I. INTRODUCTION

This supplemental submission provides additional documentation and analysis of attorney Bryan Tipp's professional misconduct in his representation of Elvis Nuno from 2018-2022. The evidence presented herein demonstrates multiple violations of the Montana Rules of Professional Conduct (MRPC), resulting in substantial prejudice to Mr. Nuno's constitutional rights and civil remedies.

II. OVERVIEW OF ADDITIONAL VIOLATIONS

Mr. Tipp's representation was characterized by:

• Gross negligence in failing to identify critical conflicts of interest
• Complete failure to file any substantive motions
• Inadequate investigation of readily discoverable Brady material
• Failure to protect client's constitutional rights
• Ineffective assistance resulting in loss of civil claims

III. DETAILED ANALYSIS OF PROFESSIONAL MISCONDUCT

A. Violation of MRPC Rule 1.1 - Competence

1. Failure to Investigate Detective Brueckner's Conflict of Interest

The most egregious failure in Mr. Tipp's representation was his complete failure to discover that Detective Brueckner, who was reassigned to Mr. Nuno's case after Officer Ethan Smith's removal, served on the Board of Directors of the YWCA of Missoula. This failure demonstrates:

• Lack of Basic Due Diligence: A simple public records search would have revealed Detective Brueckner's board position
• Failure to Understand Case Context: The entire prosecution centered on Mr. Nuno's criticism of the YWCA
• Ignoring Red Flags: Officer Smith was removed for "obvious appearance of impropriety" due to his relationship with E'Lise Chard, yet Mr. Tipp failed to investigate why the case was reassigned to Brueckner

2. Failure to Recognize Constitutional Violations

Mr. Tipp failed to identify or address clear violations of Mr. Nuno's 14th Amendment rights:

• Conscience-Shocking Behavior under County of Sacramento v. Lewis, 523 U.S. 833 (1998):
  • Institutional conspiracy between multiple agencies
  • Detective with fiduciary duties investigating her own organization
  • Deliberate targeting of Mr. Nuno's livelihood
  • Retaliatory prosecution for protected speech