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Having apparently studied up on the playbook Germany was using in WWII (no, this is not the time to invoke Godwin’s Law), Perdigao decided it was time to open another front in the war. So on May 27th, he filed a complaint against his former law firm, Adams and Reese, asserting that it was being operated as a racketeering enterprise.

There are aspects of this complaint that completely mystify me. For instance, there are lots and lots of allegations (key word) of really outrageous criminal behavior in which Mr. Perdigao participated to varying degrees, with apparently varying degrees of enthusiasm. But it is hard to see exactly how he was a victim of this activity, even if true. He seems more a participant to me, even in his own account. And given that the complaint is signed and sworn to by Perdigao, its allegations of his participation are going to be troublesome for him if his criminal case should ever come to trial.

Rendered in simplest terms, think of it as something like this: Say you have an armed robbery, in which the participants were the-guy-with-the-gun, the-guy-who-carried-the-loot, and the-guy-who-drove-the-getaway-car. Here we have, say, the getaway driver suing all the other participants, saying, ‘You made me lead a life of crime!’

An unusual theory of liability, I think.  But it makes for an interesting story…

Before going farther with this, I’m going to note that Adams and Reese issued a statement about the complaint:

The lawsuit filed Tuesday represents the latest episode in Perdigao’s continuing fantasy of blaming the government and our firm for his wrongdoing and lashing out at those who are holding him accountable for his actions.

Adams and Reese denies Perdigao’s allegations of wrongdoing. We look forward to his upcoming criminal trial and we will continue to cooperate with the U.S. Attorney and the FBI to ensure that justice is done.

Denied allegations or not, it’s (by standards of ordinary complaint writing) a heckuva read, with a very strong picaresque quality– one roguish adventure after another, although not held together by much in the way of an overall plot.

The defendants are the law firm and a number of partners in firm management. The complaint alleges that they operated ‘in a plan of deceit and deception, whereby they would and did abuse their position of trust and fiduciary relationships with the plaintiff, other partners and others’ The complaint is full of little ironies, such as that Perdigao became ‘Ethics Advisor of the Business Division, [thus] designated as the conscience of the Business Division’  The complaint alleges:

• A scheme to bribe the US Attorney through Congressman William Jefferson. This was to obtain a better sentencing deal for Robert Guidry. Apparently, Guidry asked Perdigao to find out how to ‘get to’ the then-U.S. Attorney. A partner is alleged to have said the best way to get to the U.S. Attorney was through Jefferson. Another partner noted ‘that Guidry had –’balls of steel’ to contemplate bribing a prosecutor when he was getting ready to get indicted in a corruption case.’  Guidry told Perdigao how he bribed Jefferson. ‘[H]e never placed the money directly in Jefferson’s hands, but rather under the back steps while Jefferson watched inside through the window. [On] his first –’drop’ under the back steps of Jefferson’s house in New Orleans, [w]hen he entered the back yard, he found two sets of steps. With a puzzled look, he glanced through the window for directions from Jefferson. [B]oth he and Jefferson –’cracked up laughing’ as Jefferson pointed him to behind a planter’ The U.S. Attorney agreed to cap Guidry’s financial exposure at $3.5 million, and then later claimed that Guidry’s plea agreement included immunity from state claims.
• A scheme to move assets off Guidry’s financial statement to off-shore accounts to hide them.
• A traffic-ticket fixing scheme for Adams and Reese lawyers arranged through a lawyer at the firm who was a part-time traffic court judge in New Orleans.
• Failing to advise WorldCom and Bernie Ebbers that there should be conflict waivers and other documentation as a part of loans Ebbers was getting from WorldCom to meet margin calls as the value of WorldCom stock fell.
• Misleading the bankruptcy examiner about legal advice and facts relating to the advice that the firm had given WorldCom.
• The hiring of former New Orleans mayor Mark Morial in a way to evade Louisiana anti-corruption statutes that would have prohibited him or the firm from working on city work for two years, and the manipulating of billing records to conceal they had done this. Similar charges were made about a former Jefferson Parish president and former Louisiana Insurance Commissioner Robert Wooley (the firm seems to like employing former insurance commissioners). There are related allegations of a scheme to obstruct justice relating to a grand jury subpoena about Morial’s billing records.
• Allegations that Insurance Commissioner Wooley, while commissioner, was doing the bidding of Adams and Reese clients (the allegations of various transactions involving insurance companies involve a large part of the middle third of the complaint).
• Allegations involving a conflict of interest between two firm clients in obtaining a state Medicaid Management contract.
• Allegations of impropriety concerning the brokering of state motion picture tax credits.
• Lots of allegations of hostility and unpleasantness during and after Perdigao’s departure from the firm, including an incident where a partner encountered Perdigao in a parking lot and told him: ‘The snitch usually ends up in a ditch.’

Here’s the Perdigao Complaint.