I. EVIDENTIARY ANALYSIS: Concealment & Manufacturing of Falsified Evidence

Enforcement & Ratification of Fraudulent, Backdated Invoices:


■  Morrow knowingly adopted and enforced backdated billing artifacts manufactured to bypass promotional obligations under the May 2025 "Red Hot Deal Days" campaign. By asserting validity over corrupted billing statements while concealing original audit logs, Morrow engaged in active documentary fraud.

Concealment & Spoliation of Account & Transaction Audit Logs:


■  When served with formal itemized inquiries demanding the statutory and transactional basis for undisclosed fees and suppressed promotional credits, Morrow systematically withheld primary promotional records, point-of-sale metadata, and account ledger histories.

Retaliatory Takedown Ultimatums & Extortionate Threats:


■  To suppress public disclosure and judicial review of falsified financial records, Morrow issued frivolous takedown demands and bad-faith legal ultimatums—attempting to leverage manufactured legal exposure to coerce the deletion of truthful consumer documentation and verified evidence.

II. EVIDENTIARY ANALYSIS: SUBORNATION, EXTORTION & PROCEDURAL SABOTAGE

As Corporate Legal Liaison for Verizon Wireless, Morrow played a direct and essential role in orchestrating a scheme to suppress material transactional records, submit fabricated evidentiary documents, and corrupt the official court record.

Specifically, Morrow actively subverted the administration of justice by facilitating, authorizing, and submitting unauthenticated, contradictory transaction receipts while concealing the definitive 28-digit transaction receipt for the May 18, 2025 transaction ($100.50 payment).

Morrow relied upon and provided these fraudulent and selective submissions—which falsely claimed Complainant declined device protection, while simultaneously asserting in defense pleadings that "no deal existed"—to assist counsel in filing bad-faith oppositions and motions to dismiss.

Morrow executed these tactics while possessing actual knowledge that Verizon conducted the official nationwide "Red Hot Deal" promotion (active May 15–28, 2025) and that material transactional data was willfully withheld from the tribunal to insulate Verizon Wireless from liability.

Furthermore, Morrow acted in active coordination with defense counsel and co-defendants to advance flatly contradictory corporate identity claims and jurisdictional denials—rendering Verizon's evidentiary submissions and procedural challenges entirely meritless.

In lieu of reaching a just settlement to resolve the case, Subject Dion Morrow abused his corporate position to the detriment of Verizon to exact personal revenge against Complainant following the publication of dionmorrow.info. What should have been straightforwardly resolved through fair compensation for Complainant’s documented losses has instead metastasized into an expansive multi-state conflict involving numerous individuals and institutional actors across Nevada, Illinois, and New York. By systematically withholding critical transactional records—including the 28-digit transaction receipt—and prioritizing personal retaliation over good-faith dispute resolution, Subject Morrow is directly responsible for needlessly escalating this matter into a high-exposure racketeering, public corruption, and civil rights controversy.

KEY EVIDENTIARY FILINGS

Click on the links below to access the specific court filings, and official records:

• 📄 Fabricated Customer Receipt
• 📄 Actual Receipt
• 📄 Financing
• 📄 Red Hot Deal

FALSE REPRESENTATION	DOCUMENTED FACT & PUBLIC RECORD
FALSE REPRESENTATION 1: Statements claiming Complainant "did not order device protection" or explicitly declined insurance during the May 18, 2025 transaction.	FACT 1: Material system records and transactional logs establish that device protection was part of the transaction. Verizon systematically concealed and refused to produce the definitive 28-digit transaction receipt for the $100.50 payment. Actual receipt and Financing Agreement rebut all Verizon defenses.
FALSE REPRESENTATION 2 : Assertions that "no promotional deal existed" or was available to Complainant during the relevant transaction window	FACT 2: Verizon's official nationwide promotion ("Red Hot Deal," active May 15–28, 2025) was active and applicable, directly refuting Morrow's transactional assertions.
FALSE REPRESENTATION 3 : Submission of partial, unverified store summary receipts as the "complete" transactional record of the May 18, 2025 purchase.	FACT 3: Official billing, merchant processing, and system audit logs confirm that the complete 28-digit transaction record was withheld to mislead the Court.
FALSE REPRESENTATION 4 : Representations that Cellco Partnership d/b/a Verizon Wireless was "erroneously sued" and maintains no direct liability or contractual nexus.	FACT 4: Defense counsel previously filed formal pleadings explicitly representing Cellco Partnership d/b/a Verizon Wireless in this action, establishing an undeniable corporate and litigation presence.

Cellular Sales denies the existence of the 'Red Hot Deal' promotional campaign during the May 15 to May 28, 2025 timeframe. The advertisement pictured below directly refutes this false representation by the company.





III. APPLICABLE STATE VIOLATIONS

Nevada Revised Statutes (NRS - Criminal & Civil Misconduct)
• 7.085 (Attorney Liability for Frivolous, Bad-Faith, or Deceptive Filings): Statutory liability subjecting counsel to court-ordered attorney’s fees, costs, and terminating sanctions for initiating or maintaining filings grounded in bad faith, bias, or improper collateral attacks.
• 197.020 (Bribery of Public Officer): Aiding, abetting, or inducing a judicial officer or court clerk to accept improper favors or bypass official duties.
• 197.110 (Misconduct of Public Officer): Soliciting, aiding, or abetting a public officer to defer or omit an official duty (such as deferring a mandatory default ruling under EDCR 2.20).
• 197.130 (Official Misconduct / Procuring Violation): Actively procuring, inducing, or benefiting from a public official’s misuse of office outside regular judicial hours.
• 199.010 (Bribery of Judicial Officer or Arbitrator):Giving, offering, or promising a bribe or illicit consideration to a judge or court official to influence a ruling or administrative setting.
• 199.480 (Criminal Conspiracy): Conspiring to obstruct justice and pervert the administration of law by using deceptive tactics to bias the tribunal.
• 207.190 (Coercion): It is unlawful for a person, with the intent to compel another to do or abstain from doing an act which the other person has a right to do or abstain from doing.




IV. COMPOUNDING DAMAGE, JUDICIAL COLLUSION, AND PENDING MOTION FOR TERMINATING SANCTIONS

As the result of Respondent’s perjured declarations, the presiding judge granted Defendant Cellular Sales’ Motion for Shortened Time by relying directly on fraudulent evidentiary submissions, including a fabricated transaction receipt and perjured declarations.

Also, Complainant was forced to withdraw and pull the entry of default to avoid wasting scarce judicial resources and expending extensive time litigating a Motion to Set Aside built entirely on perjured statements.

Furthermore, defense counsel's fraudulent filings and bad-faith maneuvers occurred in tandem with obvious judicial favoritism and collusion by the presiding judge. This forced Complainant to file a formal motion to disqualify the judge.

Most critically, Complainant filed an emergency Motion for a Temporary Restraining Order (TRO) on June 23, 2026. Due to the collusive and bad-faith actions of Respondent and co-counsel in manufacturing false extensions, filing perjured declarations on three separate occasions, and corrupting the record, Complainant has been completely denied a timely hearing on emergency injunctive relief, leaving ongoing irreparable harm unchecked indefinitely.

V. DEMAND FOR DISCIPLINARY AND CRIMINAL SANCTIONS

Complainant specifically requests that the State Bar investigate Counsel Carbo for perjury, subornation of perjury, wire fraud, and bad-faith abuse of process, and issue emergency disciplinary suspensions and appropriate criminal indictments.

PENDING PROCEEDINGS: TWO FORMAL MOTIONS FOR TERMINATING AND PUNITIVE SANCTIONS (NRS 7.085)

PLEASE TAKE FORMAL NOTICE that due to the pervasive, continuous, and coordinated subornation of perjury, bad-faith litigation tactics, fraudulent submittals, and procedural extortion executed by defense counsel and corporate respondents, there are currently two separate formal motions for terminating and punitive sanctions pending before the Court:

■  First Motion for Terminating and Punitive Sanctions: Filed against all named Defendants and defense counsel pursuant to NRS 7.085 (liability of attorney for maintaining frivolous, fraudulent, or bad-faith filings) and the inherent powers of the Court, seeking the immediate strike of defense pleadings, entry of default judgment, and punitive monetary assessments.

Defendants are in procedural default regarding Complainant’s Motion to Strike Baseless Filings and for Sanctions. Pursuant to the Nevada Rules of Civil Procedure and local court rules, Defendants were required to file and serve any opposition within the mandatory statutory timeframe.

Defendants completely failed to submit an opposition or request an extension of time, allowing the deadline to pass without response. Under local rules, an opposing party's failure to serve and file a written opposition constitutes a consent to the granting of the motion. Consequently, Defendants have conceded the factual and legal grounds set forth in the motion, rendering the requested sanctions and procedural remedies fully ripe for judicial entry by default.


■  Second Motion for Terminating and Punitive Sanctions: Filed as a standalone, targeted motion directly addressing the subsequent bad-faith maneuvers, continued reliance on known perjured declarations, manufactured procedural delays, and extortionate demands conditioning the withdrawal of moot filings upon the unlawful surrender of private web domains.

VII. PENDING CRIMINAL ACTIONS

In tandem with this complaint, Complainant is seeking criminal prosecution of Respondent in the State of Nevada, the State of Texas, and at the federal level, as detailed herein along with other co-conspirators.