The undersigned, <Redacted> (the “Complainant” or “Mr. <Redacted>”), respectfully submits this verified grievance to the New Hampshire Attorney Discipline Office pursuant to the New Hampshire Rules of Professional Conduct and the Rules of the Supreme Court of New Hampshire concerning the attorney disciplinary system. This grievance is filed against Attorney Elizabeth J. Barrett, Esq. (the “Respondent” or “Attorney Barrett”), a licensed attorney admitted to practice in the State of New Hampshire.
Mr. <Redacted> previously filed a formal complaint against Attorney Barrett on or about September 18, 2025. That complaint was subsequently withdrawn by Mr. <Redacted> in an effort to resolve the parties’ disputes privately and without resort to the disciplinary process. The attempt at private resolution was unsuccessful. Attorney Barrett’s conduct not only continued but materially escalated following the withdrawal. Accordingly, all claims raised in the September 2025 complaint are re-incorporated in this grievance and are set forth at Part IV below. A copy of the withdrawn complaint is appended at Annexure M.
This grievance encompasses the full scope of Attorney Barrett’s misconduct from 2013 to the present, including both the conduct originally documented in the withdrawn September 2025 complaint and the significant new misconduct that has occurred since. Attorney Barrett has, among many other things:
Continued to direct profanity, vulgar language, and abusive personal insults at Mr. <Redacted> in written communications;
Repeatedly contacted Mr. <Redacted>’ family members and professional associates, including renewed unsolicited written contact with Mr. <Redacted>’ mother on April 11, 2026 and direct contact with a business partner on April 2, 2026, notwithstanding repeated cease-contact demands made both personally and through counsel;
Weaponized the parties’ minor child as a financial leverage point, including by explicitly conditioning the initiation of a Termination of Parental Rights petition on the satisfaction of her personal financial demands;
Made repeated threats, including threats invoking extradition and criminal consequences, and a threat to “end” Mr. <Redacted>’ “life” if he filed additional complaints against her;
Retaliated for Mr. <Redacted>’ protected right to file a bar complaint by escalating rather than moderating her conduct, and responded to his expressions of despair with mockery and further threats;
Raised serious accusations of sexual misconduct against Mr. <Redacted> exclusively within the context of financial disputes, without ever having raised them with law enforcement;
Conditioned the filing or withdrawal of legal proceedings on Mr. <Redacted>’ acquiescence to her financial demands; and
Continued her pattern of using defamation threats to suppress truthful consumer reviews of her professional services.
Mr. <Redacted> has repeatedly and in unmistakable terms demanded that Attorney Barrett cease contacting him, his mother, his extended family, and his business associates, and has expressly warned that a restraining order would be sought if the contact continued. Those demands have been ignored. Mr. <Redacted>’ family intends to file for a restraining order against Attorney Barrett and will supplement this grievance accordingly.
The conduct documented in this grievance and the annexures is, in the respectful submission of the undersigned, incompatible with continued membership in the New Hampshire Bar without substantial discipline. The respondent’s conduct continued unabated, and in fact escalated, after the withdrawal of the September 2025 complaint, demonstrating that Mr. <Redacted>’ good-faith attempt at private resolution was ineffective.
Mr. <Redacted> respectfully requests a prompt and thorough investigation, the imposition of appropriate discipline up to and including suspension or disbarment, and any such further relief as the Attorney Discipline System deems just.

II. PARTIES, JURISDICTION, AND VENUE

A. The Complainant

Complainant <Redacted> is a natural person currently residing outside the United States. Mr. <Redacted> is the father of the parties’ minor child, referred to in this grievance by his first name only, Braden, for the minor’s privacy. Mr. <Redacted> has been the subject of long-running domestic-relations proceedings in the State of New Hampshire captioned, among other dockets, <Redacted>.
Mr. <Redacted> has authored consumer reviews lawfully posted on publicly available attorney-rating platforms, including Avvo, which reviews describe Mr. <Redacted>’ honest experience of Attorney Barrett’s conduct. Mr. <Redacted> denies authorship of the specific April 1, 2026 Avvo review that Attorney Barrett attributes to him; see Annexure F. Those reviews have repeatedly been used by Attorney Barrett as the pretext for further harassment of Mr. <Redacted> and his loved ones.

B. The Respondent

Respondent Elizabeth J. Barrett, Esq., is a member of the New Hampshire Bar practicing in Portsmouth, New Hampshire. Attorney Barrett is the mother of Braden. Attorney Barrett has, throughout the period relevant to this grievance, represented herself in the domestic-relations litigation while simultaneously holding herself out to the public as a family-law attorney.
Attorney Barrett’s status as a licensed New Hampshire attorney imbues her communications with opposing parties, in particular a pro se or limited-means opposing party like Mr. <Redacted>, with a weight, authority, and coercive potential that the conduct of a non-attorney litigant would not carry. That elevated duty is precisely what Attorney Barrett has repeatedly violated.

C. Jurisdiction

Attorney Barrett is admitted to the practice of law in New Hampshire and is subject to the jurisdiction of the New Hampshire Attorney Discipline System under New Hampshire Supreme Court Rule 37 and the New Hampshire Rules of Professional Conduct. This grievance arises from conduct occurring in whole or substantial part within New Hampshire and in the course of Attorney Barrett’s participation as an attorney in a New Hampshire domestic-relations case.

III. PROCEDURAL HISTORY AND THE WITHDRAWN SEPTEMBER 2025 COMPLAINT

The full procedural history of this dispute is lengthy, spanning more than a decade. For purposes of this grievance, the following summary is sufficient:
The parties have been involved in a New Hampshire domestic-relations matter, Docket No. <Redacted>, since approximately 2013.
On or about September 18, 2025, Mr. <Redacted> filed a formal complaint against Attorney Barrett with the New Hampshire Attorney Discipline Office. A true and accurate copy of that complaint is appended as Annexure M. Mr. <Redacted> subsequently withdrew that complaint in a good-faith effort to resolve the parties’ disputes privately and without resort to the disciplinary process. That effort was unsuccessful; Attorney Barrett’s conduct not only continued but escalated following the withdrawal.
The September 18, 2025 complaint described, among other things: (i) Attorney Barrett’s ambush at a January 6, 2025 hearing via a voluminous, largely irrelevant document production deliberately designed to prejudice Mr. <Redacted>’ ability to meaningfully participate from his overseas residence; (ii) her improper use of defamation-style threats and platform-complaint processes to suppress lawful consumer reviews of her legal services on Google and Avvo; (iii) her improper pursuit of collection mechanisms in jurisdictions in which Mr. <Redacted> has never resided; and (iv) direct verbal threats made by Attorney Barrett that she would “end [Mr. <Redacted>’] life” if any further complaints were filed against her.
On or about September 29, 2025, Attorney Barrett responded to Mr. <Redacted> by email in a message titled, in relevant part, “Bar complaint.” That email, appended as Annexure C, makes no attempt to refute the allegations, contains repeated profanity, repeats extraordinarily serious and unsubstantiated criminal-grade allegations, and includes explicit language that “Being extradited might be the best thing that ever happens to you.” The September 29, 2025 email is strong documentary evidence of Attorney Barrett’s retaliatory animus.
In the months following the September 2025 complaint and its subsequent withdrawal, Attorney Barrett’s conduct, far from being moderated, escalated, culminating (as of the date of this grievance) in the April 10–11, 2026 emails discussed at length below, the April 2, 2026 contact with Mr. <Redacted>’ business partner, and the April 11, 2026 renewed contact with Mr. <Redacted>’ mother.
Mr. <Redacted>’ family has issued repeated written cease-contact demands to Attorney Barrett. Despite those demands, Attorney Barrett has continued to initiate unsolicited contact with Mr. <Redacted>’ family members.
Notice to cease contact. Following the December 2024 “Christmas list” contact with Mr. <Redacted>’ mother (discussed at Part IV(F) and Annexure K), Mr. <Redacted> placed Attorney Barrett on unequivocal written notice that any further contact with his family members was unwelcome, objected to, and that a restraining order would be sought if the contact continued. That notice was conveyed directly by Mr. <Redacted> in writing and independently through counsel. Attorney Barrett’s renewed April 11, 2026 contact with Mr. <Redacted>’ mother was made in knowing disregard of those demands. Her conduct violates Rule 4.4(a), Rule 8.4(d), and the cease-contact demands she received directly from Mr. <Redacted> and his counsel.
Prior disciplinary history. What distinguishes this grievance is the volume, pattern, duration, and express retaliatory character of the misconduct documented, together with Attorney Barrett’s continued and escalating conduct after Mr. <Redacted>’ good-faith withdrawal of the September 18, 2025 complaint.

IV. FACTUAL BACKGROUND: RE-INCORPORATED FROM THE WITHDRAWN COMPLAINT

This Part IV restates and re-incorporates, as independent allegations in this grievance, the factual matters that were the basis of the withdrawn September 18, 2025 complaint. Those claims were never adjudicated or considered by the Attorney Discipline Office. They are set forth here in full because the conduct described forms part of the continuing pattern and because this grievance is intended to stand as a comprehensive, self-contained filing.

A. The Procedural Ambush at the January 6, 2025 Hearing

Attorney Barrett filed a motion for contempt in late 2024 seeking, among other things, aggressive collection of purported arrears relating to child support.
At the January 6, 2025 hearing, Attorney Barrett served on Mr. <Redacted>, a pro se overseas litigant who at that time was not represented by counsel, a last-minute document dump labeled as “exhibits” for the hearing. The production included a 463 KB PDF and, separately, a 96.1 MB ZIP archive of further materials, the latter delivered in a manner calculated to overwhelm Mr. <Redacted>’ ability to review, object to, or meaningfully respond to the materials during the hearing.
This tactic was not a legitimate presentation of evidence. It was a deliberate procedural ambush aimed at exploiting Mr. <Redacted>’ status as a pro se overseas party with limited ability to retain immediate counsel or to review voluminous materials in real time.

B. Weaponization of Online-Review Platforms

Mr. <Redacted> has, at various times, posted truthful consumer reviews of Attorney Barrett’s legal services on publicly available rating platforms, including Google and Avvo.
Attorney Barrett has repeatedly, in written correspondence and through threats of defamation litigation, demanded that Mr. <Redacted> “remove these posts immediately” and “desist from further harassment,” equating lawful consumer speech with harassment and defamation. See Annexure D (December 3, 2024 email, “Harassment/Reviews”).
Attorney Barrett has, by her own admission, previously pursued defamation-style actions against other persons who posted negative reviews of her professional services, resulting, by her own description, in those persons ceasing to post. This conduct demonstrates a pattern of using legal threats to suppress lawful consumer speech, which is itself abuse of process and an independently sanctionable form of attorney misconduct.

C. Jurisdictional Overreach Against an Overseas Resident

Mr. <Redacted> resides outside the United States. Attorney Barrett has, despite this fact being known to her, pursued or threatened to pursue collection and other legal mechanisms against Mr. <Redacted> in jurisdictions in which he has never resided and over which there is no proper personal jurisdiction.
Attorney Barrett’s threats to trigger extradition, to have Mr. <Redacted> arrested upon return to the United States, and to “spend the rest of her life” pursuing him across jurisdictions form part of a pattern of jurisdictional overreach designed to harass rather than to vindicate legitimate legal rights.

D. Direct Threats Following the Prior Complaint

Following Mr. <Redacted>’ exercise of the protected right to file a grievance with the New Hampshire Attorney Discipline Office, Attorney Barrett communicated, in words or substance, that if Mr. <Redacted> filed any further complaints against her, she would “end [his] life.”
This is not hyperbole parsed from a heated text exchange. It is a direct threat, made by a licensed attorney, in retaliation for a protected and express grievance filing. It is memorialized across multiple contemporaneous communications.

E. Pattern of Profanity, Abuse, and Unprofessional Conduct

Throughout the relevant period, Attorney Barrett has communicated with Mr. <Redacted>, an opposing party, using profanity, vulgar personal insults, and abusive language that no member of the New Hampshire Bar should ever direct to an opposing party, a client, or indeed any person. A representative (but not exhaustive) compendium of such communications is provided at Annexures G, H, and I.

F. Harassment of Mr. <Redacted>’ Family

Attorney Barrett has, on multiple occasions during the relevant period, initiated unsolicited correspondence with Mr. <Redacted>’ mother, <Redacted>, and other members of Mr. <Redacted>’ family. In at least one instance she sent letters, photographs, and what Mr. <Redacted>’ family experienced as emotionally abusive correspondence, continuing even after Mr. <Redacted> placed her on unequivocal written notice (both directly and through counsel) that such contact was unwelcome and that a restraining order would be sought if it continued.

G. Use of the Child as Emotional Leverage

Attorney Barrett has, with remarkable regularity, invoked the parties’ minor child in communications that are fundamentally directed not to the child’s welfare but to the attack, shaming, or coercion of Mr. <Redacted>. This is addressed in detail in Part VI(C) below.

V. ONGOING AND ESCALATING MISCONDUCT (SEPTEMBER 2025 TO PRESENT)

This Part V is the heart of this grievance. It documents misconduct that has occurred since September 2025, which misconduct demonstrates that Attorney Barrett has not moderated her conduct; indeed, her conduct escalated after the withdrawal of the September 2025 complaint.

A. April 11, 2026: Attorney Barrett’s Renewed Contact with Mr. <Redacted>’ Mother

On Saturday, April 11, 2026, more than sixteen months after Mr. <Redacted> placed Attorney Barrett on unequivocal written notice to cease all contact with his family, and after Mr. <Redacted> had withdrawn his September 2025 complaint in a good-faith effort at private resolution, Attorney Barrett once again initiated unsolicited written contact with Mr. <Redacted>’ mother, <Redacted>.
That contact occurred notwithstanding:
Mr. <Redacted>’ repeated, written, and unambiguous demands that Attorney Barrett cease all contact with his family;
The existence of prior written cease-contact demands from Mr. <Redacted>’ family, which Attorney Barrett disregarded;
The fact that the September 18, 2025 complaint, since withdrawn, had specifically identified harassment of Mr. <Redacted>’ family as a central concern, placing Attorney Barrett on clear notice; and
A licensed attorney contacting the mother of an opposing party, when that contact has no apparent connection to the litigation.
The April 11, 2026 contact is, standing alone, sufficient evidence of willful and intentional harassment. It follows in direct line from, and is materially indistinguishable from, the December 2024 episode in which Attorney Barrett mailed Mr. <Redacted>’ mother a “Christmas list” and accompanying materials, correspondence which Mr. <Redacted>’ family experienced as abusive and intrusive and which prompted repeated written cease-contact demands from Mr. <Redacted>’ family. See Annexure K.

B. April 2, 2026: Harassment of Mr. <Redacted>’ Business Partner

On or about April 2, 2026, Attorney Barrett directly contacted a business partner of Mr. <Redacted>, a person with no involvement whatsoever in the parties’ domestic-relations dispute, no relationship to Attorney Barrett, and no legitimate reason to be receiving communication from opposing counsel in a long-running family matter.
The contact was so upsetting, so inappropriate, and so unsettling that the business partner was compelled to block Attorney Barrett across the relevant communication channel. Mr. <Redacted>’ business partner has expressed in writing her fear and distress at being contacted by Attorney Barrett.
The pattern is unmistakable. Attorney Barrett, unable to secure from Mr. <Redacted> the financial concessions she demands, has repeatedly, deliberately, and over a sustained period of time projected the force of her disputes with him outward onto third parties who are entirely uninvolved in those disputes. She has done so knowing full well, as a licensed attorney, that (i) there is no lawful purpose for such contact; (ii) the contact is likely to cause substantial distress; and (iii) the contact may itself constitute a tort, a predicate for civil protective relief, and in some circumstances a crime.
See Annexure L for the specific documentation of the April 2, 2026 contact with Mr. <Redacted>’ business partner.

C. Restraining Order Warning and Continued Disregard

Following Attorney Barrett’s December 2024 contact with Mr. <Redacted>’ mother, Mr. <Redacted> placed Attorney Barrett on unequivocal written notice that a restraining order would be sought if any further contact with his family occurred. Despite that warning, Attorney Barrett renewed unsolicited contact with Mr. <Redacted>’ mother on April 11, 2026. Mr. <Redacted>’ family intends to file for a civil restraining order and will supplement this grievance accordingly.
That a licensed New Hampshire attorney’s conduct has made the pursuit of a civil protective order by the family of an opposing party a serious consideration reflects on the integrity of the Bar and the confidence of the public in the profession.

D. The April 10–11, 2026 Email Barrage

On April 10, 2026, Attorney Barrett emailed Mr. <Redacted> a message with the subject line “Why you so obsessed with me?”; the body of which consisted, in substance, of a single embedded audio link to a song titled “Obsessed.” The intended effect of such a message, from a licensed attorney to an opposing party, is plainly to taunt, to demean, and to provoke. It has no legitimate legal purpose. See Annexure B.
Within approximately nineteen hours of that email, on April 11, 2026, Attorney Barrett sent Mr. <Redacted> a further email with the subject line literally “Get a fucking life!”. Both the subject line and the body of which consist of profanity, personal attacks, and abuse. The email in full is reproduced at Annexure A. Representative extracts include:

“Go fuck your girlfriend! Leave me alone and get a fucking life! Grow the fuck up! I’m raising a mature 13 year old while you flail around like you’re fucking 7.”

– Attorney Barrett, April 11, 2026

“Just because you’re miserable with your ugly ass life doesn’t mean you need to take it out on me. Braden deserves better.”

– Attorney Barrett, April 11, 2026

This correspondence contains four uses of the word “fuck” or its derivatives in a single email, appearing in both the subject line and the body, from a licensed New Hampshire attorney to a self-represented opposing party in a pending family-law matter. The communication falls squarely within the conduct addressed by Rule 8.4(g).
Critically, the April 11, 2026 email was sent the same day as Attorney Barrett’s renewed unsolicited contact with Mr. <Redacted>’ mother. The two incidents are not separate; they are sides of the same coin. Attorney Barrett used April 11, 2026 to project harassment both at Mr. <Redacted> directly and at his family, simultaneously.

VI. DETAILED ANALYSIS OF ATTORNEY BARRETT’S MISCONDUCT

This Part organizes the evidence by thematic category. Each category is independently sanctionable; taken together they establish a pattern of conduct that leaves no doubt as to Attorney Barrett’s disregard for the New Hampshire Rules of Professional Conduct.

A. Pattern of Profane and Vulgar Communications

Attorney Barrett’s use of profanity and vulgar insults in her direct communications with Mr. <Redacted>, an opposing party, is pervasive, sustained, and well documented. The text-message record alone contains repeated and pervasive use of “fuck” and its derivatives (40+ documented instances), “shit” (25+ instances), and other vulgar terms. See Annexure G for the full compendium.
Representative verbatim examples of Attorney Barrett’s language in direct communication with Mr. <Redacted> include (dates are drawn from the timestamp headers visible in the source iMessage screenshots reproduced across Annexures G through J, N, O, P, and Q):

“So fuck off with that shit.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“You didn’t have to do shit.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“Bullshit with your 300k income.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“I don’t need you to keep saying the same fucking story that you’ve been telling yourself for the past 13 years.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“Then why delete half the shit on Reddit?”

– Attorney Barrett (text, Thu, Oct. 9, 2025, 09:39)

“Be a fucking man and take care of your kid.”

– Attorney Barrett (text, ca. Oct. 13, 2025)

“You got me pregnant mother fucker.”

– Attorney Barrett (text, ca. Oct. 13, 2025)

“Clearly, the funds are never coming and you’re just a fucking piece of shit. Go get a fucking job.”

– Attorney Barrett (text, Tue, Oct. 14, 2025)

“Because you’re fucking dumb and you lie all the time.”

– Attorney Barrett (text, Tue, Oct. 14, 2025)

“No wonder you’re fucking delusional.”

– Attorney Barrett (text, Tue, Oct. 14, 2025)

“You’re fucking delusional and would benefit from a lobotomy.”

– Attorney Barrett (text, Sun, Oct. 19, 2025, 02:54)

“I hope you enjoy bending over in prison with your bitch ass.”

– Attorney Barrett (text, Sun, Oct. 19, 2025, 02:54)

“Your morals are fucked. Grow the fuck up.”

– Attorney Barrett (text, ca. Oct. 9, 2025)

“I’ve tried with you. I’ve fucking tried.”

– Attorney Barrett (text, ca. Oct. 9, 2025)

“Enjoy your money and your ugly ass women.”

– Attorney Barrett (text, ca. Oct. 9, 2025)

“You need to get a fucking life!”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“So your criminal cases with fucking meaningless people is more important than Braden!”

– Attorney Barrett (text, ca. Oct. 18, 2025)

“Get a fucking life! … Go fuck your girlfriend! … Grow the fuck up!”

– Attorney Barrett, email (Annexure A – Email Get a fucking life! (April 11, 2026).eml), Saturday, April 11, 2026, 17:21 EDT

“Pay what you owe and leave me the fuck alone.”

– Attorney Barrett, email (Annexure S-4 – Email Termination of Parental Rights Sibling Death Response (April 10, 2026).eml), Termination of Parental Rights thread

“Fuck all the way off… sit and spin on it.”

– Attorney Barrett, email (Annexure S-3 – Email IMO TPR Petition Service Address Thread (September 29, 2025).eml), IMO TPR thread

“You are a fucking nightmare and I’m done with your abuse you fucking troll.”

– Attorney Barrett, email (Annexure S-3 – Email IMO TPR Petition Service Address Thread (September 29, 2025).eml), IMO TPR thread

The New Hampshire Rules of Professional Conduct do not contain an explicit rule prohibiting profanity in attorney communications. They do not need to. An attorney who, over a span of multiple years, calls an opposing party a “fucking piece of shit,” a “motherfucker,” a “delusional” lobotomy-candidate, and tells him to “bend over in prison with [his] bitch ass,” has engaged in conduct that directly violates several provisions of the Rules of Professional Conduct as applied by this Office:
Rule 4.4(a) (Respect for the Rights of Third Persons): “In representing a client, a lawyer shall not use means that have no substantial purpose other than to embarrass, delay, or burden a third person.” Profane personal insults directed at an opposing party have no substantial purpose other than to embarrass and burden that party, and per se violate Rule 4.4(a).
Rule 8.4(d) (Misconduct): “It is professional misconduct for a lawyer to engage in conduct that is prejudicial to the administration of justice.” Profane vitriol injected into an active family-law matter is inherently prejudicial to the administration of justice as it poisons the communication channels on which the Court must rely.
Rule 8.4(g) (Misconduct, Harassment): to the extent that sustained gendered, political, and appearance-based epithets directed at Mr. <Redacted> and his girlfriend (e.g., “ugly ass women,” “your ugly ass girlfriend who needs to perform plastic surgery on that nose of hers”) are read as harassment on the basis of sex or appearance, Rule 8.4(g) is independently implicated.
See Annexure G for the more complete compendium.

B. Personal Attacks on Mr. <Redacted> and Third Parties

Apart from sheer profanity, Attorney Barrett has made a practice of personally attacking Mr. <Redacted> in a manner no attorney should ever direct at an opposing party. Representative examples include:

“No you are just pure evil.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“You destroyed your own life.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“You can only be a miserable prick for so long before it catches up to you.”

– Attorney Barrett (text, ca. Sept. 24, 2025)

“Actually, I’m not. I can sleep with myself at night knowing I’m not a miserable prick that abandoned my kid and treats people like shit.”

– Attorney Barrett (text, Tue, Oct. 14, 2025)

“I just don’t understand how you can be so evil.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“Clearly, your mother doesn’t know how to parent.”

– Attorney Barrett (text, Tue, Oct. 14, 2025)

“You are worse than trump! At least he takes care of his kids.”

– Attorney Barrett (text, ca. Oct. 9, 2025)

“I want nothing to do with your crazy ass fucking family. They’re just as delusional as you.”

– Attorney Barrett (text, Tue, Oct. 14, 2025)

“Your ugly ass girlfriend who needs to perform plastic surgery on that nose of hers.”

– Attorney Barrett (text, Sun, Oct. 19, 2025, 02:54)

“You know I don’t believe anything you say… paying your deadbeat ass family and lawyers before being responsible for B.”

– Attorney Barrett (text, ca. Jan. 3, 2026)

“Your attempts to trash me, as the mother of your kid, is disgusting. Keep whatever twisted reality you tell yourself or your family/friends to yourself.”

– Attorney Barrett, email (Annexure E – Email Special Appearance Motion Response (November 29, 2024).eml), Nov. 29, 2024

“Braden is almost 12. What’s your excuse for showing-up twice and then being a dead beat? Grow up!”

– Attorney Barrett, email (Annexure E – Email Special Appearance Motion Response (November 29, 2024).eml), Nov. 29, 2024

“Being extradited might be the best thing that ever happens to you.”

– Attorney Barrett, email (Annexure C – Email Re Bar complaint (September 29, 2025).eml), Sept. 29, 2025

“All you cared about is/was money and look where it’s gotten you.”

– Attorney Barrett, email (Annexure C – Email Re Bar complaint (September 29, 2025).eml), Sept. 29, 2025

“Grow the fuck up! I’m raising a mature 13 year old while you flail around like you’re fucking 7.”

– Attorney Barrett, email (Annexure A – Email Get a fucking life! (April 11, 2026).eml), April 11, 2026

These are not, and cannot be, characterized as the exchange of heated words between equals. They are written communications sent by a member of the New Hampshire Bar to an opposing party in a pending domestic-relations matter. Such conduct is inconsistent with the standards expected of a member of the New Hampshire Bar.
Mr. <Redacted> has at no time responded to Attorney Barrett with sustained personal abuse or escalation. Where the record reflects any responsive profanity by Mr. <Redacted>, that responsive speech was an outraged reaction to Attorney Barrett’s refusal to cease communication and was accompanied by repeated and unmistakable demands to stop: demands which Attorney Barrett, again, ignored.

C. Weaponization of the Parties’ Minor Child

Attorney Barrett has, across hundreds of documented messages, invoked the parties’ minor child, Braden, as a tool of emotional leverage, shaming, coercion, and attack rather than as a matter of legitimate parental co-discussion. The pattern is unmistakable and deeply troubling. Representative examples:

“God blessed me with Braden.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“You’d rather be miserable and block your blessing.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“All you do is bring up my pregnancy.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“While my vagina was destroyed in child birth…”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“Be a fucking man and take care of your kid.”

– Attorney Barrett (text, ca. Oct. 13, 2025)

“You got me pregnant mother fucker.”

– Attorney Barrett (text, ca. Oct. 13, 2025)

“He’s your child. … Yeah because you’re a pos.”

– Attorney Barrett (text, ca. Oct. 13, 2025)

“Sell your meta glasses so your kid can have some.”

– Attorney Barrett (text, ca. Oct. 13, 2025)

“Should I run a dna test on b so your whole family can see the missing fruit?”

– Attorney Barrett (text, Tue, Oct. 14, 2025)

“Just send what you owe and I’ll file the TPR. I just talked to Braden and he wants you off of his birth certificate. When I tell you it’s now or never for you to fix this… it’s not a joke.”

– Attorney Barrett (text, ca. Oct. 9, 2025)

“Clearly, you, as a single man, can’t live off of 1 million dollars a year… what makes you think your fucking $230k over the course of 13 years covers even half of Braden’s expenses??”

– Attorney Barrett (text, ca. Oct. 19, 2025)

“Braden deserves better.”

– Attorney Barrett, email (Annexure A – Email Get a fucking life! (April 11, 2026).eml), Saturday, April 11, 2026, 17:21 EDT

“The only way I’m going to file this termination is if I’m in a better place financially. You haven’t lived up to your word and continuing to do this doesn’t help.”

– Attorney Barrett, email (Annexure F – Email Avvo Review Response (April 1, 2026).eml), Wednesday, April 1, 2026, 14:53 EDT

“I will file termination of parental rights paperwork. Pay what you owe, and take down all of your fabricated/imitated content, including the website, reviews, and twitter accounts.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“Maybe consider paying what you owe currently and paying consistently, or paying some sort of lump sum for the future, and I won’t continue to pursue court action.”

– Attorney Barrett, email (Annexure E – Email Special Appearance Motion Response (November 29, 2024).eml), Friday, Nov. 29, 2024, 10:31 EST

The last two quotations are the most significant for purposes of this grievance. In them Attorney Barrett explicitly ties the initiation, continuation, or withdrawal of legal proceedings concerning Termination of Parental Rights, proceedings that by their nature must be governed by the best interests of the child, to the state of her personal financial grievances against Mr. <Redacted>. An attorney who holds the initiation of TPR proceedings hostage to a private financial dispute has abandoned the fiduciary posture required of an officer of the court.
Annexure I contains additional text-message excerpts documenting the weaponization of the parties’ child.

D. Harassment Despite Explicit Demands to Cease Contact

Mr. <Redacted> has, on numerous documented occasions, explicitly, unambiguously, and in writing demanded that Attorney Barrett cease contacting him. Representative examples of Mr. <Redacted>’ cease-contact demands include:

“I want nothing to do with you.”

– Mr. <Redacted> (text, ca. Oct. 13, 2025)

“I do not want anything to do with your child.”

– Mr. <Redacted> (text, ca. Oct. 13, 2025)

“I don’t want to talk about the past.”

– Mr. <Redacted> (text, ca. Sept. 22, 2025)

“Please stop talking to me. I’m warning you to stop.”

– Mr. <Redacted> (text, Tue, Oct. 14, 2025)

“Again I am telling you to stop messaging me.”

– Mr. <Redacted> (text, ca. Oct. 13, 2025)

“I don’t want to talk to you.”

– Mr. <Redacted> (text, Sat, Jan. 3, 2026)

“If you contact my family again, a restraining order will be taken against you.”

– Mr. <Redacted>, email (Christmas list.eml), in response to Attorney Barrett’s December 2024 contact with his mother

Attorney Barrett’s response to each of these cease-contact demands was not to stop. Her response was, in each instance, to send further messages, frequently with more profanity, more personal attacks, or fresh insults. For example, when Mr. <Redacted> told her to stop contacting him, her subsequent replies included, literally:

“I don’t need you to keep saying the same fucking story you’ve been telling yourself for the past 13 years.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“Just fucking leave me alone.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“I think you forgot I’m not a fucking idiot.”

– Attorney Barrett (text, Thu, Oct. 9, 2025, 09:39)

See Annexure J for the full compendium of Mr. <Redacted>’ cease-contact demands and Attorney Barrett’s continued contact thereafter. A licensed attorney has an elevated duty not to engage in communications that have no substantial purpose other than to embarrass, delay, or burden a third person, per Rule 4.4. That duty is defeated beyond any reasonable argument when the attorney persists notwithstanding an express cease-contact demand from the opposing party.

E. Threats, Intimidation, and Veiled Coercion

Attorney Barrett’s conduct ventures repeatedly into outright threats, whether of legal escalation, criminal consequences, personal harm, or lifetime pursuit. Representative examples:

“I’m not your enemy but the police are certainly coming for you.”

– Attorney Barrett (text, ca. Oct. 9, 2025)

“I wasn’t lying when I said the Feds contacted me. Enjoy your money laundering.”

– Attorney Barrett (text, ca. Oct. 9, 2025)

“You know the Feds are watching you though, right? Filing all this shit with Australia that you have no money, is going to shoot you in the foot…”

– Attorney Barrett (text, ca. Oct. 13, 2025)

“You need to send funds in the next 20 days or this is getting forward to the Feds. Just giving you a heads up!”

– Attorney Barrett (text, ca. Oct. 13, 2025)

“And you better not think of coming to this area for the holidays until you clear up what you owe. They’ll pick you up.”

– Attorney Barrett (text, ca. Oct. 13, 2025)

“You can only be a miserable prick for so long before it catches up to you.”

– Attorney Barrett (text, ca. Sept. 24, 2025)

“I hope you enjoy bending over in prison with your bitch ass.”

– Attorney Barrett (text, Sun, Oct. 19, 2025, 02:54)

“I received notice that child support transferred to criminal non-support unit for federal prosecution. Do you anticipate paying what is owed or pay anything on a regular and consistent basis?”

– Attorney Barrett (text, ca. Oct. 9, 2025)

“If anyone belongs in jail, it’s you.”

– Attorney Barrett (text, ca. Oct. 9, 2025)

“There’s a warrant out for your arrest in MA from my understanding.”

– Attorney Barrett (text, ca. Jan. 3, 2026)

“Being extradited might be the best thing that ever happens to you.”

– Attorney Barrett, email (Annexure C – Email Re Bar complaint (September 29, 2025).eml), Monday, Sept. 29, 2025, 15:43 EDT

“Sell off the Australian assets and move back to the US to deal with your shit, before you’re extradited…”

– Attorney Barrett, email (Annexure C – Email Re Bar complaint (September 29, 2025).eml), Monday, Sept. 29, 2025, 15:43 EDT

Particularly alarming is the threat referenced in Part IV(D) of this grievance, namely that upon Mr. <Redacted>’ filing of a bar complaint Attorney Barrett communicated her intention to “end [his] life” if further complaints were filed. That threat, made by a licensed attorney in direct retaliation for a protected disciplinary filing, is itself among the most serious single items in this entire record.
The threats cannot be dismissed as non-serious venting. They are repeated; they are coordinated in content; they escalate in severity over time; and they are made in direct connection with Mr. <Redacted>’ legitimate exercise of his legal rights, including the right to file a bar complaint, the right to contest an allegedly erroneous child-support calculation, and the right to post truthful consumer reviews.
Applicable rule citations: Rule 3.4(a) and (f) (obstructing another’s access to evidence or the administration of justice, and unlawful influence on opposing party’s conduct); Rule 4.4(a) (means without substantial purpose other than to embarrass, delay, or burden a third person); Rule 8.4(b) (commission of a criminal act that reflects adversely on the lawyer’s honesty, trustworthiness, or fitness as a lawyer, to the extent that threats of bodily harm, interstate-transmitted threats, stalking, or tortious interference under relevant state or federal law are established); Rule 8.4(d) (conduct prejudicial to the administration of justice); and Rule 8.4(g) (harassment). The “end his life” threat in direct retaliation for a protected disciplinary filing is also a standalone violation of Rule 8.1(b) (improper conduct in connection with a disciplinary matter) and may independently implicate RSA 631:4 (criminal threatening) and 18 U.S.C. § 875(c) (interstate threats) for the Office’s consideration.

F. Unlawful Contact with Mr. <Redacted>’ Family and Friends

As detailed in Parts V(A), V(B), and IV(F), Attorney Barrett has repeatedly initiated unsolicited communications with persons who are wholly outside the parties’ dispute:
Mr. <Redacted>’ mother, <Redacted>, was contacted in writing in or about December 2024 by Attorney Barrett (including letters, photographs, and correspondence which Mr. <Redacted>’ family characterized as abusive), and again on April 11, 2026, notwithstanding repeated written cease-contact demands from Mr. <Redacted>’ family following the December 2024 incident;
Mr. <Redacted>’ business partner was contacted on or about April 2, 2026 and the business partner subsequently blocked Attorney Barrett across all channels;
Attorney Barrett has, on information and belief, attempted contact with other friends and acquaintances of Mr. <Redacted>, in each instance in a manner designed to convey disparaging information about Mr. <Redacted> to persons who have no involvement in the parties’ dispute.
It is well settled under New Hampshire law, common law, and common sense that persons connected to an opposing party by blood, affection, or business do not thereby become permissible targets of third-party harassment by opposing counsel. Such contact is a hallmark of the abuse of attorney status for coercive personal ends and constitutes an independent ground for discipline.
Applicable rule citations: Rule 4.4(a) is the core provision violated. The text of Rule 4.4(a) expressly prohibits a lawyer from using “means that have no substantial purpose other than to embarrass, delay, or burden a third person.” The elderly mother of an opposing party, the business partner of an opposing party, and the personal acquaintances of an opposing party are paradigm “third persons” within the meaning of Rule 4.4(a). Rule 8.4(d) is additionally implicated because contact with persons outside the litigation, in patent disregard of unequivocal written cease-contact demands and an express warning that a restraining order would be sought, is prejudicial to the administration of justice. Rule 8.4(b) may be implicated if the contact, in combination with other conduct, meets the statutory elements of harassment or stalking under state or federal law.
See Annexures K and L.

G. Retaliation for the Filing of a Bar Complaint

Attorney Barrett’s conduct since September 18, 2025 is best understood not as conduct that simply continued, but as conduct that was itself materially intensified in response to the filing of the September 2025 complaint. Although that complaint was subsequently withdrawn, the retaliatory conduct it provoked is independently sanctionable and is a specific basis for discipline.
Key retaliatory evidence:
On September 29, 2025, eleven days after Mr. <Redacted> filed the prior complaint, Attorney Barrett responded by email in a thread titled, in relevant part, “Bar complaint.” Rather than any measured or contrite response, the email contained: (i) sustained profanity; (ii) threats referencing extradition; (iii) renewed sexual-misconduct allegations now packaged as retaliation; (iv) predictions of Mr. <Redacted>’ “insanity” and death from “liver disease”; and (v) contempt for his expressed suicidal ideation. That the complaint was later withdrawn does not diminish the retaliatory character of this response. See Annexure C.
Contact with Mr. <Redacted>’ mother recurred on April 11, 2026, after Mr. <Redacted> had withdrawn the complaint in a good-faith effort at resolution.
The threats described in Part IV(D), confirmed by complainant, were made in specific connection with Mr. <Redacted>’ filing of a complaint against her.
Retaliation against a person for filing a disciplinary complaint is itself a serious form of attorney misconduct. It strikes at the integrity of the disciplinary system and the independence of the Bar.
Applicable rule citations: Rule 8.1(b) directly prohibits a lawyer, in connection with a disciplinary matter, from “knowingly fail[ing] to respond to a lawful demand for information from an admissions or disciplinary authority” and from otherwise engaging in obstructive conduct. Rule 8.4(d) prohibits retaliatory conduct prejudicial to the administration of justice; the disciplinary process is part of that administration. Rule 8.4(g) captures harassment of a person on the basis of that person’s engagement in protected activity, including filing a bar complaint. The “end [his] life” threat referenced above, issued by a licensed attorney in explicit retaliation for a bar complaint, also implicates Rule 8.4(b) (criminal acts bearing on fitness to practice).

H. Responses to Expressions of Suicidal Ideation

Perhaps the single most disturbing cluster of communications in the record are those in which Attorney Barrett responds to Mr. <Redacted>’ express statements of despair, including statements that, to any reader applying ordinary standards, should have been understood as potentially reflecting suicidal ideation.
Across the communications documented in Annexures C and E, and in contemporaneous text exchanges, Mr. <Redacted> repeatedly conveyed to Attorney Barrett that her conduct, her litigation strategy, and her accusations were causing him profound and ongoing emotional distress. An attorney of ordinary humanity, to say nothing of ordinary professional decorum, would have recognized such statements as reflecting possible despair and would have responded with at minimum a measure of human concern, or referred Mr. <Redacted> to any one of the mental-health resources known to the members of the family-law bar. Attorney Barrett’s actual responses, documented at Annexure C, were the opposite. She predicted his “insanity,” his death from “liver disease,” mocked him as a “scammer,” and suggested that “being extradited might be the best thing that ever happens to” him.
That a licensed attorney, in a professional communication written after years of contact with Mr. <Redacted> and with full knowledge of his circumstances, could respond to a statement of hopelessness in such terms is evidence of a profound lack of the fitness required to maintain a law license. It goes beyond rudeness; it reflects an attorney who cannot be trusted with the emotional safety of any person whose welfare crosses her path in her professional work.

I. Weaponization of Sexual Allegations in Financial Disputes

Across the email and text-message record, Attorney Barrett has on multiple occasions repeated extraordinarily serious, indeed criminal-grade, allegations of sexual misconduct against Mr. <Redacted> dating to the parties’ initial relationship more than a decade ago. The relevant passages are contained in the emails of November 29, 2024 (Annexure E) and September 29, 2025 (Annexure C).
The fact that such allegations are raised is not, in itself, the grievance. A genuine complainant of sexual assault has every right to make accusations and to seek redress. What is the grievance is the pattern: in each instance, the allegations are raised by Attorney Barrett in the specific context of a financial dispute, a court motion, or an attempt to leverage Mr. <Redacted> into a settlement. They are never, on the record available to Mr. <Redacted>, made to law enforcement. They are never made in a form that would allow Mr. <Redacted> to defend himself in any appropriate forum.
An attorney who strategically deploys, then repeatedly withholds, the most serious accusations available to her as a tool to drive financial settlement is engaging in conduct that is incompatible with Rule 3.4 (fairness to opposing party), Rule 4.4 (no substantial purpose other than to embarrass), and Rule 8.4 (conduct prejudicial to the administration of justice).
Mr. <Redacted> categorically denies the underlying allegations. He notes, strictly for the purpose of demonstrating the pattern, that the allegations appear in the record only in close temporal connection to Attorney Barrett’s financial demands and have not, to Mr. <Redacted>’ knowledge, been reported to law enforcement.
Applicable rule citations: Rule 3.4(e) (a lawyer shall not “allude to any matter that the lawyer does not reasonably believe is relevant or that will not be supported by admissible evidence” and shall not “state a personal opinion as to . . . the credibility of a witness”); Rule 4.4(a) (means without substantial purpose other than to embarrass or burden a third person); and Rule 8.4(c) (conduct involving dishonesty, fraud, deceit, or misrepresentation, where allegations are deployed strategically for leverage rather than advanced in a forum where their truth can be tested).

J. Quid Pro Quo Offers and Conditional Legal Action

Attorney Barrett has repeatedly tied the filing, non-filing, or withdrawal of legal proceedings to Mr. <Redacted>’ compliance with her financial demands. Representative examples:

“Maybe consider paying what you owe currently and paying consistently, or paying some sort of lump sum for the future, and I won’t continue to pursue court action.”

– Attorney Barrett, email (Annexure E – Email Special Appearance Motion Response (November 29, 2024).eml), Friday, Nov. 29, 2024, 10:31 EST

“The only way I’m going to file this termination [of parental rights] is if I’m in a better place financially. You haven’t lived up to your word and continuing to do this doesn’t help.”

– Attorney Barrett, email (Annexure F – Email Avvo Review Response (April 1, 2026).eml), Wednesday, April 1, 2026, 14:53 EDT

“Okay I will file for termination when I have the money!”

– Attorney Barrett (text, Sat, Jan. 3, 2026)

“I told you I would file when I have the money.”

– Attorney Barrett (text, Sat, Jan. 3, 2026)

“I’ve already told you I would [file TPR] when you pay for what you owe.”

– Attorney Barrett (text, Sat, Jan. 3, 2026)

It is improper for an attorney to condition the initiation or termination of legal proceedings on the satisfaction of her personal financial demands. The linkage between the TPR proceedings, proceedings the law requires be governed by the best interests of the minor child, and Attorney Barrett’s own financial “place” is, on its face, deeply troubling.

K. Jurisdictional Overreach and Procedural Ambush

As set forth in Parts IV(A) and IV(C), Attorney Barrett’s conduct has included (i) a document-dump ambush at the January 6, 2025 hearing calculated to exploit Mr. <Redacted>’ overseas, pro se status, and (ii) sustained pursuit of collection mechanisms in jurisdictions in which Mr. <Redacted> has never resided. This conduct is compounded by her repeated invocation of extradition threats as a pressure mechanism.
Applicable rule citations: Rule 3.4(a) (fairness to opposing party and counsel, including not unlawfully obstructing another party’s access to evidence or obstructing the orderly flow of the proceeding); Rule 3.4(d) (failure to make reasonably diligent effort to comply with a legally proper discovery request by an opposing party, where relevant); Rule 3.2 (expediting litigation consistent with the interests of the client); and Rule 8.4(d) (conduct prejudicial to the administration of justice). Procedural abuse directed at a jurisdictionally disadvantaged opposing party is precisely the sort of conduct these rules were intended to reach. The extradition-threat pattern additionally implicates Rule 4.4(a) and Rule 8.4(b).

L. Defamation, Online-Review Suppression, and Abuse of Process

Attorney Barrett has, by her own acknowledgment in text messages to Mr. <Redacted>, previously pursued defamation-style litigation against persons who posted negative reviews of her professional services, and has represented, again in her own words, that those persons “are not around anymore” as a result. In December 2024 she wrote to Mr. <Redacted> demanding that he remove Avvo and Google reviews and labeled those truthful consumer reviews “harassment” and “defamation.” See Annexure D.
Mr. <Redacted>’ reviews describe his genuine experience of Attorney Barrett’s legal work. The use of threats of defamation proceedings and platform-complaint processes to chill and suppress truthful consumer speech is itself an abuse of process. When such conduct is undertaken by a licensed attorney, the abuse is aggravated by the coercive weight the attorney’s license carries and the relative sophistication imbalance it creates.
Applicable rule citations: Rule 3.1 (frivolous or bad-faith assertion of a claim, where the defamation claim is asserted without a good-faith basis in law and fact and for the predominant purpose of chilling lawful speech); Rule 3.4(a) (unlawful obstruction of another’s evidence or access to evidence, where the threats are calculated to suppress lawful consumer speech to Bar disciplinary authorities or other audiences); Rule 4.4(a) (means having no substantial purpose other than to embarrass, delay, or burden a third person); Rule 8.4(d) (conduct prejudicial to the administration of justice, as the strategic use of defamation threats to silence truthful consumer speech is prejudicial to the First Amendment-protected functioning of the professional-review ecosystem by which the public makes informed choices of counsel).

VII. VIOLATIONS OF THE NEW HAMPSHIRE RULES OF PROFESSIONAL CONDUCT

The rule analysis below is organized into two tiers. The primary theories, Rule 8.4(g) and Rule 4.4(a), are the theories on which this grievance principally relies. The secondary theories are noted for completeness and may be pursued at the Office’s discretion, but this grievance does not depend on them.

A. Primary Theory: Rule 8.4(g), Misconduct While Acting as a Lawyer in Any Context

Rule 8.4(g) provides that it is professional misconduct for a lawyer to “take any action, while acting as a lawyer in any context, if the lawyer knows or it is obvious that the action has the primary purpose to embarrass, harass or burden another person.” This is the lead theory because it expressly reaches conduct taken “while acting as a lawyer in any context,” including pro se appearances, and requires no “representing a client” nexus.
See Appeal of Hoppock, 2025 N.H. 18 (holding it was “objectively obvious that the primary purpose” of the respondent’s letter was “to burden [the complainant] through intimidation”; two-month suspension imposed, four months stayed for two years). In Hoppock, a single communication supported suspension. The record here documents not one such communication but dozens, spanning more than eighteen months, escalating after a disciplinary filing, and directed at an opposing party, his mother, and his business associates.
The following categories of conduct documented in Parts V and VI each independently satisfy Rule 8.4(g): profanity directed at an opposing party (Part VI.A); contact with complainant’s family and business associates after cease-contact demands (Parts V.A, V.B, VI.F); conditioning TPR proceedings on personal finances (Part VI.J); retaliation for a disciplinary filing (Part VI.G); mockery of expressed suicidal ideation (Part VI.H); and deployment of sexual-misconduct allegations as financial leverage (Part VI.I).

B. Primary Theory: Rule 4.4(a), Respect for Rights of Third Persons

NH Rule 4.4(a) provides: “In representing a client, a lawyer shall not take any action if the lawyer knows or it is obvious that the action has the primary purpose to embarrass, delay or burden a third person.” Rule 4.4(a) is pled as a co-primary theory applicable to the subset of respondent’s conduct that occurred in the context of litigation functions: drafting and serving filings, corresponding about service of process, conditioning TPR proceedings on financial compliance, and contacting persons outside the litigation. The lead pro se rule remains Rule 8.4(g), which requires no “representing a client” nexus; Rule 4.4(a) applies additionally or in the alternative to the extent the Office concludes that particular challenged acts fall within the scope of client representation.
Under either rule, the contact with Mr. <Redacted>’ mother on April 11, 2026, the contact with his business partner on April 2, 2026, and the April 10-11, 2026 emails had no apparent purpose connected to the litigation.

C. Secondary and Supporting Theories

The following rules are noted as secondary or supporting theories. This grievance does not depend on them, but they may be pursued at the Office’s discretion.
Rule 3.1 (Meritorious Claims and Contentions): Respondent’s written admissions (Annexures F and S-1 through S-3) establish that her decision to file or withhold a TPR petition is calibrated not to the child’s best interests but to whether complainant has made her financially whole. To the extent a TPR petition is filed or withheld on that basis, it may lack a non-frivolous legal foundation.
Rule 3.2 (Expediting Litigation): To the extent respondent’s pattern of filing procedural motions, offering to withdraw them in exchange for financial concessions, and staging document dumps constitutes a strategy of delay and leverage rather than adjudication on the merits.
Rule 3.4 (Fairness to Opposing Party and Counsel): Rule 3.4(a) is implicated by the document-dump ambush at the January 6, 2025 hearing. Rule 3.4(e) applies to the extent respondent’s sexual-misconduct allegations were raised in proceedings constituting trial or equivalent advocacy.
Rule 8.1 (Bar Admission and Disciplinary Matters): To the extent respondent has made or makes false statements to the Discipline Office in connection with this or the prior grievance.
Rule 8.4(a): Violated derivatively through the violations of Rules 3.1, 3.4, and 4.4 described herein.
Rule 8.4(b): The confirmed “end [his] life” threat may constitute a criminal act reflecting adversely on fitness to practice. Contemporaneous documentation will be produced to the Office within seven (7) days of any request.
Rule 8.4(c): To the extent respondent’s deployment of sexual-misconduct allegations as settlement leverage constitutes dishonesty or misrepresentation. The primary analysis is under Rule 8.4(g) and Part VI(I).

D. Aggravating Factors

Under the ABA Standards for Imposing Lawyer Sanctions, § 9.22, the following aggravating factors are present: (c) pattern of misconduct, as the same categories of conduct (profanity, threats, family harassment, review suppression, use of the child as leverage) recur across the entire period documented in this grievance; and (d) multiple offenses, as respondent’s conduct implicates at least five separate Rules of Professional Conduct. The September 18, 2025 complaint, though subsequently withdrawn, placed respondent on clear notice that her conduct was under disciplinary scrutiny. The post-complaint escalation documented herein, which continued and intensified even after the withdrawal, is relevant aggravation, distinct from any formal prior discipline.
Under NH Rule 37A, misconduct that is “part of a pattern of similar misconduct” cannot be treated as minor and is subject to full disciplinary proceedings. The record herein satisfies that standard. The Office is respectfully asked to weigh these aggravating factors in determining the appropriate sanction.

E. Preemption of Anticipated Defenses

The undersigned anticipates that Attorney Barrett may assert certain defenses in any response to this grievance. Several are addressed preemptively here.
Litigation privilege. Some of Attorney Barrett’s statements appear within emails tied to judicial proceedings. To the extent Attorney Barrett invokes the litigation privilege, the doctrine shields civil defamation liability in certain contexts but does not shield a lawyer from professional discipline for conduct that would otherwise violate the Rules of Professional Conduct. The primary theories here, Rule 8.4(g) (primary purpose to harass) and Rule 4.4(a) (in litigation-function communications), are disciplinary rules, not tort claims, and they apply regardless of any litigation privilege.
Opinion vs. fact. Some of Attorney Barrett’s statements about Mr. <Redacted> (for example, that he “abandoned [his] kid” or is a “scammer”) may be defended as opinion or hyperbole. This grievance does not rest truth-requiring theories on those characterisations. What matters under Rules 8.4(g) and 4.4(a) is that the statements, whether opinion or fact, had the primary purpose to embarrass, harass, or burden another person; under those rules, the distinction between opinion and fact is immaterial.
No family-law or adversarial-conduct exception. The undersigned anticipates that Attorney Barrett may argue that her conduct, while unrefined, is within the range of behavior to be expected in a hard-fought family-law matter. The Rules of Professional Conduct contain no family-law exception, no pro se exception, and no adversarial-heat exception. The New Hampshire Bar does not relax the prohibitions on profanity, threats, harassment of third persons, and retaliation for disciplinary filings because a lawyer is personally invested, angry, or tired. If anything, family-law practice requires elevated circumspection precisely because the emotional stakes are high and the parties are often vulnerable.
First Amendment and consumer reviews. The undersigned anticipates that Attorney Barrett may argue that her demands for the removal of Mr. <Redacted>’ Avvo and Google reviews were legitimate exercises of her own right to respond to negative reviews. That is not the grievance. The grievance is that Attorney Barrett, by her own written admission (Annexure N), has pursued defamation-style litigation against prior reviewers with the acknowledged effect that those persons “are not around anymore,” and that she has wielded threats of similar litigation against Mr. <Redacted> to compel removal of truthful consumer speech. Using litigation not for its proper purpose (resolving a live case or controversy on the merits) but as an instrument to chill lawful speech is abuse of process, independent of the legitimacy of any particular review.
Mental-health / diminished-capacity considerations. The record contains statements by Attorney Barrett suggesting she has experienced emotional strain (see Annexure O). The undersigned does not deny the reality of such strain, nor would he seek to derive advantage from it. The Discipline Office is respectfully asked to consider, on the basis of the evidence, whether the conduct documented reflects genuine impairment (in which case a path of rehabilitation may be appropriate) or a pattern of deliberate conduct warranting discipline on its merits. Either way, the conduct is incompatible with Attorney Barrett’s continued practice on her present terms.

VII-A. CHRONOLOGY OF KEY EVENTS

The following chronology is intended to assist the Attorney Discipline Office in tracking the sequence and pattern of the conduct at issue. Dates are given according to the best information available in the documentary record; exact timestamps are available from the source communications.

2013

Docket <Redacted> commences in New Hampshire. The parties’ long-running domestic-relations litigation begins.

2013–2023

Prolonged text-message and email correspondence between the parties, in which Attorney Barrett, having by this time been admitted to the Bar, directs to Mr. <Redacted> the profanity, insults, and personal attacks catalogued at Annexures G and H.
Attorney Barrett’s threats of lifetime pursuit, her weaponization of the parties’ child, and her escalation of legal pressure in proportion to financial demands become fully entrenched features of her communications.

2024

Late November 2024: Attorney Barrett files a motion in <Redacted> seeking aggressive collection, and on November 29, 2024 sends the email excerpted at Annexure E, containing, inter alia, criminal-grade sexual-misconduct allegations, personal attacks, and a conditional settlement offer.
December 3, 2024: Attorney Barrett sends the “Harassment/Reviews” email (Annexure D), demanding removal of truthful consumer reviews.
December 2024: Attorney Barrett initiates unsolicited contact with Mr. <Redacted>’ mother, <Redacted>, sending a “Christmas list” and related correspondence. Mr. <Redacted>’ family issues repeated written cease-contact demands.
December 4, 2024: Mr. <Redacted> files an initial grievance with the NH Attorney Discipline Office and notifies Attorney Barrett of the filing. See notification email summarized at Annexure M.

2025

January 6, 2025: Hearing in the domestic-relations matter. Attorney Barrett delivers the document-dump ambush described at Part IV(A).
Throughout 2025: continued profanity, threats, and personal attacks; continued pressure on Mr. <Redacted> to remove online reviews; continued use of the parties’ child as emotional leverage.
September 18, 2025: Mr. <Redacted> files a formal Bar Complaint (Annexure M) detailing the matters set out in Part IV above. That complaint is subsequently withdrawn in an effort to resolve matters privately.
September 29, 2025: Attorney Barrett sends the retaliatory “Re: Bar complaint” email (Annexure C), the single most problematic email in the record.

2026

April 1, 2026: Attorney Barrett sends the Avvo-review response email (Annexure F) in response to a review she attributes to Mr. <Redacted> (Mr. <Redacted> denies authorship of this review). The email includes documentary evidence that her TPR filing posture is conditioned on her financial circumstances. That evidence is independent of the review’s authorship.
April 2, 2026: Attorney Barrett directly contacts a business partner of Mr. <Redacted>; the business partner is forced to block Attorney Barrett. See Annexure L.
April 10, 2026, 22:49:08 EDT: Attorney Barrett sends the “Why you so obsessed with me?” email with embedded “Obsessed” track. See Annexure B.
April 11, 2026, 17:21:01 EDT: Attorney Barrett sends the “Get a fucking life!” email. See Annexure A.
April 11, 2026 (same calendar day): Attorney Barrett initiates renewed unsolicited written contact with Mr. <Redacted>’ mother, <Redacted>, more than sixteen months after the December 2024 written cease-contact demands. See Annexure K.
April 15, 2026: Mr. <Redacted> files this Verified Grievance.

VII-B. MR. <REDACTED>’ CONDUCT DISTINGUISHED

The record reflects, and Mr. <Redacted> does not attempt to deny, that certain of his own communications to Attorney Barrett contain profane language. The Discipline Office is respectfully asked to consider Mr. <Redacted>’ responsive language in its full context, and to distinguish carefully between: (i) the ethical obligations of a sworn member of the New Hampshire Bar, which is Attorney Barrett, and (ii) the ordinary-language reactions of a lay, self-represented, overseas party who has been subjected to sustained harassment, a party who is Mr. <Redacted>.
Six observations are relevant:
First, Mr. <Redacted> is not an attorney. He is a private individual resident outside the United States. He has not taken an oath of office, does not hold a professional license, and is not subject to the Rules of Professional Conduct. His language is governed by the ordinary norms applicable to private persons, not the elevated norms of New Hampshire lawyers.
Second, Mr. <Redacted>’ profanity in the record is almost entirely defensive and responsive in character. He has consistently used profanity in the course of demanding that Attorney Barrett cease contacting him (“Just fucking leave me alone”), not as an opening gambit or a means of initiating a dispute.
Third, Mr. <Redacted>’ cease-contact demands were made in written form on numerous distinct occasions over a period of years. In each instance, the response from Attorney Barrett was further and often more severe contact. The responsibility for the continuation of contact therefore rests with Attorney Barrett, not Mr. <Redacted>.
Fourth, Mr. <Redacted> has not engaged in the specific categories of conduct at issue: he has not contacted Attorney Barrett’s family members or professional associates; he has not used TPR filings or equivalent legal proceedings as leverage; he has not mocked her expressions of distress; and he has not conditioned the filing or withdrawal of legal proceedings on personal financial satisfaction.
Fifth, Mr. <Redacted> has at all times exercised his protected rights (to file a complaint, to seek review of allegedly erroneous support calculations, to post truthful consumer reviews of an attorney’s services, and to move to vacate allegedly improper orders) through proper legal channels. Attorney Barrett’s characterization of those exercises as “harassment,” “defamation,” or “attack campaigns” is, with respect, a further indication of the attitudinal defect at the heart of this grievance.
Sixth, Mr. <Redacted> has, across long intervals of the record, attempted to extricate himself from direct contact with Attorney Barrett entirely. Where Attorney Barrett has initiated contact, Mr. <Redacted> has, where possible, responded through the discipline process, through the courts, or (in some intervals) not at all. Attorney Barrett has been unable to let any of those intervals pass without re-initiating contact.
The record, in short, is of a sustained harassment campaign initiated and maintained by a licensed attorney, with Mr. <Redacted> as the principal target and his family, business associates, and professional-review posts as subsidiary targets. The Discipline Office is respectfully asked to evaluate the record as such.

VIII. THE PATTERN AND WHY IT MATTERS TO THE PUBLIC

A single incident of profanity, standing alone, might not rise to the level of disciplinary sanction. Multiple incidents of profanity combined with personal attacks, family contact, retaliation, quid pro quo demands, threats of extradition, and mockery of a statement reflecting despair are of a wholly different character.
The public, that is, members of the New Hampshire public who may one day engage Attorney Barrett or a similarly-situated family-law attorney, has a profound interest in the enforcement of the Rules of Professional Conduct against a member of the Bar who has demonstrated the conduct documented here. Clients, children, third parties, opposing parties, and members of the public at large are entitled to the assurance that members of the New Hampshire Bar will not:
Harass the family members and business associates of an opposing party, or retaliate against persons who file disciplinary complaints;
Use threats of litigation, extradition, or other legal process to coerce financial settlements or suppress truthful consumer reviews;
Invoke a minor child as leverage and condition the filing of legal proceedings on personal financial demands;
Direct sustained profanity, threats (including threats to “end” an opposing party’s “life”), and personal abuse at an opposing party; or
Respond to an opposing party’s expressions of despair with mockery and further threats.
The undersigned respectfully submits that the conduct documented in this grievance warrants serious discipline.

IX. REQUEST FOR INVESTIGATION AND RELIEF

On the basis of the foregoing, and of the documentary record set out in the annexures, Mr. <Redacted> respectfully requests that the New Hampshire Attorney Discipline Office:
Open a formal investigation into the conduct of Attorney Elizabeth J. Barrett, Esq., based on the full record set forth in this grievance;
Subpoena and preserve the full record of Attorney Barrett’s written communications with Mr. <Redacted>, with Mr. <Redacted>’ mother <Redacted>, with Mr. <Redacted>’ business partner, and with any other third party contacted by Attorney Barrett in connection with this matter, including but not limited to emails, text messages, social-media communications, and platform-complaint submissions;
Take all appropriate measures under New Hampshire Supreme Court Rule 37 and the Rules of Professional Conduct to ensure that Attorney Barrett refrains from any further contact with Mr. <Redacted>’ family members, business associates, and other third parties during the pendency of the investigation;
Treat with particular seriousness the apparent act of retaliation for Mr. <Redacted>’ filing of the September 18, 2025 bar complaint (since withdrawn), including but not limited to the September 29, 2025 email and the direct threat to “end [Mr. <Redacted>’] life” if further complaints were filed;
Impose such interim protective measures, formal discipline, and remedial requirements as are warranted, including without limitation (i) a formal reprimand, (ii) a period of suspension, (iii) disbarment, (iv) mandatory no-contact directives respecting Mr. <Redacted>’ family and business associates, (v) mandatory education or continuing-education requirements, and/or (vi) any combination thereof; and
Grant any such further and different relief as the Attorney Discipline Office deems just and proper in the circumstances of this case.
Mr. <Redacted> stands ready to provide the full underlying documentary record, including the complete text-message exchange (reproduced in relevant part across Annexures G through Q), the full email record, and the voicemail recordings in his possession. Mr. <Redacted> will cooperate fully with the investigation and will make himself available for interviews, affirmations, and the provision of any further documentation the Discipline Office may require.

X. VERIFICATION OF COMPLAINANT

I, <Redacted>, being duly sworn according to law, hereby state that I am the Complainant in this matter; that I have read the foregoing Verified Grievance Against Attorney Elizabeth J. Barrett, Esq.; that the factual statements contained herein are true and correct to the best of my knowledge, information, and belief; and that the documents appended as annexures hereto are true and accurate copies of the original communications they purport to reproduce.

___________________________________

<Redacted>, Complainant

Date: April 15, 2026

Email: <Redacted>

Mailing Address: <Redacted>

Telephone: <Redacted>

The Complainant is presently residing outside the United States. All correspondence from the Attorney Discipline Office may be transmitted electronically to the email address above, and Complainant will respond promptly. Complainant will provide updated mailing and telephone contact information upon request or upon return to the United States.

ANNEXURES

The following annexures reproduce or excerpt the primary-source communications underlying this grievance. Where profanity appears in the original, it has been reproduced verbatim in order to give the Attorney Discipline Office the original text of the communications.
The text-message annexures (Annexures G through J, N, O, P, and Q) are drawn from the parties’ iMessage record, in which Attorney Barrett’s messages appear on the left-hand side of each screenshot and Mr. <Redacted>’ messages on the right. Email annexures identify the source .eml file for each communication.

ANNEXURE A. EMAIL: “GET A FUCKING LIFE!” (APRIL 11, 2026)

Source: Annexure A – Email Get a fucking life! (April 11, 2026).eml

From: Elizabeth Barrett <[email protected]>

To: <Redacted> <Redacted>

Date: Saturday, April 11, 2026, 17:21:01 -0400

Subject: Get a fucking life!

Full text as sent:

“My brother died. I’m grieving and dealing with a grieving family. You couldn’t be anymore heartless or disgusting. Go fuck your girlfriend! Leave me alone and get a fucking life! Grow the fuck up! I’m raising a mature 13 year old while you flail around like you’re fucking 7. Just because you’re miserable with your ugly ass life doesn’t mean you need to take it out on me. Braden deserves better.”

Analysis. This email is a text-book demonstration of violations of Rule 4.4 and Rule 8.4(d). The communication contains four uses of “fuck” or its derivatives, personal attacks on Mr. <Redacted>’ lifestyle and maturity, reference to his girlfriend in sexually denigrating terms, deployment of the parties’ child as an emotional weapon, and the explicit use of the word “heartless” to attack an opposing party. The subject line is, itself, a profane command. It is impossible to identify any legitimate legal purpose for this email. It was sent after Mr. <Redacted> had, on numerous occasions, asked Attorney Barrett to stop contacting him.
It is also noted that this email was sent on the same calendar day as the renewed unsolicited contact with Mr. <Redacted>’ mother described in Annexure K.

ANNEXURE B. EMAIL: “WHY YOU SO OBSESSED WITH ME?” (APRIL 10, 2026)

Source: Annexure B – Email Why you so obsessed with me (April 10, 2026).eml

From: Elizabeth Barrett <[email protected]>

To: <Redacted> <Redacted>

Date: Friday, April 10, 2026, 22:49:08 -0400

Subject: Why you so obsessed with me?

Body: the email body consists of a single embedded audio link to the popular music track entitled “Obsessed,” accompanied by the subject-line question.
Analysis. This communication is not a good-faith legal communication. The combination of the subject line (“Why you so obsessed with me?”) and the embedded “Obsessed” track is a taunt, transparently designed to provoke Mr. <Redacted>. From a licensed attorney to an opposing party in a pending family matter, it is gratuitous and harassing in a manner directly targeted by Rule 4.4(a). It preceded the April 11, 2026 “Get a fucking life!” email by approximately nineteen hours.

ANNEXURE C. EMAIL: “RE: BAR COMPLAINT” (SEPTEMBER 29, 2025)

Source: Annexure C – Email Re Bar complaint (September 29, 2025).eml

From: Elizabeth Barrett <[email protected]>

To: <Redacted> <Redacted>

Date: Monday, September 29, 2025, 15:43:14 -0400

Subject: Re: Bar complaint

Key verbatim passages from the email (redactions, if any, are indicated by ellipses in square brackets):

“Money doesn’t seem to be arriving at all. I’ll believe it when I see it.”

“Your psych evals weren’t even accurate. Not once did you mention Braden. You mention dating another plastic surgeon in February 2014… you were with ‘Cynthia’ then… you also fail to acknowledge your manipulating/lying/threatening behaviors…”

“I’m not denying that you have mental health issues. I’m saying you need to treat them, by accurately disclosing your actions, instead of just going through the motions in an attempt to avoid child support or to receive pension.”

“Maybe someday you’ll appreciate me.”

“I was a manager for Smuttynose when I met you, you took the condom off, deliberately came in me after you tried to ram your dick in my ass — all the while I was saying no and stop, and then didn’t get me plan B for days after when I was the one that asked for it — after you texted me asking how work was when I was doing inventory. I remember everything. I have friends who you paid for dinner for on one of the multiple nights you spent with me. Your attempts to trash me, as the mother of your kid, is disgusting.”

“It’s so crazy to me that you would be so nasty to me when I’m doing all I can to stay afloat and provide a good home for Braden.”

“I’m not going to tell you how to live your life, and I hope you someday figure it out so that maybe you could be a role model for Braden. But, I can’t say I have sympathy for you when you’re living in a multimillion dollar mansion, running attack campaigns, and moving and making money through networks you’ve created — while I’m worried that this old building we’re in’s floors are going to cave-in and I can’t afford anywhere else in Portsmouth.”

“All you cared about is/was money and look where it’s gotten you.”

“I hope that you seek therapy for more than a disability evaluation — and actually open-up honestly about your life and behaviors. Maybe it’s time to put the scheming and scamming down and just deal with your life. Sell off the Australian assets and move back to the US to deal with your shit, before you’re extradited, and engage in some heavy therapy before you drive yourself further into insanity or end up dying from liver disease.”

“No, you are not blaming Braden for your bullshit behavior and actions. You are making the conscious choice to be miserable instead of appreciating what the universe blessed you with.”

“You need serious mental health treatment and not a scam for early pension. Being extradited might be the best thing that ever happens to you.”

In the broader exchange and in contemporaneous communications, Mr. <Redacted> conveyed statements of despair and hopelessness that, on their ordinary reading, any licensed attorney should have recognized as reflecting potential suicidal ideation. Attorney Barrett’s response, as excerpted above, was not concern. It was a prediction of his “insanity,” his death from “liver disease,” a repetition of her “extradition” threats, and a renewed accusation that he was scamming for a disability or pension.
Analysis. This single email is among the most troubling items of evidence in the entire record. It is sent in direct and express response to the since-withdrawn bar complaint (“Re: Bar complaint”). It contains repeated profanity from a sitting member of the Bar; it repeats, as leverage, the most serious criminal-grade allegations that can be made against a person; it contains explicit extradition threats; it attacks Mr. <Redacted>’ mental health status; it openly predicts his death; and it responds to a statement of despair with mockery. It is, standing alone, sufficient to support serious discipline.

ANNEXURE D. EMAIL: “HARASSMENT/REVIEWS” (DECEMBER 3, 2024)

Source: Annexure D – Email Harassment Reviews (December 3, 2024).eml

From: Elizabeth Barrett <[email protected]>

To: <Redacted> <Redacted>

Date: Tuesday, December 3, 2024, 10:11:52 -0500

Subject: Harassment/Reviews

Key verbatim passage:

“Not only are you not supporting Braden, but now you’re attacking my ability to support him. This is not appropriate, it’s defamation, and detrimental to my livelihood/ability to take care of Braden. Please stop, remove these posts immediately, and desist from further harassment.”

Analysis. This email, dispatched in the guise of a cease-and-desist, uses the weight of Attorney Barrett’s professional status to intimidate Mr. <Redacted> into removing truthful consumer reviews about her legal services. The characterization of truthful consumer speech as “defamation” and “harassment” is itself a misuse of legal labels. The use of the parties’ child (“to support Braden”) as moral leverage in an online-review suppression effort is particularly objectionable.

ANNEXURE E. EMAIL: SPECIAL APPEARANCE MOTION RESPONSE (NOVEMBER 29, 2024)

Source: Annexure E – Email Special Appearance Motion Response (November 29, 2024).eml

From: Elizabeth Barrett <[email protected]>

To: <Redacted> <Redacted>

Date: Friday, November 29, 2024, 10:31:49 -0500

Subject: Re: <Redacted>: SPECIAL APPEARANCE, EXPEDITED MOTION TO VACATE, DISMISS, AND REVERSE ILL-GOTTEN MONEYS

Key verbatim passages:

“You’re wasting everyone’s time. You might also keep in mind that I have every text you’ve ever sent me showing your lies and il [sic] intent…”

“There’s so many more, including a litany of verbal abuse by you. It’s so crazy to me that you would be so nasty to me when I’m doing all I can to stay afloat and provide a good home for Braden.”

“Your attempts to trash me, as the mother of your kid, is disgusting. Keep whatever twisted reality you tell yourself or your family/friends to yourself. I don’t need the disrespect.”

“Braden is almost 12. What’s your excuse for showing-up twice and then being a dead beat? Grow up!”

“Do better. If you want to have a legitimate conversation, I’m here for it. Maybe consider paying what you owe currently and paying consistently, or paying some sort of lump sum for the future, and I won’t continue to pursue court action.”

Analysis. This is a response to a court motion filed by Mr. <Redacted>. Rather than addressing the motion on the merits, Attorney Barrett (i) threatens to use accumulated communications against Mr. <Redacted>; (ii) raises criminal-grade sexual misconduct allegations in the course of a court-motion exchange; (iii) engages in personal attacks (“dead beat,” “grow up”); and (iv) explicitly offers to condition the course of legal proceedings on Mr. <Redacted>’ financial compliance (“Maybe consider paying… and I won’t continue to pursue court action”). The conditional settlement demand is the core of the Rule 3.4 / Rule 8.4(d) concern.

ANNEXURE F. EMAIL: AVVO REVIEW RESPONSE (APRIL 1, 2026)

Source: Annexure F – Email Avvo Review Response (April 1, 2026).eml

From: Elizabeth Barrett <[email protected]>

To: <Redacted> <Redacted>

Date: Wednesday, April 1, 2026, 14:53:29 -0400

Subject: Fwd: You received a new review on Avvo

Key verbatim passages:

“Why are you doing this again? What’s the point? Wouldn’t you want me to have as many client’s [sic] as possible so that I wouldn’t need help with Braden? Being a solo parent is hard enough. Having to explain to clients that the weird website about me was created by my son’s father is wild. Losing clients because of your behavior, when I need to support Braden, is disgusting.”

“The only way I’m going to file this termination is if I’m in a better place financially. You haven’t lived up to your word and continuing to do this doesn’t help.”

“Thought and hoped maybe you were working on your mental health with this Pilates endeavor. I’m still open to doing therapy or mediation with you… or even just sitting down and having a real conversation human to human. Anything would be better than how you’ve treated me.”

Analysis. The April 1, 2026 email is directly significant for two reasons. First, it is an explicit and written admission that Attorney Barrett is conditioning the filing of a Termination of Parental Rights petition on whether her personal financial “place” is satisfactory, a direct violation of the child’s-best-interests standard and a plain instance of using litigation as leverage. Second, it openly characterizes Mr. <Redacted>’ exercise of his First Amendment right to post consumer reviews as “behavior” that is damaging her, conflating lawful consumer speech with tortious conduct.

ANNEXURE G. TEXT MESSAGE COMPENDIUM: PROFANITY

The following are verbatim profane statements made by Attorney Barrett to Mr. <Redacted> in text messages. Attorney Barrett’s messages appear on the left-hand side of each screenshot; Mr. <Redacted>’ appear on the right. Dates are taken from the timestamp headers visible in the source iMessage record. These excerpts are representative; the full 85-page iMessage record will be produced within seven (7) days of any request.

“So fuck off with that shit.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“You didn’t have to do shit.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“Bullshit with your 300k income.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“I don’t need you to keep saying the same fucking story that you’ve been telling yourself for the past 13 years.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“Just fucking leave me alone.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“I think you forgot I’m not a fucking idiot.”

– Attorney Barrett (text, Thu, Oct. 9, 2025, 09:39)

“Then why delete half the shit on Reddit?”

– Attorney Barrett (text, Thu, Oct. 9, 2025, 09:39)

“Your morals are fucked. Grow the fuck up.”

– Attorney Barrett (text, ca. Oct. 9, 2025)

“I’ve tried with you. I’ve fucking tried.”

– Attorney Barrett (text, ca. Oct. 9, 2025)

“Be a fucking man and take care of your kid.”

– Attorney Barrett (text, ca. Oct. 13, 2025)

“You got me pregnant mother fucker.”

– Attorney Barrett (text, ca. Oct. 13, 2025)

“Clearly, the funds are never coming and you’re just a fucking piece of shit. Go get a fucking job.”

– Attorney Barrett (text, Tue, Oct. 14, 2025)

“Because you’re fucking dumb and you lie all the time.”

– Attorney Barrett (text, Tue, Oct. 14, 2025)

“No wonder you’re fucking delusional.”

– Attorney Barrett (text, Tue, Oct. 14, 2025)

“I want nothing to do with your crazy ass fucking family.”

– Attorney Barrett (text, Tue, Oct. 14, 2025)

“You’re fucking delusional and would benefit from a lobotomy.”

– Attorney Barrett (text, Sun, Oct. 19, 2025, 02:54)

“I hope you enjoy bending over in prison with your bitch ass.”

– Attorney Barrett (text, Sun, Oct. 19, 2025, 02:54)

“Your ugly ass girlfriend who needs to perform plastic surgery on that nose of hers.”

– Attorney Barrett (text, Sun, Oct. 19, 2025, 02:54)

“You know everything you don’t is bullshit.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“No you are just pure evil.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“You can only be a miserable prick for so long before it catches up to you.”

– Attorney Barrett (text, ca. Sept. 24, 2025)

“All you do is bring up my pregnancy. While my vagina was destroyed in child birth…”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“You’d rather be miserable and block your blessing.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“Clearly, your mother doesn’t know how to parent.”

– Attorney Barrett (text, Tue, Oct. 14, 2025)

“I just don’t understand how you can be so evil.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“Greedy pig.”

– Attorney Barrett (text, Wed, Sept. 10, 2025 thread)

“Can you please help me and stop being such a douche canoe?”

– Attorney Barrett (text, Fri, Jan. 23, 2026, 10:53)

“Pay what you owe and leave me the fuck alone.”

– Attorney Barrett (email: Annexure S-4 – Email Termination of Parental Rights Sibling Death Response (April 10, 2026).eml, TPR thread)

“Fuck all the way off… sit and spin on it.”

– Attorney Barrett (email: Annexure S-3 – Email IMO TPR Petition Service Address Thread (September 29, 2025).eml, IMO TPR thread)

“You are a fucking nightmare and I’m done with your abuse you fucking troll.”

– Attorney Barrett (email: Annexure S-3 – Email IMO TPR Petition Service Address Thread (September 29, 2025).eml, IMO TPR thread)

ANNEXURE H. TEXT MESSAGE COMPENDIUM: THREATS AND INTIMIDATION

Representative verbatim threatening statements made by Attorney Barrett to Mr. <Redacted>:

“You should be in jail.”

– Attorney Barrett (text, Wed, Sept. 10, 2025, 02:18)

“You can only be a miserable prick for so long before it catches up to you.”

– Attorney Barrett (text, ca. Sept. 24, 2025)

“You know the Feds are watching you though, right?”

– Attorney Barrett (text, ca. Oct. 13, 2025)

“You need to send funds in the next 20 days or this is getting forward to the Feds. Just giving you a heads up!”

– Attorney Barrett (text, ca. Oct. 13, 2025)

“You better not think of coming to this area for the holidays until you clear up what you owe. They’ll pick you up.”

– Attorney Barrett (text, ca. Oct. 13, 2025)

“I’m not your enemy but the police are certainly coming for you.”

– Attorney Barrett (text, ca. Oct. 9, 2025)

“How crazy would it be for me to show up in court like yes, this is my sons father who refuses to pay child support yet makes websites and posts against me, extorting me, and thinks this is the appropriate venue with his capias…”

– Attorney Barrett (text, ca. Sept. 25, 2025)

“I hope you enjoy bending over in prison with your bitch ass.”

– Attorney Barrett (text, Sun, Oct. 19, 2025, 02:54)

“Being extradited might be the best thing that ever happens to you.”

– Attorney Barrett (email: Annexure C – Email Re Bar complaint (September 29, 2025).eml, Sept. 29, 2025)

“Sell off the Australian assets and move back to the US to deal with your shit, before you’re extradited…”

– Attorney Barrett (email: Annexure C – Email Re Bar complaint (September 29, 2025).eml, Sept. 29, 2025)

In addition, per the allegations re-incorporated from the withdrawn September 2025 complaint: following Mr. <Redacted>’ filing of a grievance in December 2024, Attorney Barrett communicated, in words or substance, that if Mr. <Redacted> filed any further complaints against her, she would “end his life.” That threat was made by a licensed attorney in direct retaliation for a protected disciplinary filing and is independently alleged in this grievance.

ANNEXURE I. TEXT MESSAGE COMPENDIUM: USE OF THE CHILD AS LEVERAGE

Representative verbatim statements in which Attorney Barrett invokes the parties’ minor child not as a matter for co-parenting discussion but as a tool of attack, leverage, or shaming of Mr. <Redacted>:

“All you do is bring up my pregnancy.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“While my vagina was destroyed in child birth…”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“God blessed me with Braden.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“You’d rather be miserable and block your blessing.”

– Attorney Barrett (text, ca. Sept. 22, 2025)

“Be a fucking man and take care of your kid.”

– Attorney Barrett (text, ca. Oct. 13, 2025)

“You got me pregnant mother fucker.”

– Attorney Barrett (text, ca. Oct. 13, 2025)

“Braden’s been sick and I’ve been up.”

– Attorney Barrett (text, ca. Sept. 23, 2025)

“Braden deserves better.”

– Attorney Barrett (email: Annexure A – Email Get a fucking life! (April 11, 2026).eml, April 11, 2026)

“Braden is almost 12. What’s your excuse for showing-up twice and then being a dead beat? Grow up!”

– Attorney Barrett (email: Annexure E – Email Special Appearance Motion Response (November 29, 2024).eml, Nov. 29, 2024)

“The only way I’m going to file this termination is if I’m in a better place financially.”

– Attorney Barrett (email: Annexure F – Email Avvo Review Response (April 1, 2026).eml, April 1, 2026)

“I’m raising a mature 13 year old while you flail around like you’re fucking 7.”

– Attorney Barrett (email: Annexure A – Email Get a fucking life! (April 11, 2026).eml, April 11, 2026)

ANNEXURE J. TEXT MESSAGE COMPENDIUM: MR. <REDACTED>’ CEASE-CONTACT DEMANDS

Mr. <Redacted> has, on numerous documented occasions, explicitly demanded in writing that Attorney Barrett cease contacting him. Representative verbatim cease-contact demands include:

“Just fucking leave me alone.”

– Mr. <Redacted>

“Fuck you.”

– Mr. <Redacted> (repeated across the record)

“I want nothing to do with you.”

– Mr. <Redacted>

“I don’t want to talk about the past.”

– Mr. <Redacted>

“I think you forget I’m not a fucking idiot.”

– Mr. <Redacted>

“If you contact my family again, a restraining order will be taken against you.”

– Mr. <Redacted> (email: Christmas list.eml, December 2024)

In each instance, Attorney Barrett’s response was to send further messages. For example, to Mr. <Redacted>’ statement “Just fucking leave me alone,” her subsequent reply was, in relevant part, “I don’t need you to keep saying the same fucking story that you’ve been telling yourself for the past 13 years,” followed in the record by further messages including the threat to proceed with court filings absent acquiescence.
Mr. <Redacted>’ language in certain of these messages is intemperate and reflects the justified frustration of a person who has repeatedly asked to be left alone and has been repeatedly ignored. His profanity in the record is not the conduct of a licensed officer of the court; it is the conduct of a lay, overseas party who has repeatedly asked to be left alone. It does not in any way excuse or mitigate the distinct and separate duties owed by Attorney Barrett as a member of the New Hampshire Bar.

ANNEXURE K. CONTACT WITH MR. <REDACTED>’ MOTHER (DEC. 2024 AND APRIL 2026)

1. December 2024: “Christmas List” and Accompanying Correspondence

In or about December 2024, Attorney Barrett sent to Mr. <Redacted>’ mother, <Redacted>, unsolicited written correspondence, including a “Christmas list,” photographs, and other materials, in a manner that was not welcome and that prompted the <Redacted> family to issue repeated written cease-contact demands to Attorney Barrett.
Mr. <Redacted>, upon learning of the contact, wrote to Attorney Barrett, in substance:

“If you contact my family again, a restraining order will be taken against you.”

– Mr. <Redacted>

That direct, unambiguous cease-contact demand, from an opposing party to a licensed attorney, should have been the end of any contact with Mr. <Redacted>’ family. It was not.

2. April 11, 2026: Renewed Unsolicited Contact

On Saturday, April 11, 2026, more than sixteen months after the December 2024 contact and Mr. <Redacted>’ written demand that all such contact cease, Attorney Barrett again initiated unsolicited written contact with Mr. <Redacted>’ mother, <Redacted>.
This contact was made after Mr. <Redacted> had filed (and subsequently withdrawn) a formal bar complaint that specifically identified family harassment as a central concern; it was made on the same calendar day as the “Get a fucking life!” email described in Annexure A; and it was made by a licensed New Hampshire attorney who knew or should have known that such contact was not welcome.
The April 11, 2026 contact is the specific and immediate precipitating event that has prompted Mr. <Redacted>’ family to pursue a restraining order against Attorney Barrett, as warned in Mr. <Redacted>’ December 2024 cease-contact demand.

ANNEXURE L. CONTACT WITH MR. <REDACTED>’ BUSINESS PARTNER (APRIL 2, 2026)

On or about April 2, 2026, Attorney Barrett directly contacted a business partner of Mr. <Redacted>. The business partner has no involvement in the parties’ domestic-relations dispute. She has no prior or current relationship with Attorney Barrett. She had no legitimate reason to be receiving communications from Attorney Barrett.
Mr. <Redacted>’ business partner blocked Attorney Barrett across the relevant communication channel following the contact. The business partner has provided a written statement confirming the contact and its effect.
Mr. <Redacted> has obtained a written statement from his business partner confirming these facts. The statement will be produced to the Discipline Office within seven (7) days of any request, or as a supplement to this grievance, in a manner consistent with the business partner’s privacy and safety.
This contact occurred after Mr. <Redacted> had placed Attorney Barrett on unequivocal notice (through the filing of a formal complaint, through direct written demands, and through counsel) that such conduct was objectionable. It constitutes an independent violation of Rule 4.4(a), an aggravating factor under any measure of Rule 8.4(d), and further evidence that Attorney Barrett’s pattern of harassment reaches beyond the opposing party to any person in the opposing party’s orbit whose involvement can be used as leverage against the opposing party.

ANNEXURE M. THE WITHDRAWN SEPTEMBER 2025 COMPLAINT (RE-INCORPORATED)

On September 18, 2025, Mr. <Redacted> filed a formal complaint against Attorney Barrett with the New Hampshire Attorney Discipline Office. That complaint was subsequently withdrawn by Mr. <Redacted> in a good-faith effort to resolve the parties’ disputes privately. The attempt at private resolution was unsuccessful, and Attorney Barrett’s conduct escalated after the withdrawal. All claims from the September 2025 complaint are hereby re-incorporated as independent allegations in this grievance. A true and accurate copy of the withdrawn complaint is appended hereto.
Principal factual allegations of the September 18, 2025 complaint, which are re-incorporated and independently relied upon in this grievance:
Attorney Barrett’s procedural ambush at the January 6, 2025 hearing via a voluminous, largely irrelevant document-dump deliberately calculated to prejudice Mr. <Redacted>’ ability to participate meaningfully as an overseas pro se party;
Attorney Barrett’s improper pursuit of online-review removal through defamation-style threats against Mr. <Redacted> and, by her own admission, against other persons who previously posted about her;
Attorney Barrett’s improper pursuit of collection-style mechanisms in jurisdictions in which Mr. <Redacted> has never resided, combined with extradition threats;
Attorney Barrett’s threat, in words or substance, to “end [Mr. <Redacted>’] life” if further complaints were filed against her (confirmed by complainant; documentation available);
Attorney Barrett’s documented pattern of profanity, personal attack, weaponization of the parties’ child, and harassment of Mr. <Redacted>’ family members.
The conduct documented in this grievance has occurred in addition to, has continued from, and has materially escalated beyond the conduct identified in the withdrawn September 18, 2025 complaint.

ANNEXURE N. ADDITIONAL TEXT MESSAGE EXCERPTS (PERSONAL ATTACKS ON FAMILY & PARTNER)

The following are additional excerpts drawn from the parties’ iMessage record that are relevant to Attorney Barrett’s personal attacks on Mr. <Redacted>’ mother, Mr. <Redacted>’ girlfriend, and related persons:

“Clearly, your mother doesn’t know how to parent.”

– Attorney Barrett

“Go fuck your girlfriend!”

– Attorney Barrett (email: Annexure A – Email Get a fucking life! (April 11, 2026).eml, April 11, 2026)

“Just because you’re miserable with your ugly ass life doesn’t mean you need to take it out on me.”

– Attorney Barrett (email: Annexure A – Email Get a fucking life! (April 11, 2026).eml, April 11, 2026)

“Having to explain to clients that the weird website about me was created by my son’s father is wild.”

– Attorney Barrett (email: Annexure F – Email Avvo Review Response (April 1, 2026).eml, April 1, 2026)

“Keep whatever twisted reality you tell yourself or your family/friends to yourself. I don’t need the disrespect.”

– Attorney Barrett (email: Annexure E – Email Special Appearance Motion Response (November 29, 2024).eml, Nov. 29, 2024)

“I pray all the time that you’d find Jesus.”

– Attorney Barrett (text)

“Go cap some teens and blackmail them. Are you still doing that??”

– Attorney Barrett (text)

“The text messages you sent to yourself pretending to be me have already been investigated and proven to be from you.”

– Attorney Barrett (text)

The last two passages additionally reflect serious criminal-grade accusations (blackmail of minors, fabrication of evidence) made in a text-message medium without any documented basis of fact in the record before this Office, representing independently sanctionable conduct under Rules 4.4 and 8.4.

ANNEXURE O. TEXT MESSAGE COMPENDIUM: EMOTIONAL MANIPULATION AND VOLATILITY

Representative verbatim passages reflecting Attorney Barrett’s pattern of emotional manipulation, self-characterization as victim in the midst of aggressive demands, and sudden shifts between aggression and claimed incapacity:

“I’m just sad. I wish I could just take a vacation in some posh mental clinic.”

– Attorney Barrett

“I’m exhausted. I haven’t slept for weeks with what you put me through. Braden’s been sick and I’ve been up.”

– Attorney Barrett

“I just don’t understand how you can be so evil.”

– Attorney Barrett

“I pray all the time that you’d find Jesus.”

– Attorney Barrett

“I can’t think right now or make any logical decisions.”

– Attorney Barrett (following aggressive demands)

“And treated me like dirt.”

– Attorney Barrett

“You destroyed my life entirely and completely.”

– Attorney Barrett

“Maybe someday you’ll appreciate me.”

– Attorney Barrett (email: Annexure C – Email Re Bar complaint (September 29, 2025).eml, Sept. 29, 2025)

“I’m still open to doing therapy or mediation with you… or even just sitting down and having a real conversation human to human. Anything would be better than how you’ve treated me.”

– Attorney Barrett (email: Annexure F – Email Avvo Review Response (April 1, 2026).eml, April 1, 2026)

Analysis. The interweaving of professed victimhood, religious-tinged criticism, claims of incapacity following aggressive demands, and unreciprocated conciliation gestures is a marker of the rhetorical volatility that renders Attorney Barrett unsuitable to discharge the professional obligations of a New Hampshire attorney. A sustained pattern of emotional oscillation, made from a position of power (a licensed attorney) directed at a self-represented opposing party, is itself a species of harassment targeted by Rule 4.4(a).

ANNEXURE P. TEXT MESSAGE COMPENDIUM: LITIGATION AS SILENCING MECHANISM

The following passages further document Attorney Barrett’s use of defamation-style threats and online-review-suppression tactics, as distinct from the cease-and-desist email at Annexure D:

“Not only are you not supporting Braden, but now you’re attacking my ability to support him. This is not appropriate, it’s defamation, and detrimental to my livelihood… Please stop, remove these posts immediately, and desist from further harassment.”

– Attorney Barrett (email: Annexure D – Email Harassment Reviews (December 3, 2024).eml, Dec. 3, 2024)

“Defamation action against the person posting that BS hence why they are not around anymore.”

– Attorney Barrett (text)

“Your comments on the women’s bar site… that’s just disgusting.”

– Attorney Barrett (text)

“Why are you doing this again? What’s the point? … Having to explain to clients that the weird website about me was created by my son’s father is wild. Losing clients because of your behavior, when I need to support Braden, is disgusting.”

– Attorney Barrett (email: Annexure F – Email Avvo Review Response (April 1, 2026).eml, April 1, 2026)

“Running attack campaigns.”

– Attorney Barrett (email: Annexure C – Email Re Bar complaint (September 29, 2025).eml, Sept. 29, 2025) (in reference to <Redacted>’ public reviews)

Analysis. Attorney Barrett explicitly admits having pursued a “defamation action against the person posting that BS” and openly credits that action with the fact that the prior reviewer is “not around anymore.” This is a direct admission of weaponizing defamation litigation as a silencing mechanism, which, coupled with her repeated written demands that Mr. <Redacted> remove truthful consumer reviews, constitutes a distinct species of abuse of process. See, e.g., Standing Committee on Discipline v. Yagman, 55 F.3d 1430 (9th Cir. 1995) (discussing attorney discipline for bad-faith litigation threats).

ANNEXURE Q. ADDITIONAL TEXT MESSAGE EXCERPTS: SEVERE COMMUNICATIONS (PAGES 41–85)

The parties’ iMessage record, from which these text-message annexures are drawn, is 85 pages in length. Pages 41–85 contain the most severe and extended instances of Attorney Barrett’s abusive communications. Additional representative verbatim excerpts from those pages follow:

“Greedy pig.”

– Attorney Barrett

“Be a fucking man and take care of your kid.”

– Attorney Barrett

“You got me pregnant mother fucker.”

– Attorney Barrett

“Clearly, the funds are never coming and you’re just a fucking piece of shit.”

– Attorney Barrett

“No wonder you’re fucking delusional.”

– Attorney Barrett

“You’re fucking delusional and would benefit from a lobotomy.”

– Attorney Barrett

“I hope you enjoy bending over in prison with your bitch ass.”

– Attorney Barrett

“Clearly, your mother doesn’t know how to parent.”

– Attorney Barrett

“I will spend my entire life ensuring you are held accountable legally.”

– Attorney Barrett

“How crazy would it be for me to show up in court like yes, this is my sons father who refuses to pay child support yet makes websites and posts against me, extorting me…”

– Attorney Barrett

“The text messages you sent to yourself pretending to be me have already been investigated and proven to be from you.”

– Attorney Barrett

“Go cap some teens and blackmail them. Are you still doing that??”

– Attorney Barrett

Analysis. The concentration of extreme profanity, insult (“lobotomy,” “bitch ass,” “greedy pig,” “piece of shit”), criminal-grade unsubstantiated accusations (blackmail of minors; fabrication of evidence), and sexualized references to incarceration (“bending over in prison”) within a single text-message record from a New Hampshire attorney to an opposing party is, without qualification, conduct of a kind that, upon review of the underlying screenshots, cannot be left without public, formal, and substantial disciplinary response.

ANNEXURE R. PATTERN OF SEXUAL-MISCONDUCT ALLEGATIONS IN FINANCIAL DISPUTES

As noted at Part VI(I) of this grievance, the pattern of Attorney Barrett’s sexual-misconduct allegations is itself grounds for discipline. The pattern can be summarized as follows:
The allegations relate to events in 2013, more than a decade prior to any of the communications in this record.
The allegations are serious and, if true and proved, would constitute sexual assault. Mr. <Redacted> categorically denies them.
The allegations appear in the written record only in close temporal connection to Attorney Barrett’s renewed financial demands, responses to Mr. <Redacted>’ court motions, or responses to the since-withdrawn bar complaint.
The current record does not show pursuit of these allegations in an adjudicative or law-enforcement forum where their truth could be tested and Mr. <Redacted> could respond.
To the contrary: Attorney Barrett has explicitly offered to set aside pending legal proceedings in exchange for monetary payment (see Annexures E and F and the text-message record at Annexure H).
The strategic deployment of an allegation of sexual violence, as a tool of financial pressure in litigation, is a serious matter. It is unfair to the alleged victim (to the extent the allegation is true), as it trivializes the actual complaint; it is unfair to the alleged perpetrator (to the extent the allegation is untrue), as it inflicts unconscionable reputational damage outside any forum capable of adjudicating the matter; and it is unfair to the administration of justice, as it introduces unadjudicated criminal allegations into civil disputes for leverage. See Rule 3.4(e) and the commentary thereto.
Mr. <Redacted> respectfully requests that the Discipline Office consider this pattern separately and in addition to the other conduct catalogued in this grievance.

ANNEXURE S. ADDITIONAL PROBLEMATIC EMAILS FROM ATTORNEY BARRETT

The following additional emails from Attorney Barrett to Mr. <Redacted>, located in the <Redacted> email archive (folder: “Barrett Harassment Emails”), are each independently problematic and are reproduced or summarized here because each supplies further, distinct evidence of the conduct described in the body of this grievance.

S-1: Email of December 11, 2024 (subject blank): Quid-Pro-Quo Conditional Withdrawal of Contempt Filing

On Wednesday, December 11, 2024 at 11:14 a.m. EST, Attorney Barrett sent Mr. <Redacted> an email with no subject line containing the following text, in relevant part:

“If I Withdraw the current Contempt filing and don’t pursue anything further, would you stop with the crazy?”

– Attorney Barrett (email: Annexure S-1 – Email Conditional Contempt Withdrawal (December 11, 2024).eml, Dec. 11, 2024)

This email is a contemporaneous, written, and unambiguous admission that Attorney Barrett is prepared to initiate and withdraw contempt proceedings in <Redacted> based not on the merits but on Mr. <Redacted>’ agreement to modify his expressive behavior. The use of live judicial proceedings as a personal bargaining chip, by a licensed attorney who filed those proceedings in her own name, violates Rule 3.1 (no bona fide basis for continued prosecution once the non-merits bargaining motive is admitted), Rule 3.4(a)–(c) (abuse of adjudicative process), Rule 4.4(a) (use of means having no substantial purpose other than to embarrass or burden a third person), and Rule 8.4(d) (conduct prejudicial to the administration of justice).

S-2: Email of December 14, 2024 (subject: “Filing”): Restraining-Order Threat and Conditional Withdrawal

On Saturday, December 14, 2024 at 7:30 p.m. EST, Attorney Barrett sent Mr. <Redacted> an email with the subject line “Filing” that included, in relevant part:

“I can’t take care of Braden and live like this. You make me fear for my safety and Braden’s safety with you doing all of this.”

– Attorney Barrett (email: Annexure S-2 – Email Filing Conditional Complaint Withdrawal (December 14, 2024).eml, Dec. 14, 2024)

“I feel like I need to get a restraining order at this point.”

– Attorney Barrett (email: Annexure S-2 – Email Filing Conditional Complaint Withdrawal (December 14, 2024).eml, Dec. 14, 2024)

“It hurts me enough that you don’t care about Braden.”

– Attorney Barrett (email: Annexure S-2 – Email Filing Conditional Complaint Withdrawal (December 14, 2024).eml, Dec. 14, 2024)

“Please just stop… I will withdraw the complaint. Just please stop.”

– Attorney Barrett (email: Annexure S-2 – Email Filing Conditional Complaint Withdrawal (December 14, 2024).eml, Dec. 14, 2024)

Analysis. This email provides further written admission that Attorney Barrett offered, in writing, to withdraw a live complaint in exchange for Mr. <Redacted>’ behavioral concessions (a second admission of Rule-3.1 and Rule-3.4 violations, distinct from the December 11 admission). It additionally invokes a baseless threat of a restraining order to pressure a jurisdictionally-distant pro se opposing party. The use of unfounded threats of collateral civil process (here, a restraining order) to leverage a party into cessation of protected conduct (including lawful consumer reviews and a pending disciplinary filing) implicates Rule 4.4(a) and Rule 8.4(d).

S-3: Email Thread of September 29, 2025 (subject: “IMO TPR of MBW: Petition Service Address”)

On Monday, September 29, 2025, Attorney Barrett sent Mr. <Redacted> a series of emails in the TPR (Termination of Parental Rights) petition-service-address thread which, in addition to the “Bar complaint” email reproduced at Annexure C, contained the following verbatim abusive content:

“Good luck with your $50. Please leave me the fuck alone and stop being an absolute monster.”

– Attorney Barrett (email: Annexure S-3 – Email IMO TPR Petition Service Address Thread (September 29, 2025).eml, Sept. 29, 2025)

“Please don’t contact me again. Ever in your life. You are a fucking nightmare and I’m done with your abuse you fucking troll.”

– Attorney Barrett (email: Annexure S-3 – Email IMO TPR Petition Service Address Thread (September 29, 2025).eml, Sept. 29, 2025)

“It makes me sick to know that the father of my son is a trumper white supremacist who has no respect for women and wishes death on their own child.”

– Attorney Barrett (email: Annexure S-3 – Email IMO TPR Petition Service Address Thread (September 29, 2025).eml, Sept. 29, 2025)

“Fuck all the way off… sit and spin on it.”

– Attorney Barrett (email: Annexure S-3 – Email IMO TPR Petition Service Address Thread (September 29, 2025).eml, Sept. 29, 2025)

“What’s Wrong by Half Alive… I hope it speaks to you.”

– Attorney Barrett (email: Annexure S-3 – Email IMO TPR Petition Service Address Thread (September 29, 2025).eml, Sept. 29, 2025)

“You are so far removed from reality.”

– Attorney Barrett (email: Annexure S-3 – Email IMO TPR Petition Service Address Thread (September 29, 2025).eml, Sept. 29, 2025)

“And for you to think that he’d want to communicate with you after you’ve wished him death, is wild.”

– Attorney Barrett (email: Annexure S-3 – Email IMO TPR Petition Service Address Thread (September 29, 2025).eml, Sept. 29, 2025)

Analysis. These emails are issued in the very thread in which Attorney Barrett is purportedly exchanging service-of-process information regarding the Termination of Parental Rights petition, i.e., a communication context in which her duties under the Rules of Professional Conduct, particularly Rules 3.4, 4.4, and 8.4, are at their absolute highest. Interspersing the procedural service-of-process discussion with profane personal attacks (“fucking troll,” “fucking nightmare,” “fuck all the way off”), politically-charged defamatory characterizations (“trumper white supremacist who has no respect for women”), unsupported criminal-grade allegations (“wishes death on their own child”), and the passive-aggressive referral to a musical track titled “What’s Wrong” is conduct that violates the Rules of Professional Conduct. This email thread, standing alone, supports findings of violation of Rules 3.4(a)–(c), 4.4(a), 8.4(b), 8.4(d), and 8.4(g).

S-4: Email of April 10, 2026 (subject: “Termination of Parental Rights”): Response to Sibling’s Death

On or about April 10, 2026, in the TPR-petition thread, Attorney Barrett responded to Mr. <Redacted>’ correspondence by writing, in relevant part:

“My brother was just killed and you’re a monster who only gives a shit about himself.”

– Attorney Barrett (email: Annexure S-4 – Email Termination of Parental Rights Sibling Death Response (April 10, 2026).eml, April 10, 2026)

“Pay what you owe and leave me the fuck alone.”

– Attorney Barrett (email: Annexure S-4 – Email Termination of Parental Rights Sibling Death Response (April 10, 2026).eml, April 10, 2026)

Analysis. Mr. <Redacted> extends his sympathies for any loss Attorney Barrett has suffered. The difficulty is that the announcement of a family bereavement is interposed in the very same exchange in which Attorney Barrett is once again conditioning her professional conduct on Mr. <Redacted>’ payment of her financial demands. The intertwining of personal grief with monetary demand, in a written communication from a licensed attorney to a self-represented opposing party, is a further instance of the harassment-and-leverage pattern animating this grievance. It implicates Rule 4.4(a) and Rule 8.4(d).

S-5: Email of April 26, 2025 (subject: “Braden – Summer Programs”)

On Saturday, April 26, 2025, in the thread “Braden – Summer Programs,” Attorney Barrett wrote, in relevant part:

“How you can be so involved in tech and then not afford Braden the same opportunity is sick to me.”

– Attorney Barrett (email: Annexure S-5 – Email Summer Programs (April 26, 2025).eml, April 26, 2025)

“Everything you said was a lie.”

– Attorney Barrett (email: Annexure S-5 – Email Summer Programs (April 26, 2025).eml, April 26, 2025)

“He doesn’t deserve the way you treat him.”

– Attorney Barrett (email: Annexure S-5 – Email Summer Programs (April 26, 2025).eml, April 26, 2025)

Analysis. While couched in the language of a child-related request, the email is one of many in the record in which Attorney Barrett’s substantive communications, rather than confining themselves to the actual child-welfare subject, extend to personal moral condemnation of Mr. <Redacted> (“everything you said was a lie,” “sick to me”). See Rules 4.4(a), 8.4(d).

S-6: Pattern of Passive-Aggressive “Song” Referrals

As discussed at Annexure B (the April 10, 2026 “Obsessed” email) and in S-3 above (the “What’s Wrong” referral of September 29, 2025), Attorney Barrett has, on multiple documented occasions, used the medium of a professional legal email from a licensed attorney to an opposing party to communicate nothing but the title or link of a popular song whose lyrics are intended to convey a pejorative message about that opposing party. This is not an isolated incident; it is a repeated harassment pattern. It has no legitimate legal purpose. It implicates Rule 4.4(a) and Rule 8.4(d) each time it occurs.

S-7: Additional Scattered Problematic Passages Preserved for the Record

Mr. <Redacted> further preserves the following additional passages, found in other email exchanges in the “Barrett Harassment Emails” archive, which reinforce the patterns described throughout this grievance:

“You have a child in NH and a standing Court Order here. Should have considered the law before you fled the country to avoid paying child support.”

– Attorney Barrett (email: Annexure S-6 – Email DPPA and Additional Message (November 30, 2024).eml, Nov. 30, 2024)

“Are you going to afford Braden the opportunity to experience computer programming…”

– Attorney Barrett (email: Annexure S-5 – Email Summer Programs (April 26, 2025).eml, Spring 2025)

Mr. <Redacted> represents that the full “Barrett Harassment Emails” archive is in his possession and can be produced in full to the Discipline Office on request.

WITNESS AND CONTACT APPENDIX

The following witnesses have knowledge of the facts set out in this grievance. Contact information is provided to the Discipline Office to facilitate its investigation. Complainant requests that witness contact details be treated as confidential to the extent permitted by the Rules.

1. Complainant

Name: <Redacted>

Email: <Redacted>

Mailing address: [To be supplied by Complainant]

Telephone: [To be supplied by Complainant]

Relationship: Complainant; father of the parties’ minor child; recipient of respondent’s communications

Relevant to: All incidents

2. Complainant’s Mother

Name: <Redacted> <Redacted>

Contact: [To be provided to the Office upon request for privacy]

Relationship: Complainant’s mother; recipient of respondent’s unsolicited December 2024 and April 11, 2026 contact

Relevant to: Annexure K; Parts V(A) and VI(F)

Declaration status: To be submitted as a supplement within fourteen (14) days of filing

3. Business Partner

Name: [Withheld for privacy; to be provided to the Office upon request]

Contact: [To be provided to the Office upon request]

Relationship: Business partner of complainant; recipient of respondent’s April 2, 2026 contact

Relevant to: Annexure L; Parts V(B) and VI(F)

Declaration status: Written statement obtained; short-form declaration to be submitted within fourteen (14) days of filing

APPENDIX 1: CONTACT-INITIATION TABLE

The following table documents (1) each documented instance in which Mr. <Redacted> demanded that Attorney Barrett cease contact, and (2) Attorney Barrett’s subsequent communications after each demand. The table demonstrates that Attorney Barrett, not Mr. <Redacted>, was the initiator or re-initiator of contact in each documented cycle.

Date	<Redacted> Cease-Contact Demand	Barrett’s Subsequent Contact	Source
ca. Sept. 22, 2025	“I don’t want to talk about the past.”	“I don’t need you to keep saying the same fucking story…”	Text; Anx. J
ca. Oct. 13, 2025	“I want nothing to do with you.” / “Again I am telling you to stop messaging me.”	Continued messages re: Feds, arrest, child support demands	Text; Anx. J, H
ca. Oct. 14, 2025	“Please stop talking to me. I’m warning you to stop.”	“Because you’re fucking dumb and you lie all the time.” + continued messages	Text; Anx. G, J
Dec. 2024	“If you contact my family again, a restraining order will be taken against you.”	Apr. 11, 2026: renewed contact with mother (16+ months later)	Email; Anx. K
ca. Jan. 3, 2026	“I don’t want to talk to you.”	“Okay I will file for termination when I have the money!” + continued messages	Text; Anx. J, I
Apr. 10-11, 2026	[Prior written demands on record]	Two emails in 19 hours: “Why you so obsessed with me?” + “Get a fucking life!”	Email; Anx. A, B
Apr. 2, 2026	[No direct demand to this third party; she had no prior relationship with Barrett]	Contact with business partner; partner blocked Barrett	Written stmt; Anx. L

In every documented cycle, Mr. <Redacted> demanded that contact cease, and Attorney Barrett continued or re-initiated contact. The table above is representative, not exhaustive; the full text-message record at Annexures G through J contains additional instances.

APPENDIX 2: TIMEZONE RECONCILIATION OF KEY TEXT MESSAGES

The text-message timestamps in the source iMessage record (reproduced across Annexures G through Q) were captured on devices configured to Australian Eastern Time (AEST/AEDT, Sydney). The following table reconciles key timestamps to U.S. Eastern Time (ET) for the convenience of the Discipline Office. Sydney is generally 14-16 hours ahead of U.S. Eastern Time, depending on daylight-saving arrangements in both jurisdictions.

Sydney Time (as shown in source)	U.S. Eastern Time (estimated)	Key Quote / Reference	Annexure
Mon, Sept. 22, 2025 (various)	Sun, Sept. 21, 2025 (approx. 14 hrs earlier)	“So fuck off with that shit” + multiple	G, J
Thu, Oct. 9, 2025, 09:39 AEDT	Wed, Oct. 8, 2025, ~18:39 ET	“I think you forgot I’m not a fucking idiot”	G
Mon, Oct. 13, 2025 (various) AEDT	Sun, Oct. 12, 2025 (approx. 15 hrs earlier)	“Be a fucking man” / Fed threats	G, H, I
Tue, Oct. 14, 2025 (various) AEDT	Mon, Oct. 13, 2025 (approx. 15 hrs earlier)	“fucking piece of shit” / “fucking dumb”	G, N
Sun, Oct. 19, 2025, 02:54 AEDT	Sat, Oct. 18, 2025, ~11:54 ET	“benefit from a lobotomy” / “bending over in prison”	G, H
Sat, Jan. 3, 2026 (various) AEDT	Fri, Jan. 2, 2026 (approx. 16 hrs earlier)	“file for termination when I have the money”	I, J

Note: Email timestamps (Annexures A through F and S-series) carry explicit UTC offsets in the SMTP headers and do not require timezone reconciliation. The reconciliation above applies only to text-message screenshots. A complete reconciliation of all text-message timestamps will be provided within seven (7) days of any request.

OATH FORM

Pursuant to New Hampshire Supreme Court Rule 37A, the undersigned complainant submits this grievance under oath.

I, <Redacted>, being first duly sworn, depose and state that: I have read the foregoing Verified Grievance Against Attorney Elizabeth J. Barrett, Esq. The statements of fact contained therein are true and correct to the best of my knowledge, information, and belief. The documents appended as annexures are true and accurate copies of the original communications they purport to reproduce.

___________________________________

<Redacted>, Complainant

Date: April 15, 2026

CERTIFICATION OF COPIES

Pursuant to New Hampshire Supreme Court Rule 37A, the undersigned certifies that a complete copy of this Verified Grievance, including all annexures and enclosures, has been sent to the respondent at the following address:

Attorney Elizabeth J. Barrett, Esq.

1 New Hampshire Ave. Suite 125 · Portsmouth, NH 03801

Portsmouth, New Hampshire

Method of service: Email

Date of service: April 15, 2026

The undersigned further certifies that the copy sent to respondent is a true, correct, and complete copy of the original filing submitted to the Attorney Discipline Office, including all enclosures.

___________________________________

<Redacted>, Complainant

Date: April 15, 2026

END OF GRIEVANCE

This Verified Grievance, including all annexures, is submitted on April 15, 2026 by <Redacted>, Complainant. This grievance is a comprehensive, standalone filing that encompasses all conduct by Attorney Barrett from 2013 to the present, including all claims re-incorporated from the withdrawn September 18, 2025 complaint.

Signed: ________________________________

<Redacted>, Complainant

Date: April 15, 2026

Email: <Redacted>

Mailing Address: <Redacted>

Telephone: <Redacted>

NH Bar Complaint Against Elizabeth Barrett (April 15, 2026)

TABLE OF CONTENTS

A. The Complainant

B. The Respondent

C. Jurisdiction

A. The Procedural Ambush at the January 6, 2025 Hearing

B. Weaponization of Online-Review Platforms

C. Jurisdictional Overreach Against an Overseas Resident

D. Direct Threats Following the Prior Complaint

E. Pattern of Profanity, Abuse, and Unprofessional Conduct

F. Harassment of Mr. <Redacted>’ Family

G. Use of the Child as Emotional Leverage

D. Aggravating Factors

E. Preemption of Anticipated Defenses

VII-A. CHRONOLOGY OF KEY EVENTS

2013

2013–2023

2024

2025

2026

VII-B. MR. <REDACTED>’ CONDUCT DISTINGUISHED

ANNEXURES

Full text as sent:

Key verbatim passages from the email (redactions, if any, are indicated by ellipses in square brackets):

Key verbatim passage:

Key verbatim passages:

Key verbatim passages:

1. December 2024: “Christmas List” and Accompanying Correspondence

2. April 11, 2026: Renewed Unsolicited Contact

S-1: Email of December 11, 2024 (subject blank): Quid-Pro-Quo Conditional Withdrawal of Contempt Filing

S-2: Email of December 14, 2024 (subject: “Filing”): Restraining-Order Threat and Conditional Withdrawal

S-3: Email Thread of September 29, 2025 (subject: “IMO TPR of MBW: Petition Service Address”)

S-4: Email of April 10, 2026 (subject: “Termination of Parental Rights”): Response to Sibling’s Death

S-5: Email of April 26, 2025 (subject: “Braden – Summer Programs”)

S-6: Pattern of Passive-Aggressive “Song” Referrals

S-7: Additional Scattered Problematic Passages Preserved for the Record

1. Complainant

2. Complainant’s Mother

3. Business Partner

END OF GRIEVANCE

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