IOWA SUPREME COURT ATTORNEY DISCIPLINARY BOARD 

COMES NOW Pro Se Michael J. Merritt for Complainant Cipher Hunter, in this matter before the Iowa Supreme Court Attorney Disciplinary Board. Respectfully requesting review of the below testimony and evidence in accordance with Iowa Rules of the Court Chapter 32 and 35.

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I. PARTIES

1. Petitioner, Cipher Hunter, is a civic transparency and records research initiative focused on the protection of civil liberties and governmental accountability registered in Marshall County, Iowa, and managed by Michael J. Merritt. Mr. Merritt is a retired U.S. Navy veteran, information warfare specialist, and public records researcher. He is also an advocate for domestic violence survivors, individuals living with mental health disabilities, and veterans affected by military sexual trauma (MST).
2. Respondent, Assistant to Governor Taryn Frideres, serves as Chief of Staff to Iowa Governor Kim Reynolds and is the former General Counsel to U.S. Senator Joni Ernst. Taryn Frideres is the direct reporting supervisor of Megan Hall, the designated public records custodian for the Office of the Governor.

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II.  CAUSE OF ACTION

Multiple alleged violations of the Iowa Rules of Professional Conduct stem from a unified sequence of factual events. To maintain legal sufficiency for each rule cited, overlapping facts appear where necessary to establish each violation in isolation.

1. 32:5.3(b) — “a lawyer having direct supervisory authority over the nonlawyer shall make reasonable efforts to ensure that the person’s conduct is compatible with the professional obligations of the lawyer; and” (which governs attorney supervision of nonlawyers) — Evidence supports that Assistant to Governor Taryn Frideres (Governor Record Custodian Megan Hall’s reporting supervisor (See Attachment 7))—through a pattern of supervisory inaction, failure to correct, and possible ratification of misconduct by her direct subordinate knowingly misrepresented the availability of public records, misstated the date of the original records request, and failed to release the requested records, in violation of Iowa Code Chapter 22 (See Iowa Public Information Board Case No. 22FC:091).  As a senior official, Taryn Frideres bears responsibility not only for her own historical conduct, but also for the conduct of personnel under her supervision. Megan Hall’s response to a request submitted pursuant to Iowa Code § 22.4(2) indicates either a lack of ethical commitment to transparency or a failure by Frideres to adequately train and oversee individuals she has entrusted with operational responsibilities for responding to public records requests submitted to the Office of Governor Kim Reynolds.
2. 32:5.3(c) — “a lawyer shall be responsible for conduct of such a person that would be a violation of the Iowa Rules of Professional Conduct if engaged in by a lawyer if: (1) the lawyer orders or, with the knowledge of the specific conduct, ratifies the conduct involved;”(which governs attorney supervision of nonlawyers) — Evidence supports that Assistant to Governor Taryn Frideres (Governor Record Custodian Megan Hall’s reporting supervisor (See Attachment 7))—through a pattern of supervisory inaction, failure to correct, and possible ratification of misconduct by her direct subordinate knowingly misrepresented the availability of public records, misstated the date of the original records request, and failed to release the requested records, in violation of Iowa Code Chapter 22 (See Iowa Public Information Board Case No. 22FC:091).  As a senior official, Taryn Frideres bears responsibility not only for her own historical conduct, but also for the conduct of personnel under her supervision. Megan Hall’s response to a request submitted pursuant to Iowa Code § 22.4(2) indicates either a lack of ethical commitment to transparency or a failure by Frideres to adequately train and oversee individuals she has entrusted with operational responsibilities for responding to public records requests submitted to the Office of Governor Kim Reynolds.
3. 32:8.4(d) — “engage in conduct that is prejudicial to the administration of justice;” — Evidence supports that Office of the Governor Record Custodian Megan Hall—who reports directly to Assistant to Governor Taryn Frideres—knowingly misrepresented the original date of a public records request, possibly to reshape the historical timeline to adhere to Iowa Code § 22.8(4)(d), and failed to release requested social media block lists. (See: Iowa Public Information Board Case No. 22FC:0091.) Evidence indicates these block lists are the property of the State of Iowa pursuant to § 1 of Article IV of The Constitution of the State of Iowa and are therefore subject to public access under Iowa Code Chapter 22 (See Attachment 5).
4. 32:8.4(d) — “engage in conduct that is prejudicial to the administration of justice;” — Evidence supports that Office of the Governor Record Custodian Megan Hall—who reports directly to Assistant to Governor Taryn Frideres—failed to provide requested contact information for the servicing of court documents, thereby burdening and delaying a third party’s exercise of legal rights.  This omission served no substantial purpose other than to obstruct lawful efforts to litigate or serve necessary court documents (See Attachment 6).
5. 32:4.1(a) — “make a false statement of material fact or law to a third person; or” Evidence supports that Office of the Governor Record Custodian Megan Hall—who reports directly to Assistant to Governor Taryn Frideres—knowingly misrepresented the original date of a public records request by stating, “On December 30, 2024, we received your request to inspect certain records.”  This misrepresentation appears to have been made in an attempt to reshape the historical timeline in a manner consistent with Iowa Code § 22.8(4)(d), which governs permissible delays in responding to public records requests (See Attachment 5).
6. 32:4.1(a) — “make a false statement of material fact or law to a third person; or” Evidence supports that Office of the Governor Record Custodian Megan Hall—who reports directly to Assistant to Governor Taryn Frideres—knowingly misrepresented the availability of public records, specifically social media block lists, despite publicly available evidence on Governor Kim Reynolds’ official website showing active social media profiles that belong to the State of Iowa pursuant to § 1 of Article IV of The Constitution of the State of Iowa. Hall stated, “It has been determined, following a search and review for potentially responsive records, that the agency does not possess any records that are responsive to your request.” This response stands in direct conflict with observable state-operated accounts and raises serious concerns regarding the agency’s candor and commitment to lawful transparency under Iowa Code Chapter 22 (See Attachment 5).
7. 32:4.4(a) — “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, or use methods of obtaining evidence that violate the legal rights of such a person.” — Evidence supports that Office of the Governor Record Custodian Megan Hall—who reports directly to Assistant to Governor Taryn Frideres—knowingly misrepresented the availability of public records, specifically social media block lists, despite publicly available evidence on Governor Kim Reynolds’ official website showing active social media profiles that belong to the State of Iowa pursuant to § 1 of Article IV of The Constitution of the State of Iowa. Hall stated, “It has been determined, following a search and review for potentially responsive records, that the agency does not possess any records that are responsive to your request.” This response stands in direct conflict with observable state-operated accounts and raises serious concerns regarding the agency’s candor and commitment to lawful transparency under Iowa Code Chapter 22 (See Attachment 5).
8. 32:4.4(a) — “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, or use methods of obtaining evidence that violate the legal rights of such a person.” — Evidence supports that Office of the Governor Record Custodian Megan Hall—who reports directly to Assistant to Governor Taryn Frideres—failed to provide requested contact information for the servicing of court documents, thereby burdening and delaying a third party’s exercise of legal rights.  This omission served no substantial purpose other than to obstruct lawful efforts to litigate or serve necessary court documents (See Attachment 6).
9. 32:8.4(c) — “engage in conduct involving dishonesty, fraud, deceit, or misrepresentation;” — Evidence supports that Office of the Governor Record Custodian Megan Hall—who reports directly to Assistant to Governor Taryn Frideres—knowingly misrepresented the original date of a public records request by stating, “On December 30, 2024, we received your request to inspect certain records.”  This misrepresentation appears to have been made in an attempt to reshape the historical timeline in a manner consistent with Iowa Code § 22.8(4)(d), which governs permissible delays in responding to public records requests (See Attachment 5).
10. 32:8.4(c) — Evidence supports that Office of the Governor Record Custodian Megan Hall—who reports directly to Assistant to Governor Taryn Frideres—knowingly misrepresented the availability of public records, specifically social media block lists, despite publicly available evidence on Governor Kim Reynolds’ official website showing active social media profiles that belong to the State of Iowa pursuant to § 1 of Article IV of The Constitution of the State of Iowa. Hall stated, “It has been determined, following a search and review for potentially responsive records, that the agency does not possess any records that are responsive to your request.” This response stands in direct conflict with observable state-operated accounts and raises serious concerns regarding the agency’s candor and commitment to lawful transparency under Iowa Code Chapter 22 (See Attachment 5).
11. 32:8.4(a) — “violate or attempt to violate the Iowa Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another;” — This complaint alleges that through a pattern of supervisory inaction, failure to correct, and possible ratification of misconduct by her direct subordinate, Assistant to Governor Taryn Frideres has enabled or ratified conduct supporting ten distinct violations of the Iowa Rules of Professional Conduct as supported by the testimony and evidence within this complaint.

The following section provides a factual timeline and documentation supporting the violations outlined above.

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III. FACTS AND BACKGROUND

The timeline of evidence submitted supports that Taryn Frideres, in her leadership capacity over her subordinate Megan Hall, failed to properly respond to or release requested public records on two occasions.  The public records requested in Attachment (6) provide evidence of two additional requests Taryn Frideres disregarded.

Timeline of Events

Each of the following events corresponds to a documented attachment and supports the foundation for the alleged Iowa Rules of Professional Conduct violations outlined in Section II.

1. 11 OCT 2022 — Former Iowa Public Information Board Executive Director Margaret E. Johnson communicated in her initial dismissal of IPIB case 22FC:0091, “The Jasper County attorney contacted the IPIB on September 16, 2022, and filed a response on September 22, 2022. In response to the complaint, the County attorney stated that the County “has no such list. It does not exist anywhere. There is no ‘public record’ of such a list kept anywhere in Jasper County, including in its computer systems. Because such a list does not exist, it is impossible to comply with Mr. Merritt’s request.”  Public records are defined in Iowa Code section 22.1(3)(a) as records “stored or preserved in any medium, or of belonging to… any county….” If the government body does not store or preserve a specific record, then there is no record to be released to a record requester.  Iowa Code section 23.8 requires that a complaint be within the IPIB’s jurisdiction, appear legally sufficient, and could have merit before the IPIB accepts a complaint. This complaint does not meet the necessary requirements for acceptance.”  At the same time, the evidence indicates that former Iowa Public Information Board Executive Director Margaret E. Johnson’s original dismissal is legally insufficient because it completely disregards the “belonging” aspect of Iowa Code Section 22.1(3)(a).  Johnson’s interpretation of Iowa Code Section 22.1(3)(a) also misrepresents the very text the Executive Director was referencing while possibly assisting Jasper County, IA, with withholding their social media block lists during the 2022 election year.  Given available public domain name system (DNS) evidence showing the vast majority of State of Iowa government bodies contractually store and preserve their public records via commercial assets (i.e., Microsoft, Google, or Facebook) if Johnson’s interpretation were applied statewide, it would exempt nearly all electronic records hosted on Microsoft, Google, and Facebook’s infrastructure from Chapter 22—effectively rendering Iowa’s transparency statute obsolete in the digital age. — (See Attachment 1, Memorandum — Iowa Public Information Board — Dismissal — 11 OCT 2022).
2. 09 NOV 2022  — Upon the Iowa Public Information Board tabling former Iowa Public Information Board Executive Director Johnson’s 11 OCT 2022 dismissal, it was determined that Facebook block lists “belonging to… any county….” are public records in the State of Iowa.  — (See Attachment 2, Memorandum — Iowa Public Information Board — Revised Dismissal — 09 NOV 2022).
3.  03 DEC 2024 — The Complainant requested pursuant to Iowa Code Section 22.4(2) a copy of the social media block list for the Office of the Governor of the State of Iowa.  Article 4 of the Constitution of the State of Iowa provides evidence that the Governor’s office belongs to the State of Iowa.  At the same time, Attachments (8.) and (9.) provide evidence that the Facebook Page “Governor Kim Reynolds” (https://www.facebook.com/IAGovernor) belongs to the State of Iowa, as it is labeled “Government Official.”  — (See Attachment 3, Electronic Mail — Michael J Merritt — 03 DEC 2024–1623).
4.  30 DEC 2024 — After no evidence supporting a response from Governor Kim Reynolds or a proper release of public records, a status request was sent to the Office of the Governor.  — (See Attachment 4, Electronic Mail — Michael J Merritt — 30 DEC 2024–0827).
5.  10 JAN 2025 — Megan Hall who reports to Taryn Frideres responded, “On December 30, 2024, we received your request to inspect certain records. It has been determined, following a search and review for potentially responsive records, that the agency does not possess any records that are responsive to your request.” This response provides evidence of both a misrepresentation of the original request date—placing it outside the suggested timeline under Iowa Code Section 22.8(4)(d)—and a false denial regarding the availability of the Governor’s Facebook Page block list.  — (See Attachment 5, Electronic Mail — Megan Hall — 10 JAN 2025–0928).
6.  22 JAN 2025 — An email was sent to Megan Hall who reports to Taryn Frideres communicating, “The originator of this request has attempted to acquire public records from the Executive Department of the State of Iowa since the second half of 2024 with no supporting evidence of proper cooperation or adherence to this state’s laws provided by the Office of the Governor of the State of Iowa. I am respectfully requesting the following public records:  1.  Open records requests, including the words 12th Fleet that evidence indicates were ignored by the Executive Department of the State of Iowa during the 2nd half of 2024.  2.  All record requests received by the Office of the Governor of the State of Iowa from the originator of this request (or any email address associated with the provided domain).  The originator of this correspondence requests confirmation that the following address is the appropriate destination for a process server to deliver court documents that will be filed in Marshall County Court by 01 APR 2025.”  No evidence of a response to a request for additional public records or a proper address for the service of court documents was provided by Megan Hall who reports to Taryn Frideres — (See Attachment 6, Electronic Mail — Michael J Merritt — 22 JAN 2025 — 1356).
7.  13 JUN 2025 — Evidence supporting an internal State of Iowa Governor org chart showing Megan Hall reports to Taryn Frideres — (See Attachment 7, State of Iowa Team View — Taryn Frideres — 13-6-2025_225526).
8.  13 JUN 2025 — Evidence supporting the official social media profiles for the Office of The Governor of the State of Iowa — (See Attachment 8, Screenshot — governor-iowa-gov — 13-6-2025_22577).
9.  14 JUN 2025 — Evidence supporting that Facebook Page “Governor Kim Reynolds” (https://www.facebook.com/IAGovernor) is a “Government Official” Facebook Page belonging to the State of Iowa as the Facebook page intro states, “Official account for the Governor of Iowa, Kim Reynolds.” — (See Attachment 9, Screenshot – facebook-com-iagovernor – 14-6-2025_22019 – 2025-06-21 223008). 

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IV. ATTACHMENTS

1. Memorandum — Iowa Public Information Board — Dismissal — 11 OCT 2022
2. Memorandum — Iowa Public Information Board — Revised Dismissal — 09 NOV 2022
3. Electronic Mail — Michael J Merritt — 03 DEC 2024–1623
4. Electronic Mail — Michael J Merritt — 30 DEC 2024–0827
5. Electronic Mail — Megan Hall — 10 JAN 2025–0928
6. Electronic Mail — Michael J Merritt — 22 JAN 2025 — 1356
7. State of Iowa Team View — Taryn Frideres — 13-6-2025_225526
8. Screenshot — governor-iowa-gov — 13-6-2025_22577
9. Screenshot – facebook-com-iagovernor – 14-6-2025_22019 – 2025-06-21 223008

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V. ANALYSIS

The historical evidence supports the conclusion that the Office of the Governor, under Kim Reynolds, does not act in support of government transparency.  At the same time, the evidence supports that unethical actors, licensed by this Court (Taryn Frideres) and employed within the Office of the Governor, have enabled and perpetuated this form of administrative tyranny—through silence, stonewalling, and disregarding requests that are received by citizens of entities possibly perceived as non-threatening.

“A journalist is arrested and put on trial for doing her job. The governor’s office and state agencies defy the law without consequence by ignoring or refusing requests for public records. A veteran state employee claims she was fired for complying with the law and providing a public record to a reporter.”

“Just last week, Iowa Capital Dispatch Deputy Editor Clark Kauffman reported that the governor’s office ignored public records requests related to the firing of the head of the Iowa Veterans Home. Among documents obtained elsewhere by Iowa Capital Dispatch were a series of thank-you notes former Commandant Timon Oujiri had written to the governor and chief of staff for “raises.” Two years after the first note, he was fired for receiving overpayments.”

Pfannenstiel, Brianne. The Reynolds Administration Is the Least Transparent in 30 Years. Iowa Capital Dispatch, 9 Aug. 2021, https://iowacapitaldispatch.com/2021/08/09/the-reynolds-administration-is-the-least-transparent-in-30-years/. Accessed 22 June 2025.

“The state of Iowa agreed Wednesday to pay more than $174,000 in attorney fees to settle three lawsuits against Republican Gov. Kim Reynolds that accused her of failing to follow the state’s public records law.

The settlements follow an Iowa Supreme Court ruling from April in which the justices unanimously agreed the governor’s office can be sued for not providing public documents in a timely manner and allowed the lawsuits to continue. The parties have decided to settle the lawsuits instead of continuing the fight in court.

Reynolds’ office did not provide certain public records for more than a year after they were requested by journalists, and only provided the documents after lawsuits were filed. The settlement agreements state the governor and her staff are not admitting to violating any laws or policies.”

Sostaric, Katarina. Reynolds Settles Three Lawsuits Accusing Her of Violating Iowa’s Public Records Law. Iowa Public Radio, 21 June 2023, https://www.iowapublicradio.org/state-government-news/2023-06-21/reynolds-settles-three-lawsuits-accusing-her-of-violating-iowas-public-records-law. Accessed 22 June 2025.

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VI. CONCLUSION

The evidence presented in this complaint does not merely describe violations of the Iowa Rules of Professional Conduct—it exposes a broader failure of ethical leadership and systemic accountability at the highest levels of government. Assistant to the Governor Taryn Frideres, by either action or omission, enabled misconduct that deprived the public of lawful access to records, distorted the legal timeline of request fulfillment, and obstructed access to constitutional remedies.  This complaint respectfully requests that the Iowa Supreme Court Attorney Disciplinary Board not merely examine the cited violations, but confront a broader culture of impunity.

This matter implicates not only the operational integrity of the office of State of Iowa Governor Kim Reynolds, but the ethical standards by which this Court vests public trust in its licensees.  The conduct of Assistant to the Governor Taryn Frideres constitutes a serious breach of professional responsibility, meriting immediate investigation by the Iowa Supreme Court Attorney Disciplinary Board. This matter implicates not only the credibility of a state agency but also the standards of integrity governing the Iowa Bar and the Court’s licensing authority.

Moreover, the Iowa Supreme Court has communicated regarding Iowa Code Chapter 22 “The purpose of the statute is to open the doors of government to public scrutiny [and] to prevent government from secreting its decision-making activities from the public, on whose behalf it is its duty to act.” ’ “Diercks, 806 N.W.2d at 652 (quoting Rathmann v. Bd. of Dirs., 580 N.W.2d 773, 777 (Iowa 1998)). “ ‘Accordingly, there is a presumption of openness and disclosure under this chapter.’ ” Id. (quoting Gabrilson v. Flynn, 554 N.W.2d 267, 271 (Iowa 1996)). 

This is not merely a guiding principle—it is binding law. Taryn Frideres’ conduct, as detailed in this declaration, cannot be reconciled with that mandate. The record supports a finding that her actions violate both Iowa statutory law and the Iowa Rules of Professional Conduct, and directly contradict Iowa’s constitutional commitments to transparency and civil rights protection.

Taryn Frideres’ failure to uphold her duties under Iowa Code Chapters 22 reflects not only her personal conduct, but also the institutional posture of the Office of the Governor of the State of Iowa. If left unaddressed, this matter would cast serious doubt on the Court’s commitment to holding its licensees to meaningful standards of legal and ethical accountability.

Accordingly, the undersigned respectfully requests that the Iowa Supreme Court Attorney Disciplinary Board initiate a formal review of Taryn Frideres’ conduct. This is not merely a request for disciplinary review—it is an affirmation that legal licensure in Iowa demands fidelity to law, transparency, and justice.

The Form of the Iowa Judicial Branch Licensed Gaslit Reality Distortion Field

A form of unethical rhetoric practiced or enabled by licensed attorneys of the Iowa Judicial Branch, characterized by misrepresentation, intentional ambiguity, and strategic omissions (See Iowa Rules of the Court §§ 32:4.1(a), 32:8.4(c))—with the malicious or willfully negligent intent of distorting the recipient’s perception and understanding of reality.

Simultaneously, it functions to damage, obstruct, or delay (See Iowa Rules of the Court § 32:4.4(a)) the individual’s access to rights, liberties, and lawful remedies.

At the same time, unethical actors within the Iowa Judicial Branch’s licensed community serve to enable and manifest the state’s corruption, authoritarianism, and tyranny—all under the cloak of bureaucratic procedure.

Fiat justitia ruat caelum

I certify under penalty of perjury and pursuant to the laws of the state of Iowa that the preceding is true and correct.