this task. On August 19, 2015, my client let me know he would be in Buffalo that weekend due to our upcoming hearing on the 24th of August, and we emailed back and forth about him wanting a visit with his children.  I then immediately contacted [redacted] and requested visitation that same day.  I spent about 15 minutes on attempting to arrange visitation for CLIENT’ visit to Buffalo. To my knowledge, and based upon my efforts, CLIENT did have a visit with his daughters on August 21, 2015.Our hearing on August 24th was on a Monday.  CLIENT emailed me and let me know he would only be available on August 22, 2015 to meet, which was a Saturday. I was not free to meet with CLIENT that Saturday, so I texted him and offered to meet with him Sunday evening for a bit, or at 8:00 on Monday morning before the hearing.  CLIENT opted for 8:00 on Monday morning.  Because we were not going to have much time to prepare, I prepared my hearing outline ahead of time and emailed it to CLIENT Sunday evening so he would know what questions I was going to ask him, and what my strategy would be at the hearing.  I know he received this email, because he responded to the email that I sent him with the preparation questions, etc. . I met CLIENT in a private conference room at the Courthouse on August 24, 2015 at 8:00 a.m.  We went through the exhibits I hard prepared for the hearing, which consisted of 112 pages of documents, comprising more than a dozen exhibits.  We also went through my hearing outline and the questions I anticipated asking him, that I had sent him the night before.  He indicated understanding of the purpose of the hearing, the exhibits I had prepared, and the questions I intended to ask him. We then proceeded into the Courtroom and had the hearing.  It took almost three hours.  At the hearing, I made the arguments I felt were legitimate for the Plaintiff to return CLIENT’ personal property to him.  This Motion was denied at the end of the hearing because Judge [redacted] felt the issue was basically res judicata.  We then moved on to the child support portion of the hearing. I made an oral motion that the child support be temporarily modified, and the Judge granted this Motion. He modified the child support to $750.00 per month (which is one half the amount CLIENT had been paying) until a hearing on my permanent Motion for Modification of child support could be heard. CLIENT was also held in contempt for failure to pay his child support and a judgement was issued against him in the amount of approximately $30,000.00, for past child support owed. (The judgement ended up being a bit less than child support authority requested, due to arguments that I made at the hearing.)  I was able to successfully argue that the contempt charges should be purged with faithful payment of child support arrears. The Court held that he could purge the charges with payment of back child support in the amount of $500.00 per month.  I then met with CLIENT for about ten minutes after the hearing to make sure he understood everything he had been ordered to do.  I would invite you to speak with [redacted] and Judge [redacted] about my performance at this hearing, to determine my competency and preparation. CLIENT returned to Oklahoma and then emailed me six times on August 27, 2015 concerning additional thoughts about the previous hearing, including an email which stated, “I'm not blaming you one bit, but I can't come up with these thoughts while I'm under pressure in the court room. My mind just doesn't work that fast. If I could think of these things in a split second, trust me I would have said something to you.” Clearly, CLIENT had different feelings about how I performed  during the hearing right after it occurred, than he does now.  He specifically stated he did not blame me for the outcome of the hearing, previously, while now he does.  This email exchange took about ten minutes. On September 1, 2015, I got the draft Order concerning the return of the personal property from [redacted].  I spent about ten minutes reviewing the Order.  I then corresponded with [redacted] about my thoughts on the Order. On September 10, 2015, I got a text from CLIENT and we talked about me needing to prepare discovery requests to prepare for our permanent child support hearing which had been scheduled for February 18, 2016.  He was amenable to my doing that, so that same day, I spent just over two and a half hours preparing extensive Interrogatories and Requests for Production.  The Interrogatories were eight pages with 18 questions with numerous sub-parts.  The Requests for Production were 6 pages with 12 questions with sub-parts.  The reason it took me over two hours to prepare the discovery was because I had to go through the documents CLIENT had previously sent to [redacted] to determine what I needed to get from the Plaintiff to assist in our hearing and reflect the same types of information CLIENT had already given to Ms. [redacted] prior to my involvement.  Much of this information I had gotten from [redacted], who was kind enough to give me copies of what CLIENT had previously provided.  I spent about ten minutes on September 14, 2015 finalizing the discovery and sending it to CLIENT for his approval.  He got back with me with his approval of the documents the same day.  Also on September 14, 2015 I reviewed and signing the Child Support Order regarding the contempt and modification from the August 8, 2015 hearing that I had finally received from Child Support Enforcement.  This took me about fifteen minutes. At the end of this hearing, Judge [redacted] indicated that a hearing on my permanent Motion to Modify Child Support would be scheduled within the next few days.  The Court then notified us a short time later that the hearing would be scheduled for February 18, 2016.  This Notice of Setting was provided to CLIENT via mail and email. (I also reminded CLIENT about the hearing and it’s location in the email I sent him with the Order allowing me to withdraw in mid-January.) On September 17, 2015, CLIENT emailed me seven times about a potential suspension of his driver’s license for failure to pay his child support, and the hunting and fishing licenses that had already been suspended.  I responded to each of his emails.  I also corresponded with [redacted] about some additional discovery documents that I was sending to her that she had requested to supplement the responses CLIENT had already provided her.  During this discussion, [redacted] also pointed out to me that she believed that early in the proceedings CLIENT had failed to respond to a Counterclaim, and requested that I do so.  To avoid a default on this issue, I then spent just over an hour preparing an Answer to Counterclaim, which I immediately sent for filing. On September 28, 2015, I began compiling formal responses to outstanding discovery from [redacted].  CLIENT was not very forthcoming in his responses and my new assistant, Angie G[redacted], and I had to email CLIENT repeatedly and work very hard to compile proper answers. Between Angie and I, we emailed CLIENT at least 15 times trying to get him to respond properly. He always instructed us that the requested documents were in the documents he had already given us, or sent us elsewhere to look.  He did finally mail me much of what [redacted] needed, after this effort on our part to obtain it.  All total, it took over two and a half hours to get his discovery responses gathered, typed, legible, and in a form that I felt good about sending to [redacted]. There were numerous emails between me and [redacted] and me and CLIENT between September 28 and October 19, 2015, when I finally sent the discovery responses to [redacted]. On October 20, 2015, CLIENT asked me to try to arrange visitation between him and his daughters as he was going to be in Buffalo.  I called [redacted] and emailed her that day to discuss this, which took about 15 minutes.  I also corresponded with my client a few times throughout the day about the progress we were making.  I do believe CLIENT ended up meeting his daughters for a short visit, but I cannot be certain if he followed through with it or not, at this time. On November 3, 2015, [redacted] emailed me and told me that CLIENT had not filed his monthly update according to the Court’s order from our August 8, 2015 hearing.  I therefore emailed CLIENT with language I cut and pasted from the order, reminding him what his responsibilities were pursuant to that order.  He had received the Order from Angie via email in September, but I wanted to remind him again what it said.  We emailed back and forth several times throughout the day about this, which took about fifteen minutes. 
On November 14, 2015 I received several hundred pages of discovery responses from [redacted].  I went through all of the documents and this took me just over two hours. All of these responses were copied and provided to CLIENT, at the cost of $144.25 for his copies.  There was obviously a lot there to go through.  I haven’t counted the pages, but the stack of documents is well over six inches thick. On November 30, 2015, [redacted] sent a settlement proposal to me, which I reviewed for about five minutes.  I then forwarded it to CLIENT for his review and comment.  He was not favorable to the proposal and I let [redacted] know. The relationship between CLIENT and myself deteriorated during the course of the relationship, and on December 28, 2015, I filed a Motion to Withdraw.  There was a hearing held on this issue and my Motion was granted on January 13, 2016. The relationship deteriorated due to several factors: A. CLIENT had a pattern of being verbally abusive and threatening to me.  I repeatedly requested that he refrain from treating me this way, or I would be forced to withdraw. He did not curb his behavior. His behavior became so intimidating that in early January, I contacted the Buffalo Sheriff’s office to report his behavior and to ask them to alert me if he was in the area, as he has probation conditions which require him to report to the Buffalo Police department within an hour of arriving in Buffalo. (He was convicted of reckless endangerment against his ex-wife for trying to run her over with his [redacted], which was recorded on video by a bank surviellence camera.) The police agreed with me that they believed he was a legitimate threat and indicated they would call me when they knew him to be in the area.  B. He began making comments to me verbally and in emails that I thought amounted to real threats to his ex-wife, [redacted], and the Court.  I even contacted Bar Counsel about these threats and how to approach that issue.  I informed [redacted] and Judge [redacted] during our hearing concerning my Motion to Withdraw that I felt that CLIENT posed a real threat to them and his ex-wife, without revealing anything he had said to me specifically.  Please feel free to verify this with them. C. CLIENT would repeatedly do things that were contradictory to his best interest, and which would sabotage his case, regardless of my advice otherwise.  He made it impossible to represent him.  If you want examples of this, I would be happy to provide them. D. After about the first part of November, 2015, he repeatedly told me he was dissatisfied with my services, told me he was looking for another lawyer, and constantly demanded the return of his money. After the Court ordered that I withdraw, I made a copy of CLIENT’ entire file, and sent the original file to him in a sealed banker’s box.  I sent him the originals of everything, in the condition I had kept them in my office.  Everything was organized in file folders, tabbed and indexed, or in binders. I took a photo of the banker’s box that I put his file in before I sealed it up with duct tape. The banker’s box containing his file was then mailed to him via UPS and I have a tracking receipt which indicates that the box was delivered to his doorstep on January 29, 2016 at 10:39 a.m. After all was said and done, I billed CLIENT fairly for all the time I spent on his case.  In the end, he owed me $302.24, which I have told him I am not going to collect.  This was owed to me even after I DID NOT charge him for the time I spent at the initial status conference on July 9, 2015, I DID NOT charge him for any of the 89 text messages that were exchanged while I represented him, and I only charged him for a fraction of the time spent corresponding via the 218 separate emails that were exchanged.  CLIENT received bills every month, and not once did he object to a bill. Late in the case, he did send me a short email asking for an explanation of the bill, which I provided, but no objection was forthcoming after that.
This is the course of my representation of CLIENT, to respond to his complaint against me. To address the potential violations of the rules, I respond as follows:
1.3 DILIGENCE: I believe I was diligent in working CLIENT’ case.  I did everything he asked me to do, promptly.  I responded to every email, phone call and text from CLIENT in a timely manner.  I filed documents promptly, and within time lines established by the W.R.C.P. and the Court.  I reviewed documents he provided to me and made sure I understood the status of the case. I truly do not know what more I could have done to be diligent in representing CLIENT.  I accomplished many of the goals we set out to accomplish during our initial meeting, and the ones I was unable to accomplish were due to circumstances, not my lack of diligence.  For instance, I had a hard time reaching CLIENT’ goals for obtaining, and/or modifying visitation with his daughters, because the previous visitation orders required CLIENT to complete parenting courses and anger management courses which he never completed.  On top of that, the previous orders required that there be a supervisor on all visits, whom his daughters were comfortable with.  This was hard to accomplish under the circumstances, and the difficulties were created by CLIENT, not me.  I explained this to him, but he was unwilling to take the necessary steps to get more contact with his daughters.  Other than the visitation issue, I accomplished everything CLIENT hired me to do. 1.4 COMMUNICATION: I communicated freely and often with CLIENT.  I have transmittal letters which prove that I sent all pleadings and discovery to him, as well as dozens of emails from me and Angie which prove many documents were emailed to him as well.  There is not one time, not one, when CLIENT emailed me, or texted me, when I did not respond.  NOT ONE TIME. CLIENT did not always like my responses, but I was always truthful and direct with him about the status of his case.  If you wish for me to forward all of the emails and texts between CLIENT and myself to you, I would be more than happy to do so, as well as provide all proofs of correspondence via transmittal letter and email.
1.5 FEES: I charged CLIENT our agreed upon rate of $200.00 per hour, which has been my customary rate for over five years.  I sent CLIENT an invoice each and every month.  The invoices clearly indicate that the starting point in his trust account was his deposit of $5,000.00.  I did mistakenly communicate with him that I thought his retainer had only been $3,000.00, but I explained that confusion to him, and even apologized for it, in an email dated February 4, 2015 (long after I had withdrawn.) I spent about 25 hours on CLIENT’ case over the course of about seven months.  I spent this time doing what I needed to do to accomplish CLIENT’ goals.  CLIENT owes me money after all is said and done, but I have indicated to him that I will not be trying to collect what is owed. 1.15 SAFEKEEPING OF PROPERTY: I have never refused to provide CLIENT’ documents to him.  His entire file consisting of all pleadings, all discovery with responses, the original documents he provided to me, and a copy of all of his invoices was delivered to his doorstep via UPS on January 29, 2016 at 10:39 a.m.  He received his file less than two weeks after I was given the go ahead to withdraw by Judge [redacted], and 19 days prior to his hearing to Modify Child Support which is scheduled for February 18, 2016.  Other than providing his entire file that was in my possession, and I mean every single document, I cannot understand what else he needs, or could claim I have refused to give him.  I kept copies of everything, and can provide this to Bar Counsel to provide to CLIENT again, if necessary.  However, CLIENT has all of his documents and has for  over three weeks. 
I do not believe I have violated the Wyoming Rules of Professional Responsibility in any manner.  I believe this complaint is motivated by several factors that are attributable soley to
CLIENT: i. CLIENT is low functioning.  He has only a G.E.D. education and is incapable of comprehending the legal process and what went on during my representation of him. He admitted as much to me in more than one email.  He simply cannot understand what is going on. ii. CLIENT is mentally ill.  He suffers from depression and paranoia, which is verifiedby medical records that he filed in the civil court file after I withdrew from the case. On top of that, it is my personal belief that CLIENT has Borderline Personality Disorder.  He displays symptoms consistent with this mental affliction.  Specifically, he will lie, manipulate, and contort facts to be perceived as a victim in all situations. He fails to take responsibility for his own behaviors, and has no conscience about how he treats others in order to maintain his status as the victim.  Someone else is always to blame.  He blamed his ex-wife for ruining his life, then he blamed her first lawyer for “conning” him into signing a Stipulated Divorce Decree with $1,500.00 per month in child support.  Then he blamed Judge Cundiff for failing to set aside the Decree, which CLIENT willingly agreed to.  Then he blamed his bankruptcy lawyer and [redacted], for the loss of his Outfitter’s License.  Then he blamed [redacted] for alienating him from his daughters, even though he failed to take the necessary steps to have visitation with them again.  Now he is blaming me for failing  to diligently pursue his case, which is simply not true.  I predict that next, he will blame Bar Counsel for failing to hold me accountable for further “alienating him from his daughters”, etc.  It will never end with CLIENT.  He is simply unable to understand what is going on, and refuses to take accountability for his own actions. I know this is a lengthy response, but I must defend myself.  CLIENT is simply lying, and it must stop.  He has harassed me to the point of me informing law enforcement, and I do not feel safe in my home. CLIENT has lied about me on Facebook and defamed me on social media (Sheridan UpCycle.)  He has filed documents in the court file, containing only lies, trying to blame me for his situation.  Now he is attempting to compromise my reputation with Bar Counsel, and is asking that I lose my license.  It is disappointing, to say the least.  I put everything out there in this response, and can back up every fact I stated in this letter with documentation.  I will do so at your request. Thank you.Sincerely,  MEINECKE & SITZ, LLC M.  Jalie Meinecke MJM/ag Encl: Exhibits 1, 2 and 3.

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[redacted]
Dear Mr. [redacted]:I am responding to your letter of February 8, 2016.  The following is almost identical to the response that I sent to the grievance that CLIENT filed against me with the Wyoming State Bar.  I have simply redacted it to protect the privacy of my client. Also, there are no attachments to this response, but I will provide those at your request. CLIENT and I met for about two hours and fifteen minutes on Sunday, June 7, 2015. I met with him in my Cody office, even though I was scheduled to be in Sheridan that week, because this was most convenient for him as he had relatives in Powell, Wyoming and could stay with them prior to our meeting.  At the time I met with him, CLIENT had no residence in Wyoming. To meet his needs, I left my family on a Sunday, drove to Cody from Sheridan, and met with him at my Cody office.  I spent just over two hours with him that day.  I did not charge him for any travel time between Cody and Sheridan. At this first meeting, CLIENT provided me with several documents that he had compiled since his divorce.  Prior to meeting with me, CLIENT had represented himself in his divorce, which took place generally from April, 2013, through finality of the divorce in December of 2013, with an abundance of post divorce proceedings.  I took notes at our June 7, 2015 meeting. As I recall, at this initial conference, CLIENT was very confused about the status of the proceedings up to that point.  He told me there was a hearing scheduled for that coming Thursday, June 10, 2015, but he was not entirely clear on what that hearing was going to entail.  He stated that it had something to do with a Motion for Order to Show Cause, but at that meeting, he was unable to provide the exact papers that pertained to the upcoming hearing, from the documents he brought with him.   At the end of our meeting, we agreed that I would investigate the full purpose of the hearing on Thursday, request a continuance to prepare for the hearing, and represent him at that hearing.  We also came up with five things that were CLIENT’ goals when he hired me.  Those things were: 1. He wanted me to attempt to retrieve some of his personal property that he believed his ex-wife had unlawfully obtained and retained. 2. He wanted his child support reduced from $1,500.00 per month (which was the amount he had stipulated to in the Divorce Decree.) 3. He wanted me to attempt to enforce his visitation and contact with his daughters. 4. He wanted me to try to obtain information for him about his daughter’s health and well being. 5. He wanted to try to get his daughters in counseling.At our meeting, we briefly discussed some peripheral issues he had concerning someone at the Wyoming Outfitter’s Board named [redacted], whom he believed had wrongfully failed to [redacted]w his license, along with some other issues.  He also mentioned he thought his bankruptcy attorney, [redacted] had not been truthful with him when his Outfitter’s license had been disposed of through the bankruptcy.  I informed him I do not take malpractice cases, so would be of no help if he had complaints against [redacted].  I told him that I knew an attorney named [redacted] in Powell, whom I knew had pursued cases against the Outfitter’s Board previously.  I told him I would call [redacted] to see if [redacted] might take the case, or have an idea of who could. He asked me how he could hire someone to pursue a case like that.  I briefly explained to him that a case such as that would probably be taken on a contingent fee basis, with an attorney taking a portion of any recovery at a rate of somewhere between 33% and 25%.  I specifically cautioned him that this did not sound like something that would be a $1M case, and not to get his hopes up. (I did indeed later speak with [redacted] about this case, who indicated that he would look into some ideas he was having, and get back with me.  It went no further than that.)  As you can see from one of the emails that CLIENT provided, when he questioned me about this issue, I reminded him that I had only promised to seek a referral.  (I also told him in the same email that I did not think I could find someone to take his case as CLIENT had taken on the habit of being overly dramatic, and had begun to periodically threaten to check himself into a mental institution to manipulate me, and others involved.)  Also at our first meeting, I told CLIENT that I would require a $5,000.00 retainer before I would begin working on the case.  Because it was a Sunday, I had no staff to assist me in processing the payment, so I took his credit card number and then gave it to my assistant, Stacie L[redacted]. When Stacie tried to run the credit card it was declined, several times. While working with Stacie, CLIENT was able to pay the $5,000.00 retainer, over the course of three days.  Just a few days after CLIENT made his retainer payments, Stacie left my employ and moved to Minnesota.  I do not recall that Stacie told me about the last payment on June 12, 2015 before she left my employ, so for a time, I did not recall that CLIENT had actually accomplished the entire $5,000.00 deposit.  However, Stacie had entered the entire $5,000.00 into CLIENT’ trust account, so all my hours that I billed him were taken from a $5,000.00 initial retainer.  This was reflected on each and every monthly bill that I sent CLIENT. I have in my file, transmittal letters that each bill was sent, and several of them were both sent and emailed. If you want the transmittal letters, please let me know. Because CLIENT had told me that he thought there was a hearing the following Thursday, the next day, Monday, June 8, 2015 I began examining the documents that he had brought to me.  I spent approximately two and half hours looking through what he brought, which consisted of a hand written journal that was probably 100 pages front and back (I returned the journal to him with his file, so I can’t look at it to verify that); a one inch black binder with photos and Facebook posts, and the following pleadings: 1. Pl’s Resp. To Def’s Mot. For Order to Show Cause why Pl should not be held in Contempt dated 02/12/14; 2. Order On Pending Motions dated 03/12/14;3. Order to Show Cause why Defendant should not be held in Contempt forViolating Terms of the Stip. Order Modifying Decree of Divorce dated03/12/14;4. Summons dated 06/16/14;5. Defendant’s Financial Affidavit dated 06/19/14;6. Mot. For Order for Pl to Return Def’s Personal Property & Property of [redacted] dated 11/22/14;7. Request for Hearing for Def’s Mot. For Rtn of Pers. Property and Property of[redacted] dated 11/22/14;8. Motion to Compel Discovery dated 01/29/15;9. Plaintiff [redacted]’ Response To Defendant’s Motion For Order for Pl toRtn Def’s Personal Property and Property of [redacted] dated01/29/15;10. Request for Setting on Pl’s Motion to Compel dated 01/29/15;11. Motion for Order for Subpoena Duces Tecum dated 01/31/15;12. Order Setting trial to Court - Domestic Relations dated 03/16/15;st 13. Plaintiff’s 1 Request for Production of Documents dated 04/24/15;14. Plaintiff [redacted]’s Initial  Pretrial Memorandum Pursuant to Court’s Scheduling. Order for Petition to Mod. Child Support dated 04/24/15; 15. Child Support Authority’s Initial Pre-Trial Memorandum dated 04/24/15;16. Defendant [redacted]’ Initial Pretrial Memorandum Pursuant to court’s schedulingorder for petition to Mod. Child Support dated 05/01/15;17. Confidential Financial Affidavit dated 05/04/15;18. Income Withholding for Support dated 05/07/15;19. Plaintiff’s Mot. For Sanctions against Def and Mot. To Dismiss Petition toModify/Reduce Child Support dated 05/14/15; 20. Request for Setting on Pl’s Motion for Sanctions/Motion to Dismiss dated 05/14/15; 21. Def’s Response to Pl’s Mot. For Sanctions against Def. And Mot. To Dismiss Petition to Modify/Reduce Child Support dated 05/20/15; 22. Plaintiff Pretrial Memorandum pursuant to Court’s Scheduling Order for Petition to Modify Child Support dated 5/26/15; 23. Motion for Order to Show Cause Why Pl. Should not be held in Contempt of Court for Viol. The Court’s Order by Refusing Def. Visitation Rights dated 06/03/15; nd 24. Plaintiff [redacted]’ 2 Supplement to Mot. For Sanctions/Mot to Dismissdated 06/04/15;25. Affidavit and Authority for Attorney Fees dated 06/04/15.26. Six pages of Patient Care Summary sheets for CLIENT;27. Six pages of medical records from South Sheridan Medical Center forCLIENT [redacted]; 28. 26 pages of medical records from Northern Wyoming Mental Health Center for CLIENT [redacted]; 29. 18 pages of correspondence from [redacted] that consisted primarily ofunsigned copies of the foregoing listed pleadings;30. 56 pages of [redacted] bank records for [redacted], LLC;31. 15 pages of tax return documents;32. 51 pages of correspondence from Bankruptcy Trustee [redacted] anddocuments concerning the bankruptcy of CLIENT [redacted]; 33. 75 pages of documents from Buffalo Sheriff/Police Department, all containing police reports concerning CLIENT [redacted]; These documents were all together in a green folder provided by CLIENT, in random order.  It took me approximately two and a half hours to organize the documents, review them, and give my assistant instructions to put them into five different folders. I was able to ascertain after review of these documents and a call to the Courthouse in Buffalo, Wyoming, that there was not a trial scheduled for the upcoming Thursday, but that there was a hearing scheduled on June 26, 2015.  I emailed opposing counsel, [redacted], and told her that I was going to enter an appearance and wanted to discuss with her a Motion for Continuance and see if I could obtain her approval.  [redacted] and I were finally able to speak on the phone on June 17, 2015, for approximately one half hour. [redacted] got me up to speed on the case, and what exactly it was that she believed were pending issues for the case, etc.  She agreed to a continuance, so that day I filed my Entry of Appearance and Request and Order for Continuance. [redacted] and I talked again the next day about some pending issues concerning outstanding discovery she had sent to CLIENT before my involvement.The Court then ordered that the June 26, 2015 hearing would be postponed and scheduled a status conference for July 9, 2015.  On July 7, 2015, I prepared a Motion to Modify Child Support and Request for Setting consisting of five pages. It took me approximately an hour and ten minutes to prepare the documents.[redacted] and I attended the status conference on July 9, 2015 by phone.  At said conference, [redacted], Judge [redacted] and I discussed what Motions were still pending that had been previously filed by CLIENT, and which Motions were still pending that had been previously filed by Ms. [redacted].  We came to the conclusion that the only pending Motions were CLIENT’ Motion for Return of his Personal Property, and Ms. [redacted]’s Request for Contempt and Order to Show Cause for CLIENT’ failure to pay child support.  We concluded that those two Motions would be scheduled for August 24, 2015 at 9:00 a.m.  At this conference I also discussed with the Court and Ms. [redacted] the possibility that I may file a Motion to Modify Child Support.  I hadn’t done so up to that point, because CLIENT [redacted] had previously filed such a Motion, but the Court had dismissed it as a sanction to CLIENT for not responding to discovery, and I was unclear if it had been dismissed by the Court with prejudice, or without.  I ascertained at the conference that it had been dismissed without prejudice, and it was a consensus at the scheduling conference that I could re-file therefore re-file the Motion.  Therefore, I advised CLIENT of the situation and sent the Motion to Modify that I had prepared on July 7, 2015 to him for his approval.  After obtaining his approval, I then sent the Motion to Modify for filing in Buffalo and it was filed on July 27, 2015, along with my Request and Notice of Setting. On July 20, 2015 I spent approximately fifteen minutes on a letter to the Sheridan Clerk concerning some confusion that had occurred with filing the Motion to Modify, as the case had started out in Buffalo and was then transferred to Sheridan.  I was unclear on where to send the documents once filed, as the documents were to be filed in Buffalo, but then given to Judge [redacted] in Sheridan, and I was unfamiliar with how this process worked.On August 3, 2015, I reviewed Ms. [redacted]’s Response to my Motion to Modify and Disclosure.  I spent about twenty minutes on this task. On August 19, 2015, my client let me know he would be in Buffalo that weekend due to our upcoming hearing on the 24th of August, and we emailed back and forth about him wanting a visit with his children.  I then immediately contacted [redacted] and requested visitation that same day.  I spent about 15 minutes on attempting to arrange visitation for CLIENT’ visit to Buffalo. To my knowledge, and based upon my efforts, CLIENT did have a visit with his daughters on August 21, 2015.Our hearing on August 24th was on a Monday.  CLIENT emailed me and let me know he would only be available on August 22, 2015 to meet, which was a Saturday. I was not free to meet with CLIENT that Saturday, so I texted him and offered to meet with him Sunday evening for a bit, or at 8:00 on Monday morning before the hearing.  CLIENT opted for 8:00 on Monday morning.  Because we were not going to have much time to prepare, I prepared my hearing outline ahead of time and emailed it to CLIENT Sunday evening so he would know what questions I was going to ask him, and what my strategy would be at the hearing.  I know he received this email, because he responded to the email that I sent him with the preparation questions, etc. . I met CLIENT in a private conference room at the Courthouse on August 24, 2015 at 8:00 a.m.  We went through the exhibits I hard prepared for the hearing, which consisted of 112 pages of documents, comprising more than a dozen exhibits.  We also went through my hearing outline and the questions I anticipated asking him, that I had sent him the night before.  He indicated understanding of the purpose of the hearing, the exhibits I had prepared, and the questions I intended to ask him. We then proceeded into the Courtroom and had the hearing.  It took almost three hours.  At the hearing, I made the arguments I felt were legitimate for the Plaintiff to return CLIENT’ personal property to him.  This Motion was denied at the end of the hearing because Judge [redacted] felt the issue was basically res judicata.  We then moved on to the child support portion of the hearing. I made an oral motion that the child support be temporarily modified, and the Judge granted this Motion. He modified the child support to $750.00 per month (which is one half the amount CLIENT had been paying) until a hearing on my permanent Motion for Modification of child support could be heard. CLIENT was also held in contempt for failure to pay his child support and a judgement was issued against him in the amount of approximately $30,000.00, for past child support owed. (The judgement ended up being a bit less than child support authority requested, due to arguments that I made at the hearing.)  I was able to successfully argue that the contempt charges should be purged with faithful payment of child support arrears. The Court held that he could purge the charges with payment of back child support in the amount of $500.00 per month.  I then met with CLIENT for about ten minutes after the hearing to make sure he understood everything he had been ordered to do.  I would invite you to speak with [redacted] and Judge [redacted] about my performance at this hearing, to determine my competency and preparation. CLIENT returned to Oklahoma and then emailed me six times on August 27, 2015 concerning additional thoughts about the previous hearing, including an email which stated, “I'm not blaming you one bit, but I can't come up with these thoughts while I'm under pressure in the court room. My mind just doesn't work that fast. If I could think of these things in a split second, trust me I would have said something to you.” Clearly, CLIENT had different feelings about how I performed  during the hearing right after it occurred, than he does now.  He specifically stated he did not blame me for the outcome of the hearing, previously, while now he does.  This email exchange took about ten minutes. On September 1, 2015, I got the draft Order concerning the return of the personal property from [redacted].  I spent about ten minutes reviewing the Order.  I then corresponded with [redacted] about my thoughts on the Order. On September 10, 2015, I got a text from CLIENT and we talked about me needing to prepare discovery requests to prepare for our permanent child support hearing which had been scheduled for February 18, 2016.  He was amenable to my doing that, so that same day, I spent just over two and a half hours preparing extensive Interrogatories and Requests for Production.  The Interrogatories were eight pages with 18 questions with numerous sub-parts.  The Requests for Production were 6 pages with 12 questions with sub-parts.  The reason it took me over two hours to prepare the discovery was because I had to go through the documents CLIENT had previously sent to [redacted] to determine what I needed to get from the Plaintiff to assist in our hearing and reflect the same types of information CLIENT had already given to Ms. [redacted] prior to my involvement.  Much of this information I had gotten from [redacted], who was kind enough to give me copies of what CLIENT had previously provided.  I spent about ten minutes on September 14, 2015 finalizing the discovery and sending it to CLIENT for his approval.  He got back with me with his approval of the documents the same day.  Also on September 14, 2015 I reviewed and signing the Child Support Order regarding the contempt and modification from the August 8, 2015 hearing that I had finally received from Child Support Enforcement.  This took me about fifteen minutes. At the end of this hearing, Judge [redacted] indicated that a hearing on my permanent Motion to Modify Child Support would be scheduled within the next few days.  The Court then notified us a short time later that the hearing would be scheduled for February 18, 2016.  This Notice of Setting was provided to CLIENT via mail and email. (I also reminded CLIENT about the hearing and it’s location in the email I sent him with the Order allowing me to withdraw in mid-January.) On September 17, 2015, CLIENT emailed me seven times about a potential suspension of his driver’s license for failure to pay his child support, and the hunting and fishing licenses that had already been suspended.  I responded to each of his emails.  I also corresponded with [redacted] about some additional discovery documents that I was sending to her that she had requested to supplement the responses CLIENT had already provided her.  During this discussion, [redacted] also pointed out to me that she believed that early in the proceedings CLIENT had failed to respond to a Counterclaim, and requested that I do so.  To avoid a default on this issue, I then spent just over an hour preparing an Answer to Counterclaim, which I immediately sent for filing. On September 28, 2015, I began compiling formal responses to outstanding discovery from [redacted].  CLIENT was not very forthcoming in his responses and my new assistant, Angie G[redacted], and I had to email CLIENT repeatedly and work very hard to compile proper answers. Between Angie and I, we emailed CLIENT at least 15 times trying to get him to respond properly. He always instructed us that the requested documents were in the documents he had already given us, or sent us elsewhere to look.  He did finally mail me much of what [redacted] needed, after this effort on our part to obtain it.  All total, it took over two and a half hours to get his discovery responses gathered, typed, legible, and in a form that I felt good about sending to [redacted]. There were numerous emails between me and [redacted] and me and CLIENT between September 28 and October 19, 2015, when I finally sent the discovery responses to [redacted]. On October 20, 2015, CLIENT asked me to try to arrange visitation between him and his daughters as he was going to be in Buffalo.  I called [redacted] and emailed her that day to discuss this, which took about 15 minutes.  I also corresponded with my client a few times throughout the day about the progress we were making.  I do believe CLIENT ended up meeting his daughters for a short visit, but I cannot be certain if he followed through with it or not, at this time. On November 3, 2015, [redacted] emailed me and told me that CLIENT had not filed his monthly update according to the Court’s order from our August 8, 2015 hearing.  I therefore emailed CLIENT with language I cut and pasted from the order, reminding him what his responsibilities were pursuant to that order.  He had received the Order from Angie via email in September, but I wanted to remind him again what it said.  We emailed back and forth several times throughout the day about this, which took about fifteen minutes. On November 14, 2015 I received several hundred pages of discovery responses from [redacted].  I went through all of the documents and this took me just over two hours. All of these responses were copied and provided to CLIENT, at the cost of $144.25 for his copies.  There was obviously a lot there to go through.  I haven’t counted the pages, but the stack of documents is well over six inches thick. On November 30, 2015, [redacted] sent a settlement proposal to me, which I reviewed for about five minutes.  I then forwarded it to CLIENT for his review and comment.  He was not favorable to the proposal and I let [redacted] know. The relationship between CLIENT and myself deteriorated during the course of the relationship, and on December 28, 2015, I filed a Motion to Withdraw.  There was a hearing held on this issue and my Motion was granted on January 13, 2016. The relationship deteriorated due to several factors: A. CLIENT had a pattern of being verbally abusive and threatening to me.  I repeatedly requested that he refrain from treating me this way, or I would be forced to withdraw. He did not curb his behavior. His behavior became so intimidating that in early January, I contacted the Buffalo Sheriff’s office to report his behavior and to ask them to alert me if he was in the area, as he has probation conditions which require him to report to the Buffalo Police department within an hour of arriving in Buffalo. (He was convicted of reckless endangerment against his ex-wife for trying to run her over with his [redacted], which was recorded on video by a bank surviellence camera.) The police agreed with me that they believed he was a legitimate threat and indicated they would call me when they knew him to be in the area.  B. He began making comments to me verbally and in emails that I thought amounted to real threats to his ex-wife, [redacted], and the Court.  I even contacted Bar Counsel about these threats and how to approach that issue.  I informed [redacted] and Judge [redacted] during our hearing concerning my Motion to Withdraw that I felt that CLIENT posed a real threat to them and his ex-wife, without revealing anything he had said to me specifically.  Please feel free to verify this with them. C. CLIENT would repeatedly do things that were contradictory to his best interest, and which would sabotage his case, regardless of my advice otherwise.  He made it impossible to represent him.  If you want examples of this, I would be happy to provide them. D. After about the first part of November, 2015, he repeatedly told me he was dissatisfied with my services, told me he was looking for another lawyer, and constantly demanded the return of his money. After the Court ordered that I withdraw, I made a copy of CLIENT’ entire file, and sent the original file to him in a sealed banker’s box.  I sent him the originals of everything, in the condition I had kept them in my office.  Everything was organized in file folders, tabbed and indexed, or in binders. I took a photo of the banker’s box that I put his file in before I sealed it up with duct tape. The banker’s box containing his file was then mailed to him via UPS and I have a tracking receipt which indicates that the box was delivered to his doorstep on January 29, 2016 at 10:39 a.m. After all was said and done, I billed CLIENT fairly for all the time I spent on his case.  In the end, he owed me $302.24, which I have told him I am not going to collect.  This was owed to me even after I DID NOT charge him for the time I spent at the initial status conference on July 9, 2015, I DID NOT charge him for any of the 89 text messages that were exchanged while I represented him, and I only charged him for a fraction of the time spent corresponding via the 218 separate emails that were exchanged.  CLIENT received bills every month, and not once did he object to a bill. Late in the case, he did send me a short email asking for an explanation of the bill, which I provided, but no objection was forthcoming after that.This is the course of my representation of CLIENT, to respond to his complaint against me. To address the potential violations of the rules, I respond as follows:1.3 DILIGENCE: I believe I was diligent in working CLIENT’ case.  I did everything he asked me to do, promptly.  I responded to every email, phone call and text from CLIENT in a timely manner.  I filed documents promptly, and within time lines established by the W.R.C.P. and the Court.  I reviewed documents he provided to me and made sure I understood the status of the case. I truly do not know what more I could have done to be diligent in representing CLIENT.  I accomplished many of the goals we set out to accomplish during our initial meeting, and the ones I was unable to accomplish were due to circumstances, not my lack of diligence.  For instance, I had a hard time reaching CLIENT’ goals for obtaining, and/or modifying visitation with his daughters, because the previous visitation orders required CLIENT to complete parenting courses and anger management courses which he never completed.  On top of that, the previous orders required that there be a supervisor on all visits, whom his daughters were comfortable with.  This was hard to accomplish under the circumstances, and the difficulties were created by CLIENT, not me.  I explained this to him, but he was unwilling to take the necessary steps to get more contact with his daughters.  Other than the visitation issue, I accomplished everything CLIENT hired me to do. 1.4 COMMUNICATION: I communicated freely and often with CLIENT.  I have transmittal letters which prove that I sent all pleadings and discovery to him, as well as dozens of emails from me and Angie which prove many documents were emailed to him as well.  There is not one time, not one, when CLIENT emailed me, or texted me, when I did not respond.  NOT ONE TIME. CLIENT did not always like my responses, but I was always truthful and direct with him about the status of his case.  If you wish for me to forward all of the emails and texts between CLIENT and myself to you, I would be more than happy to do so, as well as provide all proofs of correspondence via transmittal letter and email.1.5 FEES: I charged CLIENT our agreed upon rate of $200.00 per hour, which has been my customary rate for over five years.  I sent CLIENT an invoice each and every month.  The invoices clearly indicate that the starting point in his trust account was his deposit of $5,000.00.  I did mistakenly communicate with him that I thought his retainer had only been $3,000.00, but I explained that confusion to him, and even apologized for it, in an email dated February 4, 2015 (long after I had withdrawn.) I spent about 25 hours on CLIENT’ case over the course of about seven months.  I spent this time doing what I needed to do to accomplish CLIENT’ goals.  CLIENT owes me money after all is said and done, but I have indicated to him that I will not be trying to collect what is owed. 1.15 SAFEKEEPING OF PROPERTY: I have never refused to provide CLIENT’ documents to him.  His entire file consisting of all pleadings, all discovery with responses, the original documents he provided to me, and a copy of all of his invoices was delivered to his doorstep via UPS on January 29, 2016 at 10:39 a.m.  He received his file less than two weeks after I was given the go ahead to withdraw by Judge [redacted], and 19 days prior to his hearing to Modify Child Support which is scheduled for February 18, 2016.  Other than providing his entire file that was in my possession, and I mean every single document, I cannot understand what else he needs, or could claim I have refused to give him.  I kept copies of everything, and can provide this to Bar Counsel to provide to CLIENT again, if necessary.  However, CLIENT has all of his documents and has for  over three weeks. I do not believe I have violated the Wyoming Rules of Professional Responsibility in any manner.  I believe this complaint is motivated by several factors that are attributable soley toCLIENT: i. CLIENT is low functioning.  He has only a G.E.D. education and is incapable of comprehending the legal process and what went on during my representation of him. He admitted as much to me in more than one email.  He simply cannot understand what is going on. ii. CLIENT is mentally ill.  He suffers from depression and paranoia, which is verifiedby medical records that he filed in the civil court file after I withdrew from the case. On top of that, it is my personal belief that CLIENT has Borderline Personality Disorder.  He displays symptoms consistent with this mental affliction.  Specifically, he will lie, manipulate, and contort facts to be perceived as a victim in all situations. He fails to take responsibility for his own behaviors, and has no conscience about how he treats others in order to maintain his status as the victim.  Someone else is always to blame.  He blamed his ex-wife for ruining his life, then he blamed her first lawyer for “conning” him into signing a Stipulated Divorce Decree with $1,500.00 per month in child support.  Then he blamed Judge Cundiff for failing to set aside the Decree, which CLIENT willingly agreed to.  Then he blamed his bankruptcy lawyer and [redacted], for the loss of his Outfitter’s License.  Then he blamed [redacted] for alienating him from his daughters, even though he failed to take the necessary steps to have visitation with them again.  Now he is blaming me for failing  to diligently pursue his case, which is simply not true.  I predict that next, he will blame Bar Counsel for failing to hold me accountable for further “alienating him from his daughters”, etc.  It will never end with CLIENT.  He is simply unable to understand what is going on, and refuses to take accountability for his own actions. I know this is a lengthy response, but I must defend myself.  CLIENT is simply lying, and it must stop.  He has harassed me to the point of me informing law enforcement, and I do not feel safe in my home. CLIENT has lied about me on Facebook and defamed me on social media (Sheridan UpCycle.)  He has filed documents in the court file, containing only lies, trying to blame me for his situation.  Now he is attempting to compromise my reputation with Bar Counsel, and is asking that I lose my license.  It is disappointing, to say the least.  I put everything out there in this response, and can back up every fact I stated in this letter with documentation.  I will do so at your request. Thank you.Sincerely,  MEINECKE & SITZ, LLC M.  Jalie Meinecke MJM/ag Encl: Exhibits 1, 2 and 3.