The bar cites witness testimony, phone records and a recording of Morrissey himself, in which he instructed Myrna “what the story should be, talked to her about who she could get to help corroborate the story and told her how to get other individuals to agree with the theory.”

And it details what it describes as Morrissey’s evolving alibis for the night he was accused of having sex with the receptionist, first telling his defense attorney that he had sex with another woman in his office that night, then claiming he was never in his office and instead was at a meeting in Charles City County and later met with a minister and delivered backpacks for children.

The bar also rebuts Morrissey’s hacker defense, alleging that the Verizon phone records clearly indicate graphic text messages were sent directly by Morrissey.

Bar investigators allege that even the forensic expert hired by Morrissey reported that Morrissey appeared to have deleted text messages “having potential evidentiary value from his phone” and that lewd text messages uncovered by investigators most plausibly originated from Morrissey.

Morrissey could not be reached for comment Tuesday, but the bar complaint notes he has retained a lawyer and is acting as his own co-counsel.