The complaint was submitted by Leslie Brodie and came on the heels of a report issued by Judge Wallace Tashima of the Ninth Circuit, who was acting as a special master.
In the report issued by Tashima, Thomas Girardi, who is Miller's business partner, was found to have acted "recklessly"
Brodie was concerned that Howard Miller's role in the attempt to mislead the court was being ignored. As such, she decided to prusue the matter herself.
She alleges that both Miller and Girardi created an elaborate deception in order to shield themselves in the event any misconduct is discovered.
The complaint also alleges that "In addition to deceiving courts by their actions, both vexatiously and in multiple proceedings used judicial resources in a fraudulent manner in order to enrich themselves, causing injury to Dole Food Company and allegedly causing injuries to their clients, the plaintiffs in Nicaragua who desperately needed help" Brodie wrote.
Amid those revelations, speculations are abound that Miller will step-down from his position as the president of the State Bar very soon.
The full text of the complaint can be found online at: