In August 2020, your wife contacted the Board of Bar Overseers and filed a complaint alleging that I, as “her lawyer” for the Apothecary, had violated professional ethics and committed malpractice.

Did you know that?

Did you know that your wife concocted some story to the BBO in an effort to have me censured, admonished, and potentially disbarred?

Up until your wife’s BBO complaint, I would hear from the BBO exactly once a year, in September, reminding me to renew my bar card and pay the annual license fee. But on February 25, 2022, I received an email from the BBO regarding your wife’s August 3, 2020 complaint.

Why was the BBO contacting me on a year-and-a-half-old complaint?

The answer to that question and others that people might have about the background of this saga can be found below, in my response to the BBO, made in an effort to protect my license to practice law from the delusional allegations of your wife.

TTYS,

Jkb

Narrative Response

Christine Nordhaus (hereinafter “Christine”) and I first became friendly in the summer of 2017 when she was working as the farmer at The Littleton Community Farm (hereinafter “LCF”), a non-profit entity whose objectives are the alleviation of local food insecurity and providing general education relative to the origins of food, its production, and sustainability.[1] In the summer of 2017, when Christine was “in charge” of the operations at LCF, she and I had the opportunity to not only spend many hours together but also to start a friendship with one another.

In the fall of 2017, I welcomed Christine into my already established friend group, and soon thereafter Christine warned us that she “could never keep friends long-term because” she “always did something to anger them.” Jennifer Barlow, Katie Carruth, Cammy Bean, and I believed that we were different from all those former friends of Christine as our group of five had created such a deep bond through our friendships. We believed we would never be on the receiving end of Christine’s anger.

In the summer of 2018, my volunteer time with LCF continued alongside the strengthening of my friendship with Christine. Though we encountered a significant challenge to our friendship, we overcame that.[2]

In the fall of 2018, the Town of Littleton, where we both reside, was beginning to seriously discuss what parameters would frame the licensure of the two retail cannabis shops that would eventually open in Littleton. Primarily, the Town of Littleton, through its Board of Selectmen (hereinafter the “Board”) would enter into Host Community Agreements with two entities. Thereafter, those entities would be able to make application to our commonwealth’s Cannabis Control Commission for licensure to legally sell cannabis, as a recreational product, to the public from a brick-and-mortar shop in Littleton.

Christine and I both expressed an interest in opening up a retail cannabis shop in Littleton, and given our close friendship, we decided to partner with one another to realize this goal. See Exhibit A, Paragraphs 3, 4. And once we’d committed to working together as partners, we got to work. See Exhibit A, Paragraphs 5-44, inclusive.

This vocational time with Christine was some of the most enjoyable time I’d ever had in pursuit of something for which I might earn money. I woke up every morning with a sense of purpose and the good fortune to be able to spend time with Christine. Her good humor, generous nature, and strong work ethic made the days fly by, getting us ever closer to April 26, 2019, when we submitted our comprehensive proposal to the Board with the hope that we would soon be invited to come before the Board to make a formal presentation. See Exhibit B.

On May 20, 2019, Christine and I attended the Board’s regular meeting where made our formal business presentation to the Board. See Exhibit C, paragraph 6A. We had every expectation that the Town of Littleton would be entering into a Host Community Agreement with us given the reception we received. We were given the impression that had not one of the Board members been absent on the night of our presentation that the Board would have voted to enter into a Host Community Agreement with us. We were thrilled.

Then, all hell broke loose.

On June 7, 2019, I received a telephone call from then-Selectman Chase Gerbig (hereinafter “Chase”) who was calling to ask “some hard questions.” My heart sank as I suspected his call concerned a relationship that I’d had with the then-Chief of Police John Kelly (hereinafter “Kelly”) while I was serving the Town of Littleton as a member of the Board.[3] From mid-October 2013 to mid-February 2014, Kelly and I had a relationship that included scores of flirty email exchanges in addition to spending time with each other. The impetus for Chase’s call was to inform me that a resident in town had submitted a public records request seeking those specific emails.[4] Chase also mentioned “something about a letter.” His reference, though he did not know any specifics about “a letter,” concerned an anonymous letter that I sent to Kelly in mid-December 2013. I sent myself a near identical letter at the same time. My clouded judgment, accounted for in part by the limerence I felt for Kelly and in part by my then critically low level of vitamin B12, led me to think that, in the wake of receiving these letters, Kelly and I would be united under the mantle of the threat of exposure of our relationship to work together, i.e., spend copious amounts of time trying to ferret out the letter’s author.[5] My strategy to unite Kelly with me for this purpose spectacularly backfired, as instead of spending time with me, he distanced himself from me. The letter had a deadline of January 13, 2014. On January 7, 2014, I went to Kelly and confessed my amateurishly crafted letter. See Exhibit D. At the time of my confession, Kelly forgave my odd behavior. No criminal charges resulted as Kelly, though the putative “victim” of this act, saw it for what it was: a foolish attempt to bring us together by this fantastical “crisis.” The two of us resumed our extra-marital communications, clandestine coffee dates, and ongoing fascination with one another, and Kelly promised (orally and in writing) to return the letter to me once it came back from the state where he had sent it for fingerprinting.

Fast forward three weeks to late January 2014: a sergeant from the Littleton Police Department, David Leslie (hereinafter “Leslie”) came to my home and gave me two documents: one an anonymous letter addressed to the Board claiming that Kelly and his second-in-charge, Deputy Chief Matt King (hereinafter “King”), were “cooking the books on vacation time;” the other document was an inter-departmental email to inform “all staff” at the Littleton Police Department that King had been placed on administrative leave and that no one should talk about it. In fact, the then-chief Tom O’Dea referred to his directive as a “gag order.” Then Leslie told me why King had been put on leave: King had been accused of digitally raping a woman who had reported the alleged crime to the Ayer Police. Leslie added that King returned to work after King had paid the victim off to not go forward on charges against him. No charges were ever filed. Leslie brought this information to me as he was concerned that the Littleton Police Department was about to have an accused digital rapist at the helm.

On February 11, 2014, I brought this information to the then-chair of the Board, Ted Doucette (hereinafter “Ted). Unsure of what we should do, Ted asserted that we needed to call town counsel, Tom Harrington (hereinafter Tom”) to ascertain if we were required, in our role as Selectmen, to do something with the information. Atty. Harrington told us that while we did not have a “legal obligation” as selectmen to do anything with the information I had received from Leslie, we might feel as if we had a “moral one.” Ted and I felt that the matter needed to be looked into and told Tom as much. He advised us to bring the matter then-Town Administrator Keith Bergman, which we did and an investigation ensued. When Kelly discovered that I was the one who had brought the information to light, he was incensed, so much so that he said, “You’re never getting the letter back,” referring to the anonymous letter I had sent him, which he’d already promised to give back to me.

On February 14, 2014, just three days after I shared the information with Ted, Tom called me and asked that I come in to meet with him and Bonnie Holston[6] (hereinafter “Bonnie’), the then-Assistant Town Administrator for Budget and Finance for Littleton, as it had come to their attention that I had an “inappropriate relationship” with Kelly. According to Bonnie, in the fall of 2013, King had appeared in her office and while the two of them were “just casually chatting,” King told her of my relationship with Kelly. And so ensued a red-herring “sexual harassment” investigation, headed up by Tom and Bonnie. After various interviews[7] were conducted, there was a finding that no sexual harassment had occurred. Nevertheless, King and Kelly wanted me to not only recuse myself from any aspect of King’s hiring[8] but also to resign from the Board. When I refused to resign, Kelly threatened to use the letter against me and opined that I would be disgraced, disbarred, and potentially incarcerated. On March 7, 2014, I resigned, and while it may sound dramatic, I was terrified and thereafter slipped into a state of depressed hibernation.[9]

When I emerged from hibernation, I tentatively made my way back into public and into community life. So, when the opportunity to do something new in town—and for the town[10]—came up and I’d found a willing partner in Christine, I felt as though the ugliness of 2013-2014 was history, which is why when Chase called me to tell me that it was all being unearthed, I felt duty bound to tell Christine what had happened all those years ago. See Exhibit A, paragraph 46. Her initial reaction was “Those assholes.” But then soon thereafter, she changed her tune and wanted to remove my name from our proposal while preserving our 50/50 ownership of our business. See Exhibit A, paragraphs 47-56, inclusive. Given how I had been traumatized by the way I’d been treated in the late winter of 2014 (and the years that it took for me to recover from it all), I naturally had a reluctance in placing my trust in others. So, when Christine told me that she wasn’t comfortable memorializing our arrangement in writing (though she had said she would in the presence of both of our husbands), she asked me to take a “leap of faith” and reminded me of both our dear friendship and her love for me. See Exhibit A, paragraph 57. And I believed her, not only because she was my friend but also because I loved her as well.

Christine and I continued to work together—as partners. See Exhibit A, paragraphs 58-63, inclusive. On the night of June 19, 2019, Christine came to my home to socialize with me, Jennifer Barlow, and Cammy Bean. Christine was upset because she had earlier that day gone to the Town Office in Littleton with an updated, though otherwise identical proposal to the one we had submitted on April 26, 2019, save the removal of my name. See Exhibit A, paragraph 64.[11]

Christine and I continued to work together and refer to each other as co-equal partners, though she was now the “face” of the business. See Exhibit A, paragraphs 66-76, inclusive, and see Exhibit H.

Then, to my heartbreak and dismay, on August 5, 2019, Christine stabbed me in the back, making it clear (via text no less) that I was no longer part of our business and that I had “no part in the decisions I am making now.” See Exhibit A, paragraphs 77-80, inclusive.

Thereafter, at the urging of my family[12] and through the assistance of counsel, I contacted Christine to suggest that we come to an agreement and settle on a buyout. When this fell on deaf ears, I filed a lawsuit, ironic in that we had joked about the very same thing.[13] I filed my Complaint on November 5, 2019.

When I received her Countercomplaint, I was stunned by her mendacious claim that I had ever acted in way, shape, or form as her or the business’s attorney and had committed malpractice. While it is true that some of my contributions to the work we did together included interpreting and analyzing legal language—e.g., our town’s bylaws, the statutory framework underpinning retail cannabis in the commonwealth, reviewing our lease agreement, among other things—I never did so “as an attorney,” rather I did so based on my education and training, much in the same way that Christine contributed from her special set of skills.

As litigation does, the case dragged on and on, causing me considerably more heartache. When we finally entered into a settlement agreement on April 2, 2021, I was glad to be done with the case and done with having to spend any emotional energy on Christine.

However, the very next day, I received a text from Chuck Decoste, a then- and current member of the Board alerting me to the fact that I was featured in the “Straight Talk” section on Christine’s candidate’s website[14] where she used me[15] as an example of how very corrupt Littleton’s politics are. While I cannot seem to locate the screenshot of that webpage[16], I have included evidence of her “talking points” from that time. See Exhibit G. Christine had made similar spurious claims on her candidate’s website about me. For the record, she was not elected.

In early January of this year, Christine’s two children, Max and Peter, a college freshman and high school junior, respectively, wre overheard saying, “My mom sold the Apothecary for a million dollars.” As per the terms of our Settlement Agreement, I should receive 9.9% of the gross sale of the business. I brought this credible information to my lawyer on January 11^th. After confirming that Christine was no longer being represented by her counsel of record from our long-since-settled lawsuit, my lawyer contacted Christine directly and failed to get a straight answer from Christine about the sale, instead being told “I remain 100% owner.”

Then, on February 25^th, I received Christine’s complaint that she filed with your offices, dated August 3, 2020—more than a year and a half ago. My lawyer and I independently drew the same conclusion, i.e., once Christine was challenged about her sale of the business, she called the BBO to check in on the progress of the investigation into my alleged conduct.

Given that Christine’s complaint to you is dated August 3, 2020, it appears as though your office didn’t take action on the complaint until, as I suspect, hearing from her in early February of this year. It is conceivable that she dated her complaint “August 3, 2020” and didn’t deliver it to you until earlier this month. If that is the case, that’s a clear breach of our Settlement Agreement, executed on April 2, 2021. See Exhibit J, paragraph 3 (General Release), page 3.

Specific Answers to Your Enumerated Requests in Your Correspondence:

1.      See Exhibit D,

2.      Yes. I believe that my reasons for sending the letter have been explained above. But in summation: I sent the letter in the hope that the chief of police and I would work together, united under the mantle of crisis, to ferret out the author, thereby allowing us to spend time together on said investigation—especially given the fact that the holidays were coming up—with this as a viable excuse to take time away from our families

3.      No.

4.      No. I never served as Littleton Apothecary at any time. After Christine removed my name from the Apothecary’s filings with the Secretary of the Commonwealth’s Corporations Division, she mused, “You could be the Apothecary’s lawyer. That would really piss them off. Those assholes can’t fucking tell me who I can hire as my lawyer.” She never “hired” me for any legal work for herself personally or for the Apothecary. We were business partners.

5.      No.

6.      Christine hired Blake Messing, Esq. to represent the Apothecary’s interests relative to the award of the Host Community Agreement soon after she unilaterally cut me out of the business. See Exhibit I.

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[1] In the summer of 2013, the founder of LCF, Amy Tarlow-Lewis, requested my participation in the formation of this non-profit. Since that time, my involvement, which has been consistent and committed, has included volunteering in the production and harvesting of the food grown at LCF, teaching an LCF-sponsored class, as well as helping with the weekly distribution of the CSA shares.

[2] Earlier in the summer, our friend group had spent an afternoon on Jennifer Barlow’s pontoon boat. While out on the boat, Christine had treated me badly and deeply hurt my feelings by speaking to me in a degrading manner. This led to a short period of time where I distanced myself from Christine. The silence was broken when I went to Christine at LCF. In the barn, we had a heart-to-heart where she profusely apologized and pledged her loyalty to both me and our friendship. She said, “I’ll never give up on you because I love you.”

[3] I was elected in May of 2013 and resigned from the Board on March 7^th, 2014. See Exhibit A, paragraph 45.

[4] Her name is Jillian Shaw. I coached her son in a season or two of soccer and couldn’t understand what would have motivated her to make this public record request.

[5] As there had been some community outrage over the unanimous vote my Board had taken, on December 10, 2013, relative to the promotion of the town’s then-deputy chief of police to the position of chief of police which dispensed with the normal protocol of conducting a formal search, I used that “current event” as the impetus for the letter’s writer’s threat of exposure of my relationship with Kelly.

[6] In the early summer 2019, the Littleton Police were tasked with conducting an investigation into a vast sum of money that had been stolen from Littleton’s coffers. Bonnie was the lead suspect. In the first week of July, 2019, when Bonnie got word that she would soon be indicted, she killed herself, leaving two school-aged children motherless.

[7] Of King, Kelly, and myself.

[8] King’s formal interview before the Board had been initially scheduled for February 24, 2014 but had been indefinitely postponed due to the Board’s investigation into the allegation of digital rape.

[9] From April 2014 to February 2016, I wrote seven full-length novels. The first one, titled TRIX, was a fictionalized version of the time that I served on the Board. In the spring of 2021, I decided to take the TRIX manuscript and “defictionalize it, thereby creating a memoir. I have been publishing weekly episodes (Monday at 8:00PM) of GINNED UP available by subscription at Substack since July, 19, 2021. I have published thirty-five episodes over the course of thirty-five consecutive weeks. Before I’d published Episode 1, I received a letter from Kelly’s attorney advising me that his client knew of the publication and that they were going to be keeping tabs on it. Thereafter, I received two additional “warning” letters, the second of those two demanded that I cease publication and delete what I’d published thus far. I did not do this. In fact, I publicly responded to this third letter on my widely-read blog. See Exhibit E.

[10] Part of Christine’s and my proposal to the Board relative to opening a retail cannabis store was the creation of a foundation (my idea) endowed with three million dollars ($3,000,000.00) to fund “good works” in Littleton.

[11] Later, when Christine alleged that I had served as her lawyer, Cammy Bean swore an Affidavit about the events of that night as well as other observations Cammy made of Christine and me. See Exhibit F, paragraphs 16-20, inclusive, and paragraphs 22, 23.

[12] Christine and I enlisted the help of a financial analyst with whom we first consulted in the fall of 2018. This analyst predicted $12m in profits over the course of eight years. His was a conservative estimate. My children saw the potential income from the shop as freeing them from shouldering crushing college expenses. Worth noting: reportedly, Gage Cannabis in Ayer sold $31m of cannabis and cannabis-related products in 2021 alone.

[13] See Exhibit F, paragraph 19.

[14] Christine was running for a seat on the Board and the election was about a month away.

[15] Christine also used Bonnie (Holston) Fleck, deceased, as an example of corruption in town. You will recall that Bonnie was never indicted because she committed suicide before she was even arrested.

[16] Many months later that “Straight Talk” page was removed, though her website is still up at http://www.christineforlittleton.org.

* * * * *

For anyone who read all the way to this point and is interested in any of those Exhibits, please feel free to reach out. (This, of course, includes the press. 978.760.0482)