OUTPOST 422® | JEDVIDENCE™

PRESS RELEASE & INVESTIGATIVE LEGAL MEMORANDUM

FOR PUBLIC RELEASE — November 8, 2026

Boardman & Clark LLP Faces 36-Item Independent Review of Alleged Litigation Animus Toward Self-Represented Complainant

MADISON, WISCONSIN — OUTPOST 422®, through its JEDVIDENCE™ investigative research framework, announces a 36-item comparative examination of litigation submissions prepared by attorneys Robert E. Gregg and Storm B. Larson of Boardman & Clark LLP.

The investigation concerns two separate employment-discrimination proceedings involving journalist and self-represented complainant Bradley J. Burt.

The documents under examination are Gregg’s January 30, 2026, initial response on behalf of Frank Productions LLC in Madison Equal Opportunities Division Case No. 2025-00002 and Larson’s May 19, 2026, position statement on behalf of Camp Createability LLC in Wisconsin Equal Rights Division Case No. CR202601199.

The investigative theory, described as work-product animus, questions whether materially inaccurate factual representations, unsupported witness characterizations, or unnecessarily disparaging advocacy were used to prejudice a self-represented complainant.

No court has determined that the attorneys or their firm engaged in misconduct based on the materials examined for this release.

I. The Federal Standard: Bad-Faith Litigation Conduct

Federal jurisprudence recognizes judicial authority to address proven abuses of the litigation process.

In Chambers v. NASCO, Inc., 501 U.S. 32, 43–46 (1991), the United States Supreme Court recognized federal courts’ inherent authority to sanction litigation conduct undertaken in bad faith, including certain forms of fraud, harassment, and oppressive litigation practices.

In Roadway Express, Inc. v. Piper, 447 U.S. 752, 764–67 (1980), the Supreme Court addressed sanctions and attorney responsibility for unreasonable litigation conduct, emphasizing procedural safeguards before sanctions are imposed.

Federal Rule of Civil Procedure 11(b) additionally requires factual contentions presented to federal courts to have evidentiary support or an appropriate basis for anticipated evidentiary support.

These authorities establish standards for examining litigation misconduct. They do not establish that disputed employer position statements submitted to state or municipal administrative agencies automatically violate federal procedural rules.

II. The Gregg Submission: Witness Attribution and Termination Justification

Gregg’s 118-page submission advances Frank Productions’ position that Burt’s November 2024 termination resulted from alleged threatening conduct rather than disability discrimination or retaliation.

The response attributes statements to employees, describes management’s knowledge, discusses earlier workplace complaints, and characterizes Burt’s conduct and communications.

OUTPOST 422’s review will examine the original witness statements, the chronology of protected-activity complaints, the employer’s contemporaneous communications, and the evidentiary foundation for the asserted termination reasons.

The investigation will distinguish statements made from personal knowledge from secondhand accounts, legal arguments, and characterizations supplied by the employer.

III. The Larson Submission: Retaliation Knowledge and Witness Reliability

Larson’s eight-page position statement advances Camp Createability’s position that Burt was discharged for performance and conduct reasons rather than retaliation or disability discrimination.

The statement acknowledges that Burt mentioned retaliation and harassment to employee Emily Williams but maintains that the termination decisionmaker, Debbie Armstrong, did not know of those allegations.

This distinction presents a material factual question: what information reached the decisionmaker before the June 7, 2025, termination?

The investigation will compare the position statement with contemporaneous communications, termination records, and any independently authenticated witness accounts.

IV. The 36-Item JEDVIDENCE Examination

The comparative review consists of 18 disputed-representation questions concerning Gregg’s submission and 18 concerning Larson’s submission.

Each item will be examined under four evidentiary considerations:

1. Provenance: Who originated the representation, and what primary record supports it?
2. Accuracy: Does the statement accurately reflect the available documentary record?
3. Knowledge: What evidence establishes what the author knew when the representation was submitted?
4. Materiality: Could the alleged discrepancy affect an issue relevant to the underlying proceeding?

The review does not equate an adverse legal argument, disputed witness statement, or factual inconsistency with perjury or intentional fabrication.

V. Federal Accountability and the Limits of the Proposed Theory

In Chambers, the Supreme Court explained that federal courts may respond to established bad-faith litigation conduct through their inherent powers.

Separately, 28 U.S.C. § 1927 permits certain sanctions against attorneys who unreasonably and vexatiously multiply federal court proceedings.

Neither authority independently creates a general damages action against a law firm for alleged hostility toward a self-represented opposing party.

Any proposed federal action against Boardman & Clark LLP must therefore identify an independently recognized cause of action, establish federal jurisdiction, and address applicable defenses, including litigation privilege.

VI. Public Interest and Next Steps

OUTPOST 422 considers the accuracy of factual representations in employment-discrimination proceedings a legitimate subject of investigative reporting.

The 36-item review is intended to distinguish advocacy from factual reporting, test witness provenance, identify material contradictions, and evaluate whether any documented conduct warrants administrative correction, professional review, or legally available judicial relief.

Burt has indicated his intention to begin evaluating federal filing procedures on November 9, 2026. No federal complaint is represented here as having been filed.

Boardman & Clark LLP, Gregg, Larson, and the respective employers should be afforded an opportunity to respond to any specific allegations before final investigative findings are published.

Editorial disclosure: This report concerns disputed allegations in proceedings involving the publisher. The publisher is also the complainant in the underlying matters. No independent judicial finding of attorney misconduct has been established.

OUTPOST 422® | JEDVIDENCE™
Independent Investigative Journalism and Legal Research
https://outpost422.com/

Federal Authorities

• Chambers v. NASCO, Inc., 501 U.S. 32, 43–46, 50–51 (1991).
• Roadway Express, Inc. v. Piper, 447 U.S. 752, 764–67 (1980).
• Fed. R. Civ. P. 11(b)–(c).
• 28 U.S.C. § 1927.

Research disclaimer: The federal authorities concern standards applicable in federal judicial proceedings. Their citation does not establish that those standards directly govern the two underlying administrative submissions or create a private cause of action against opposing counsel.