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The Florida Bar v. Elizabeth Martinez-Genova
SC04-2365


PLEASE RISE.
>> GOOD MORNING.
GOOD MORNING.
LADIES AND GENTLEMEN, THE
FLORIDA SUPREME COURT.
PLEASE BE SEATED.
>> OKAY.
WE'RE READY ON THE NEXT
CASE, THE THIRD CASE, THE
FLORIDA BAR VERSUS ELIZABETH
MARTINEZ-GENOVA.
>> GOOD MORNING.
MY NAME IS BARNABY MIN AND I
REP SEN THE FLORIDA BAR.
THREE-YEAR SUSPENSION
INSTEAD FOR TWO REASONS:
NUMBER ONE, A FINDING OF IN
TEXTALING MISAPRORTION OF
TRUST FUND.
THERE IS PRESUMPTION.
>> I KNOW USUALLY WE ARE
KNOWLEDGEABLE ABOUT THE
FACS, BUT I WOULD LAKE TO
UNDERSTAND EXACTLY, THE
TRUST FUND VIOLATION WERE
TAKING OTHER CLIENT'S MONEY
OR WAS BECAUSE THE
ALLEGATION IS A PART OF THE
SCAM THAT WAS BEING
PERPETRATED BY OUR CLIENT.
>> IT WAS BOTH, YOUR HONOR.
>> WHAT HAPPENED IS, THIRD-PARTY
RESPONSE WITH OPERATING
COUNTS BUT IT WAS SUPPOSED
TO BE A TRUST.
SHE WAS SUPPOSED TO HOLD AN
TRUST AND APPLY TO FEES
DURING THE ADDITIONAL LEN
AKBRAEMENT.
HOLDING THE FUN AND TRUST,
RESPONDER WOULD IMMEDIATELY
DISPERSE THOSE FUNDS BUT
ALSO TO CLIENT AND ALSO TO
OTHER PARTIES.
THOSE FUNS TO REIMBURSE THEM
SO IT TO BE SELFISH TAKING
THE MONEY AS WELL AS
PARTICIPATING IN THIS SCAM.
>> THE AMOUNT INVOLVED?
WHAT THE BAR ALLEGES WITH A
SCHEME HERE.
HELP US FLUSH OUT, THIS IS
ONE OF THOSE CASES THAT WE
ARE FAMILIAR.
>> JUDGE, THE MAIN THING WAS
HE STATED HIS HIS COMPANY
TRANSFERRED $50,000 TO
RESPOND APT FOR FOLDING
TRUST FOR THE LEN APREMENT.
AS SOON AS THEY RECEIVED THE
$50,000.
IT GOES TO THE BANK TO MAKE
WIRE TRANSFERS TO TWO OTHER
PARTIES THAT HAD THEIR
FUNDS, MADE CASH
WITHDRAWALS, SUBSTANTIAL
CASH WITHDRAWALS AN $8,000
AND THEN RESPONDER WOULD USE
REMAINING FUNDS BY GOING TO
ATM WITHDRAWAL, WALGREEN'S,
ECKERD, TAKING THE MANY
WITHOUT THE PERMISSION OF
THE THIRD PAERD PARTY.
THE THIRD PARTY SIGNED AN
ACTUAL AGREEMENT, RECEIVED
LETTERS SAYING THEY WERE TO
BE HELD, WERE TO BE APPLIED
TO THE FEES, THEY STATED THE
FEES WITHIN A DAY OR TWO
RESPONDED IMMEDIATELY.
>> IS IT CORRECT, THIS BANK
ACCOUNT WAS SET UP BY IN
CONJUNCTION -- NO, YOUR
HONOR.
I BELIEVE THE FACS SHOWED
THE BANK ACCOUNT WAS
ALREADY, IT WAS AN OPERATING
ACCOUNT THAT SHE HAD WELL
BEFORE SHE KNEW HIM.
>> OKAY.
WHAT FUNDS DID IT HAVE IN IT
AT HA POINT?
>> IT IS VERY MINIMAL.
THE EVIDENCE SHOWED THAT HIS
FIRST AUDIT IN OCTOBER OF
2003 SHOWED THERE WAS MAYBE
$18 OR SO AS THE STARTING
BALANCE.
RECEIVED $15,000 IMMEDIATELY
DISBERSED THOSE FUNS TO
RECEIVE ANOTHER $8,000 TO
DISPERSE THOSE FUNDS
RECEIVED ANOTHER $52,000.
>> THE $15,000 OUT OF THIS
KEEP IT -- ACCOUNT, WAS IT
DESIGNATED, WAS IT A
PERSONAL ACCOUNT?
AN ESCROW ACCOUNT?
HOW IS IT DESIGNATED?
>> IT WAS AN OPERATING
ACCOUNT.
>> IT WAS OPERATING?
>> CORRECT.
>> DID SHE HAVE AN OFFICE?
>> AN FIS.
>> PHYSICAL OFFICE?
>> MY UNDER STANDING IS THE
HAD AN OFFICE THAT SHE
WORKED OUT OF, SHE HAD
LETERHEAD, IT SHOWS THE
RESPONDENT SENT LETTERS TO
COME PLAY AIN'T WITH THE
ADDRESS ON IT CONFIRMING THE
AGREEMENT THAT THE
COMPLAINANT HAD.
THE AGREEMENT SPECIFICALLY
STATED THE FUNDS SHOULD BE
HELD IN TRUST.
>> GO AHEAD.
I JUST WANT TO -- BECAUSE TO
ME, WHAT THE BAR IS SAY,
WHAT THIS ESTABLISHES IS
TRUE, THIS IS FAR WORSE THAN
VIOLATIONS WE HAD WHERE
SOMEBODY HAD QUESTION OF
TIMING AM THEY ARE TRYING TO
LEVERAGE.
THESE FUNDS WHICH YOU ARE
SAYING, THEY HAVE NEVER
GOING TO BE HEARD TO HAVE
ANY PART OF THE FEE.
THEY WERE ALL TO BE, THEY
WERE PUT IN OPERATING
ACCOUNT OR ESCROW ACCOUNT OR
TRUST ACCOUNT, THEY WERE
THERE TO BE HELD TO DO
SOMETHING WITH ONCE THE LOAN
WAS APPROVED.
IS THAT THE CONDITION?
>> CORRECT.
>> CORRECT.
>> YES.
THE FEES TO BE HELD IN TRUST
AN ACCREDITED TO THE CLOSING
FEES.
24R WAS ALSO TESTIMONY THAT
IF THE PERSON SEEKING THE
LOAN HAD DEFAULTED THEN IT
COULD BE FORFEITED IF HE HAD
FORFEITED AND NOT OBTAIN THE
FEES, REFUNDED BACK TO THE
COME PLANT ANT OR THE
CLIENT.
>> AS WE LOOK AT THIS CASE,
IT REALLY APPEARS THAT IT IS
CLEAR THAT THE MONEY SHOULD
HAVE BEEN PLACED IN TRUST
AND MANAGED IN A DIFFERENT
WAY.
IT ALMOST APPEARS TO BE
ADMISSION OF REMORSE FOR
WHAT HAS OCCURRED.
IT IS EGREGIOUS.
I THINK REALLY THE ISSUE
THAT WE ARE GOING TO HAVE TO
STRUGGLE WITH TODAY IS GOING
TO BE THE OVERLAY OF DRUG
USE, DRUG CONSUMPTION, THOSE
KIND OF THINGS, IT SEEMS, OR
DO YOU DISAGREE WITH THAT?
THIS IS WHAT IT SEEMS THIS
CASE IS REALLY ABOUT.
DOES THAT MITIGATE WHAT
WOULD NORMALLY HAPPEN IF
WITH HEA NOD DRUGS, THIS
WOULD BE VERYK VERY CLEAR.
I AGREE WITH YOU, YOUR
HONOR.
>> THE QUESTION REALLY
BECOMES:
HOW DO WE USE THAT IN
MITIGATION?
DO WE USE IT IN MITIGATION?
DOES THAT TRANSFORM WHAT MAY
BE SOME KIND OF SUSPENSION?
THAT IS WHAT I THINK WE NEED
TO HONE IN ON PLEASE.
>> ABSOLUTELY THIS COURT HAS
CONSIDERED MITIGATING
FACTORS IN DETERMINING
WHETHER THIS IT HAS BEEN
OVERCOME.
HOW THE MAJORITY OF CASES,
THIS COURT HAS STATED,
RESPONDENT SHOULD BE
DISBARED FROM THE TRUST
FUND.
I TURN YOUR HONOR'S
ATTENTION TO THE CASE.
THAT ATTORNEY MISAPPROPRIATE
TRUST FUND.
THIS COURT FOUND THAT ONE OF
THE MAIN REASONS, THE
UNDERLYING REASONS WAS
BECAUSE OF SUBSTANCE ABUSE
PROBLEM.
AFTER MITIGATING FACTORS IN
ADDITION TO THE SUBSTANTIAL
ABUSE, THE FACT NO PAYBACK
HAD NO PRIOR DISCIPLINE.
NEVERTHELESS, EVEN THOUGH IT
WAS THE MAIN FACTOR IN THE
FRUNS, THIS COURT FINING
THAT RESPONDENT PARTICIPATED
OR MISAPPROPRIATED TRUST
FUNDS OVER A SUBSTANTIALLY
PERIOD OF TIME AND STILL
ABLE TO FUNCTION AS AN
ATTORNEY.
THAT IS WHAT WE HAVE ON THE
PRESS EATEN CASE.
THE ATTORNEY MISS MARTINEZ-
GENOVADIS M APPROPRIATE FUND
OVER SUBSTANTIAL PERIOD OF
TIME AND FOUND THAT TO BE
ONE OF THING A GRATEth VAING
FACTORS THAT RESPONDENT THE
FUND OVER I BELIEVE A YEAR
PERIOD.
TENS OF THOUSANDS OF DOLLARS
OVER AN OVER AGAIN.
ADDITIONALLY, EVEN THOUGH
MISS MARTINEZ GENOVA DID
HAVE A DRUG PROBLEM, SHE WAS
ABLE TO FUNCTION AS AN
ATTORNEY.
THE RESPONDENT WAS ABLE TO
HANDLE A NUMBER OF COMPLEX
CASE, COME IN, TESTIFY
DURING THE FINAL HEARING THE
RESPONDENT WAS A CONFIDENT
ATTORNEY WHO HANDLED
JUDGMENT ISSUES WAS ABLE TO
FIND LITIGATION CASES WHO
WAS ABLE TO PAY HER BILLS
AND RUN A LAW OFFICE AND WAS
ABLE TO BE SUCCESSFUL
ATTORNEY.
>> WE HAVE BEEN SENDING THE
MAYBE A WRONG MESSAGE
THROUGH CASES SUCH AS MASON,
THOSE TYPES OF CASES BECAUSE
BOTH OF THOSE CASES, THERE
WERE TRUST ACCOUNT
VIOLATION, MAYBE NOT TO THE
EX TEP HERE, BUT, I MEAN,
THERE IS CERTAINLY A VIEW
THAT TRUST ACCOUNTS AND
THEFT FROM TRUST ACCOUNTS
CANNOT BE TOLERATED UNDER
ANY CIRCUMSTANCES AND THEN,
THERE MAY BE ANOTHER VIEW
THAT, WELL, MAYBE, MAYBE
CERTAIN THINGS MAY MITIGATE
SOMEWHAT, WHAT IS YOUR VIEW
WITH REGARD TO OUR STATUS OF
OUR LAW IN THIS AREA?
>> THAT IS THE DOCUMENT,
YOUR HONOR.
THIS COURT IMPOSE SANCTIONS.
IT DOES CONCEIVE THOSE CASES
ARE DISTINGUISHABLE ABOUT
FROM THE PRESS ACCEPT CASE.
IT WAS UNINTENTIONAL
VIOLATION, THAT WAS DUE TO
ACCOUNTING ERRORS, NOW, THAT
WAS ISOLATED UNITED STATES
DENT IN WHICH IT SPENT A
CONSIDERABLE A. TIME.
THAT IS NOT WHAT WE HAVE IN
THE CASE.
IN THE CASE, IT IS NOT AN
ACCOUNTING ERROR, IT IS A
SCHEME THAT THE RESPONDENT
ANT TERNED INTO IT.
>> ADDITIONAL IF I REMEMBER
CORRECTLY, THERE HAD BEEN
RESTITUTION.
>> HERE THERE HAS BEEN NO
RESTITUTION.
>> CORRECT.
THEY FOUND THAT TO BE AN
AGGRAVATED FACTOR.
THE RESPONDENT MADE NO
ATTEMPTS.
>> WHAT DOES THE RECORD TELL
US ABOUT WHAT HAPPENED TO
HIM IN TERMS OF ANY CRIMINAL
PROSECUTION OR OTHER -- DOES
THE RECORD TELL US ANYTHING?
>> THE RECORD IS SEE YOU
LEN.
WHAT DOES THE RECORD TELL US
IN TERMS OF HIS INVOLVEMENT
AND MANIPULATION OF THIS
SITUATION?
>> YOUR HONOR, THE
RESPONDENT ARGUED TO SHE WAS
SCAMMED JUST LUKE THE OTHER
THIRD PARTIES.
TESTIMONY IN THE CASE IS NOT
CREDIBLE.
RESPONDENT KNEW WHAT SHE WAS
DOING, WILLFULLY IGNORED BY
ACCEPTING THE THIRD PARTY
FUNDS WHICH WERE SUPPOSED TO
BE HELD AND RATHER THAN HOLD
THUS, DISPERSE THOSE FUNDS
AND DIN FACT ENGAGEG WITH
THE QLIP.
>> DID SHE SAY THAT IN HER
DEFENCE, I MEAN, SHE WAS
REFORCEFUL, DID SHE
ACKNOWLEDGE THAT THOSE FUNS
WERE NEVER HEARD TO ACCEPT,
IN OTHER WORDS, GAIN, IT IS
AN ISSUE, WELL, YOU TOOK
TRUST FUNDS.
IT IS A QUESTION OF THE
TIMING OF IT.
IS IT HER POSITION THAT
THESE WERE FEES THAT WERE
DUE FOR THE TRANSACTION IN
QUESTIONS?
>> THEY ARGUED DURING THE
FINAL HEARING WAS.
THE FEES BELONG TO THE
CLIENT.
THERE IS EVIDENCE IN THE
RECORD NUMBER 1 AND NUMBER
3.
THEY WROTE LETTERS TO THE
THIRD PARTY STANDING THE
FUNDS WERE GOING TO BE HELD
IN TRUST SO RESPONDENT BY
SIGNING THE LETTER STATING
THAT THE FUNDS WILL BE HELD
IN TRUST PURSUE NT SA TO THE
LOAN AGREEMENT KNEW THOSE
WERE SUPPOSED SPO BE HELD IN
TRUST AN IGNORED
RESPONSIBILITY BY THE FUND.
>> ADMITTED TO THE BAR IN
2,000.
AS SOLO PRACTITIONER,
ANYTHING IN THE RECORD AS TO
HER AGE, WAS THIS A SECOND
CAN I REAR?
CAREER?
WHAT THE CIRCUMSTANCES WERE?
I KNOW SHE HAD A SUN THAT --
SON THAT SHE LOST AS A
RESULT -- NOT LOST IN TERMS
OF DIED, BUT LOST CUSTODY OF
AS A RESULT OF THE DRUG HAN
ABOUT IT.
>> THE RESPOND ENT DID
TESTIFY CONCERNING HER PAST.
SHE WENT TO LAW SCHOOL.
SHE WORK AS LEGAL SECRETARY.
SHE WORKED AS PARALEGAL FOR
VARIOUS FIRMS AN TEMPORARY
AGENCY, SHE DID HAVE A
PROBLEM PASSING THE BAR EXAM
THE FIRST TIME DUE TO A
NUMBER OF PROBLEMS BUT
DELAYED HER BEING ADMITTED
UP UNTIL 2,000 WHEN SHE
GRADUATED FROM LAW SCHOOL
PRIOR TO THIS.
SHE GRADUATED FROM LAW
SCHOOL, SHE WORKED FOR
HERSELF, SHE WORKED WITH HER
HUSBAND.
SHE WORKED FOR --
>> DID SHE HAVE A DRUG HABIT
BEFORE SHE WENT TO LAW
SCHOOL?
WAS THERE TESTIMONY ABOUT
LONG-TERM DRUGS ADDICTION?
>> YES, YOUR HONOR.
I BELIEVE THE TESTIMONY
SHOWS THE RESPONDENT STARTED
USING DRUGS AT THE AGE OF 18
THE TESTIMONY ALSO SHOWS DUE
THE CHARACTER WITNESSES THAT
SHE HAD SIG CAN DRUG
ADDICTION FOR THE PAST TEN
YEARS.
>> THE REASON I AM ASKING
THESE QUESTIONS, PRANKLY,
THAT WE ARE ALWAYS
STRUGGLING WITH THESE ISSUES
OF HAVING TO PREVENT
SOMETHING LIKE THIS FROM
HAPPENING TO BEGIN WITH.
DOES SHE KNOW SHE WAS
ADMITTED TO THE BAR?
SHE WAS NOT.
RESPEND ENT TO THE ACTUAL
HEARING WITH THE EXAMINERS
WHERE SHE PRESENTED EVIDENCE
TO THE EXAMINER SHE WAS FIT
TO BECOME AL LAWYER AND SHE
WAS ADMITTED.
>> THE EXAM KNEW SHE HAD
THIS DRUG PAST DRUG USE?
>> NO.
RESPONDENT MISREPRESENTED
UNTHINK APPLICATION SHE HAD
A PRIOR DRUG PROBLEM.
RESPEND ENT SAID SHE DID NOT
THINK SHE HAD A PROBLEM
WHICH IS WHY SHE LIE ON THE
BAR APPLI CAUTION, THE FACT
OF THE MATTER IS, SHE WAS
ABDUCTED TO DRUGS ON THE BAR
APPLICATION, SHE STATED, I
AM NOTED A DICKED TO DRUG, I
DON'T HAVE A DRUG PROBLEM.
>> YOU ARE MOVING INTO
REBUTTAL.
YOU CAN PROCEED IF YOU WANT.
YOU ARE DOWN INTO THE
REBUTTAL TIME.
>> YOUR HONOR, BECAUSE SHE
HAS BEEN FOUND OF
MISAPPROPRIATING TRUST TUND
AND FOUND GUILTY OF
COMMITTING CRIMINAL OFFENSE,
THE PUNITIVE IS THE
APPROPRIATE PENALTY AND ANY
MITIGATING FACTORS DO NOT
OVERCOME THAT PRESUMPTIVE
PUNITIVE TIMOR THE
AGGRAVATING FACTORS THAT
HAVE BEEN FOUND.
THANK YOU.
>> THANK YOU.
>> MISS WEAR.
>> THANK YOU.
MAY IT PLEASE THE COURT,
MANSY WEAR.
I AM APPEARING PRO BONO,
YOUR HONOR.
FIRST OF ALL, I WANT TO SAY,
AN I HAD NOTIFIED THE BAR AS
WELL.
MISS GEN NOVEMBER VAE GENOVA
CONTINUES TO PARTICIPATE IN
THE PROGRAM FULLY ATTENDS 6
MIGHTING AS WEEK, 3 AA,
THREE NA, SHE HAD VISITATION
TO HER SON RESTORED TO HER.
SHE HAS HIM OVERNIGHT, OVER
OTHER WEEKEND.
SHE WOIS WORKING AS VOL LUP
TIER, AND SHE IS WORKING FOR
A LAW FIRM IN A PARALEGAL
CAPACITY.
I ALSO WANTED TO NOTE THAT
AFTER THE BAR FILED AN
AMENED AFFIDAVIT ASKING FOR
AN ADDITIONAL $3,000 BEYOND
WHAT HAS BEEN ORDERED BY THE
REFEREE AS I READ THE RULE
AND THERE SEEMS TO BE NO
CASES, 7.6, THAT ADDITIONAL
AMOUNT WOULD BE --
>> WELL, COSTS ARE SORT OF
THE LEAST OF YOUR CLIENT'S
PROBLEMS HERE.
I UNDERSTAND.
VIEW A VERY LIMITED AMOUNT
OF TIME AND IT SEEMS TO ME
THAT YOU COULD USE YOUR TIME
TRYING TO DEMONSTRATE TO
THIS COURT WHY WE SHOULD NOT
DISBAR YOUR CLIENT ON THE
FACE OF THESE SERIOUS
CHARGES?
>> FIRST OF A UL, YOUR
HONOR, AND I APPRECIATE THE
OPPORTUNITY TO EVEN HAVE AN
OPPORTUNITY TO COME HERE AN
ADDRESS YOU.
THE REFEREE HEARD ALL OF THE
WITNESSES AND SAW ALL OF THE
EVIDENCE AND THOUGHT ABOUT
THIS VERY CAREFULLY AND SHE
FOUND OF COURSE THE
AGGRAVATEORS THAT SHE DID
FIND.
SHE FOUND 9 MIT GITORS.
IT APPEARS PROBABLY THAT
MR. GENOVA WAS SO DEEPLY
INTO DEPRESSION AND DRUGS
THAT WHEN HE MET HER, HE
RECOGNIZED HER AS POTENTIAL
LOSS FOR HIS TEAM.
I UNDERSTAND THE BAR IS THAT
SHE SHOULD HAVE BEEN SOME
KIND OF CRIMINAL BACKGROUND
CHECK.
>> HOW ABOUT THE REFEREE?
DID THE REFEREE FIND YOUR
CLIENT WAS JUST ANOTHER
VICTIM?
>> I THINK THAT THE -- I
THINK THAT THE MITIGATEORS
ALSO THE DISCUSSION THE
REFEREE'S REPORT INDICATES
SHE WAS AWARE OF THAT.
I THINK SHE -- I THINK THAT
SHE MADE THE FACT SHE DID.
WE UNDERSTAND THAT THERE IS
A REVERSAL ON THOSE.
>> HERE, LET ME STATE MY
CONCERN.
THIS HAPPENED IN 2004 AND
THIS WAS NOT AN
UNINTENTIONAL ACT ON THE
PART OF YOUR CLIENT, IN FACT,
THE EXHIBIT IN THE RECORD
DEMONSTRATES ON FEBRUARY
19th, 2004, SHE SIGNED A
LETTER THAT WAS SENT TO
MR. HIM PLEASE BE ADVISED
THE RECEIPT IN THE AMOUNT OF
$52,000, GROURNDS WILL BE
APPLIED TO A PAYMENT TO A
LOAN COMMITMENT FEE.
THE BANK RECORDS INDICATE
THAT ON FEBRUARY 23rd, 4
DAYS LATER, SHE WITHDRAW $8,000.
>> GAVE IT TO HIM.
>> OF THAT MONEY THAT WAS
PAYABLE TO HER, TO ELIZABETH
GENOVA.
AND SO THE PROBLEM THAT WE
HAVE HERE IS THAT WITH
LAWYERS REP ACCEPT TRUST
REPRESENT TRUST TO THE
PUBLIC THAT WE HAVE A
RESPONSIBILITY, ALL THE
LAWYERS IN THIS STATE HAVE A
RESPONSIBILITY TO SAY THAT
IF YOU DO THAT KIND OF ACT,
YOU CAN'T BE A LAWYER
ANYMORE.
>> YOUR CONCERNS, OF COURSE,
ARE ALL OUR CONCERNS.
THE RECORD SHOWS THAT SHE,
SHE REPEATEDLY TOLD MICHAEL,
SHE DID NOT HAVE A TRUST
ACCOUNT.
SHE WAS NOT HOLDING FUNDS IN
TRUST.
SHE REPEATEDLY ASKED FOR
REASSURENESS AS WHICH SHE
GOT FROM THEM?
SHE DIDN'T HAVE
RESPONSIBILITY TO HIM.
SHE HAD RESPONSIBILITY TO
TELL THIS PERSON SHE REP
ACCEPTED TO THE FACT TO GET
THE $52,000 SENT TO HER.
>> OKAY.
THE COURT IS CLEAR, THAT --
THE COURT IS CLEAR ON THAT.
YOUR POSITION IS THAT AS A
THIRD PARTY, SHE HAD THAT
RESPONSIBILITY --
>> WHEN SHE REPRESENTED TO
HIM --
>> RIGHT.
>> THAT IS WHAT THAT MONEY
WAS GOING TO BE USED FOR.
THERE CAN'T BE ANY QUESTION.
THAT IS WHAT IT HAD TO BE
USED FOR.
BUT ON THE MATTER OF THE
REFEREE, YOU KNOW, WE HAVE
AN ABUNDANCE OF CASE LAWS.
WE HAVE A LOOP WHICH SAYS
THAT TAKE MONEY OUT OF TRUST
WHETHER IT BE DETONATED A
TRUST ACCOUNT, AN OPERATING
ACCOUNT OR ANY KIND OF AN
ACCOUNT, IF THE LAWYER TAKES
IT OUT THE PRESUMED
DISCIPLINE IS DISBARMENT.
THE REFEREE DIDN'T DEAL WITH
THAT.
DIDN'T SHOW HOW IT WAS THIS
PRESUMPTION.
>> I THINK SHE FOLLOWED THE
RELATIVELY RECENT CASE OF
BEHRMAN WHICH IS LIKE THIS
CASE SIMILAR A SCHEME,
SIMILARLY SOMEBODY WAS TAKEN
I BY A PERSON WHO WAS CLOSER
TO HIM AND THE PEOPLE WHO
WERE, WHO WERE DISAN
ADVANTAGEED WITH THIRD
PARTY, ALL OF THAT IS THE
SAME.
AT, WITH MUCH MORE MONEY.
>> WELL MR. BEHRMAN, I
UNDERSTAND YOUR POSITION ON
THAT, MR. BEHRMAN WAS 7
YEARS OLD, IT WAS AN
ISOLATED INCIDENT INVOLVING
MR. BEHRMAN.
IT WAS NOT -- THE FACTS OF
MR. BEHRMAN'S SITUATION WERE
DIFFERENT.
SINCE HIM, WE HAVE HAD
SERIES OF CASES WHICH WE
HAVE MADE IT VERY CLEAR THAT
TALKING FROM A TRUST ACCOUNT
IS PRESUMED TO BE A
DISBARMENT.
>> THAT IS CORRECT, YOUR
HONOR.
>> THEN THERE IS ALSO MASON
WHO IS ADVERTISING,
PETITIONING FOR REIN STAMENT.
SHE PURPOSELY WROTE MACHINE
MANY CHECKS TO HERSELF AN
USED THEM TO PAY BILLS.
SHE WAS INVOLVED IN THE
REMOVAL OF QUITE A LOT OF
MONEY SHE WAS SUSPENDED FOR
TWO YEARS.
THE MORE RECENT CASE WHICH I
SUPPLEMENTED WITH WHERE WE
DIDN'T EVEN, WE DIN EVEN
HOPE FOR A REDUCTION IN THE
AMOUNT OF SUSPENSION, BUT
HIS WAS REDUCED FROM 3 YEARS
TO A 2-YEAR SUSPENSION.
THE FACT IN THAT CASE
APPEARS, AT LEAST THE READER,
I HAVEN'T SOON THE BRIEF, IT
SEEMS TO ME FAR MORE
EGREEMINGOUS AS THESE ARE.
AS WELL, YOU KNOW, --
>> DIDN'T WE SAY IN THAT
CASE THAT THAT WAS NEGLIGENT
CONDUCT AS OPPOSED TO
INTENTIONAL CONDUCT?
THAT IS TRUE, CORRECT?
YES.
ABSOLUTELY.
THE COURT DID SAY THAT.
>> HOW CAN YOU EVEN COMPARE
THAT TO THE FACT THAT --
WHAT DID YOUR CLIENT THINK
SHE WAS DOING?
WHEN SHE WAS TAKING MONEY
FROM ONE PERSON AND THEN
DOLLING IT OUT TO HERSELF
AND OTHERS?
>> SHE WAS ASSUREDED RIGHTLY
OR WRONGLY, SHE WAS ASSURED,
SHE BELIEVED THAT, THAT HIS
ASSURANCES THAT THIS WAS,
THIS WAS THE APPROPRIATE
THING TO DO.
THIS WOMAN DIDN'T EVEN HAVE
A CHECKING ACCOUNT?
THAT IS WHY SHE WE TO THE
BANK AND TOOK OUT THE CASH.
SHE HAD NOTHING TO WRITE
CHECKS ON.
>> THESE TRANSFERS WERE MADE
TO AN AN ACCOUNT?
>> EXACTLY.
THEY HAD TO EITHER GET A
BANK CHECK OR GET OUT THE
CASH.
THERE IS, BY THE WAY, NO
DISPUTE THAT WAS A 3% WHICH
IS $1800 OUT OF THE THANK
TRANCE ACTION.
SHE WAS NOT --
>> BUT IF YOUR CLAYIENT GETS
A LETTER OR SOME INDICATION
THAT THE PERSON WHO SENDS
THE MONEY BELIEVES THAT IT
IS GOING TO BE HELD IN TRUST
UNTIL SUCH TIME AS THE LOAN
IS EITHER GIVEN OR NOT GIVEN
AND THEN ON THE SAME DAY GO
TO THE BANK AND GIVES MONEY
TO A THIRD PARTY, HOW IN THE
WORLD CAN THAT NOT BE
INTENTIONALLY CONDUCT?
UNDERSTANDING THAT SHE WAS
SUPPOSED TO BE HOLDING THE
MONEY FOR A SPECIFIC
PURPOSE.
>> BECAUSE SHE NEVER SAW THE
CONTRACT.
SHE ONLY KNEW WHAT HE WAS
TELLING HER AND AS, SHE WAS
DEEPLY MOO THESE OTHER
THINGS.
I MEAN, OBVIOUSLY, IF ANY OF
US WOULD HAVE KNOWN, LISTEN,
CLOSE.
>> HOW DID SHE -- SHE
MAINTAINED A PUBLIC OFFICE?
>> AIM MOT SURE SHE HAD A
PHYSICAL OFFICE.
SHE HAD A DESK SOMEWHERE.
I DON'T KNOW WHAT THE
ARRANGEMENT WAS.
>> WHAT WAS HER HUSBAND
FEDERALLY PROSECUTED FOR AT
THE TIME HE WAS ARRESTED ON
DUI?
>> HE WAS BANKRUPTCY COURT.
HE WENT TO PRISON FOR THAT.
HE IS OUT OF PRISON.
HE HAS DONE WHAT HE NEEDED
TO DO TO MAKE RESTITUTION AN
SO FORTH.
THEY WERE NOT WORKING
TOGETHER.
DRUG RELATED AT ALL HIS
ACTIVITIES?
>> OH, YES, OH, YES.
HE, YES.
>> SO SHY AN HUSBAND WERE
DEEPLY INVOLVED IN DRUGS?
>> ON THE USE OF THEM NOT
THE SALE OF THEM.
BY THE WAY, ALLEGATIONS SHE
WAS USING THIS MONEY TO BUY
DRUGS, NO, PEOPLE WOULD GIVE
THEM TO HER AND THEY WOULD
SHARE THEM, YOU KNOW?
IT IS AWFUL.
IT IS AWFUL IN HUMAN TERMS
NOT AWFUL IN THE TERMS OF
PEOPLE SITTING DOWN AND
TRYING TO STEAL FROM PEOPLE.
>> I GUESS MY CONCERN IS, WE
ARE NOT TALKING ABOUT A 22,
23, 25-YEAR-OLD.
HE WITH TALKING ABOUT A
41-YEAR-OLD LAWDIE WHO HAS
HAD A LONG HISTORY OF
SUBSTANCE ABUSE.
WE HAVE RESPONSIBILITY TO
PROTECT THE PUBLIC AND HOW
CAN WE BE ASSURED THAT CAN
BE DONE IN A CASE LIKE THIS?
>> ONE OF THE THINGS THAT I
THOUGHT ABOUT WHEN I BRIEFED
THIS CASE WAS:
THE RECORD WITH RESPECT TO
DRUG AND ALCOHOL ABUSE IS
WHAT IT IS.
IT IS CONSIDERED BY THE
REFEREE, BUT IT IS FROM.
I AM PUZZLED BY HOW SHE
PASSED, SHE PASSED THROUGH
THE BAR EXAM IN THE
SPREEINGDS TO BE ADMITTED TO
THE BAR, I DIDN'T KNOW HER
THEN.
I DIDN'T THE.
IT WAS LONGSTANDING ENOUGH
SO IT SHOULD HAVE RAISED
SOME CONCERN.
I DON'T BELIEVE FOR A MOMENT
SHE MISREP ACCEPTED HERSELF
ON THE APPLICATION.
I DON'T THINK SHE WAS AWARE
OF IT.
I THINK IT WAS BY DEPRESSION
WHICH WAS VERY REAL AND --
>> DO WE HAVE THAT KIND OF
INFORMATION IN THE RECORD?
>> WITH RESPECT TO WHAT SHE
USED THE MANY FOR?
>> NO, WITH HER RESPECT TO
BEINGING DEPRESSED THAT
MASKED HER, I MEAN, IS THIS
YOUR TAKE ON THIS OR IS THAT
EVIDENCE IN THE RECORD?
>> IT WAS IN THE RECORD.
SHE HAD BEEN IN 1992.
THEY HAVE THE YEAR WRONG.
IT US IN THE RECORD.
I AM THINKING THAT IT MAY BE
THAT IT MASKED, THAT IT
MASKED SOME OF THAT, AS
WELL, SHE WAS LIVING WITH
HER HUSBAND WHO WAS HIMSELF
USING AND LIVING A VERY FAST
LIFESTYLE AT THE TIME.
YOU ARE GIVING A VERY
SYMPATHETIC VIEW, YOU ARE
DOING THIS PRO BONO.
I AM THE ONE WHO THINKS
PEOPLE SHOULD GET SECOND OR
THIRD CHANCES ESPECIALLY
WITH DRUG ADDICTIONS, NOT OM
DO I HAVE NO SIM PAT THINK.
MY CONCERN IS THAT WE F WE
DON'T DISBAR THIS INDIVIDUAL,
WE ARE SENDING OUT A SIGNAL
THAT SOMEHOW THIS IS GOING
TO BE TOLERATED AND I DON'T
AGREE.
MASON FIRST OF ALLS WITH A
CLOSE VOTE BUT THE FINDING
WAS THAT THERE WERE
ACCOUNTING ERRORS.
THIS PERSON, YOUR QLIN, NOT
ONLY DID THIS AND WAS
SUPPORTING A DRUG HABIT, BUT
IN HER DEFENSE, APPARENTLY,
SHE SAID, WELL, SHE WAS ABLE
TO DO ALL OF THE THINGS, SHE
HANDLED A MATER THAT
REQUIRED HER, THIS IS NOT
LIKE SOMEBODY, SOME BAG LADY
THAT WAS GOING FROM DAY TO
DAY.
>> JUDGE, I LOOKED THAT
CASE.
TO THEENTIAL DENL I COULD
FINE OUT WHAT WENT ON IN THE
UNDERLYING CASE, I WAS NOT
AT THE TRIAL.
I WOULD HAVE, YOU KNOW, SHE
DID A COUPLE OF NICE THINGS,
PEOPLE CAME IN AND SAID SOME
NICE THINGS ABOUT HER.
I WOULD NOT INTERPRET THAT
HAS BEING ABLE TO HANDLE ANY
KIND OF CONFLICT MATTER.
>> IS IT TRUE SHE WAS DURING
2002-2004 ARRESTED THREE
TIMES, TWICE FOR POSSESSION
OF COCAINE, ONE FOR SALE?
YES, JUDGE.
>> ONE WAS DISMISSED.
THE OTHER TWO HAVE BEEN NO
ACTION.
SHE SUCCESSFULLY COMPLETED
THE DRUG.
YOUR HONOR, YOU ARE CORE REB
ABOUT THAT.
SHE GOT ANOTHER CHANCE IN
THE CRIMINAL JUSTICE SYSTEM?
YES, YOUR HONOR.
>> ANY OTHER CHANCE OTHER
THAN TO HAVE TO BE DISBARRED
IN THE CASE?
WELL, WITH THE ONE THING,
YOUR HONOR, THE COURT EVEN
THOUGH I UNDERSTAND YOUR
REVIEW IS WIDER ON THE
DISCIPLINARY PART, THE
REFEREE'S RECOMMENDATION
AFTER FOUR DAYS OF TRIAL
WOULD BE GIVEN, WOULD BE
GIVEN SUBSTANTIAL DIFFERENCE
TO YOU.
THIS WASS ONLY A WELL
THOUGHT-OUT REFEREE'S REPORT
GIVEN CAREFUL CONSIDERATION
AND CERTAINLY NOT
DISREGARDING THE IMPORTANCE
OF PROTEBING THE PUBLIC
WHICH IS PART OF THE COURT
APPOINT.
THE OTHER THING I THINK IS
THAT THIS, THAT WITH A 3
YEAR PROBATION ORDERED
FOLLOWED BY A 3-YEAR
SUSPENSION POLOED BY
PROBATION, WE DON'T KNOW
WHETHER OR NOT SHE WOULD FIT
THE CRITERIA TO BE, TO BE
ALLOWED TO PRACTICE ONCE
AGAIN, BUT THAT PROCESS IS
RIGOROUS ENOUGH, IT IS
IMPOSSIBLE TO CONCEIVE THAT
SHE WOULD BE ADMITTED BACK
TO PRACTICE UNLESS EVERYONE
WHO NEEDED TO BE CONVINCED
AND THERE WERE A LOT OF
FOLKS, PERFECTLY CONVINCED
THAT NOT ONLY WAS SHE
CAPABLE AP SO FORTH AND SO
ON, SHE ABSOLUTELY WAS
FULLY, FULLY REHABILITATED.
I THINK DISBARING HER, SHE
IS A RELATIVELY YOUNG WOMAN,
DISBARING HER ALTOGETHER
TELLING HER YOU WILL NEVER
BE ABLE TO BE READMITTED
AGAIN, I THINK, ON THE
CIRCUMSTANCE, WHEN SHE
ABSOLUTELY WAS A VICTIM OF A
STILL PRACTICE AND SKILLED
CONMAN WHO PLUCKED HER AS A
LAWYER KNOWING OF THE DRUG
AND ALCOHOL INVOLVEMENT, SO
HE WAS AWARE OF THAT.
YOU KNOW?
WOULD I HAVE DEALT WITH IT
IN THE SAME WAY?
WOULD I HAVE PRESENED THE
EVIDENCE IN A DIFFERENT WAY?
>> POSSIBLY, BUT I THINK
THAT, I THINK THE REFEREE
UNQUESTIONABLY HAD ALL OF
THE CONCERN, ALL OF THE
POLICY CONCERNS WHICH MUST
CONCERN YOU FULLY, FULLY IN
LINE, AND I THINK THAT SHE
WAS VERY CAREFUL IN MAKING
THE, THOSE REPRESENTATION
AND SINCE THEY WERE WELL
REASON THE COURT'S JURIES
PRU DISWITHIN THE RULES FOR
THE DISCIPLINE, WE WOULD
HAVE THAT YOU AFFIRM THOSE
RULINGS IN EVERY RESPECT.
>> THANK YOU VERY MUCH.
>> YOU HAVE EXHAUSTED YOUR
TIME.
>> THANK YOU.
>> REBUTTAL.
MR. MIN.
>> THANK YOU VERY BRIEF
REBUTTAL.
THE THREE CASES OF THE
RESPONDENT ARGUED TO YOU
HONOR.
AS YOUR HONORS POINTED OUT
QUITE DISTINGUISHABLE.
IN THOSE CASES, THEY DEALT
WITH ATTORNEYS WHO
NEGLIGENTLY MISAPPROPRIATED
FUNDS IN THE CASE, THERE WAS
INTENTIONAL MISAPPROPRIATION
OF TRUST FUN.
>> WHILE YOU ARE ON THAT
SPECIFIC THING, REALIZING
YOUR LIMITED AMOUNT OF TIME.
HAS THE BAR TABULATED THE
EXACT A. FUNDS THAT WERE
MISAPPROPRIATED AND ACTUALLY
IN EFFECT STOLEN FROM THIS
CLIENT?
JUDGE, I BELIEVE THOSE FACTS
WERE ACTUALLY STIPULATED TO.
SPECIFICALLY ON PAGE 4 OF
THE REPORT, THE RESPONDENT
RECEIVED $15,000 FROM ONE
CLIENT, ONE-THIRD PARTY,
HOWEVER, THE MUCH SHE DID
REIMBURSE THAT PARTY.
RECEIVED $60,000, THOSE FUNS
HAVE BEEN TOTALLY
MISAPPROPRIATED.
HE AGREED TO REFUND THOSE
FUNDS $45,000 OF THOSE FUNDS
TO THE CLIENT TO THE THIRD
PARTY.
>> WITH DO WE KNOW WHETHER
HE GOT THESE FUNDS OR
WHETHER THE RESPOND ENT GOT
THINK FUNDS OR DO WE KNOW
THAT?
>> YES, SIR.
IT IS ON PAGE 4 AND 5.
THE REPORT OF THE $8,000 THE
RESPONDENT HE NRBLY RECEIVED
$7,700 OF THAT WAS CASH
WITHDRAWALS, THE OTHER
REMAINING AMOUNT WAS BY THE
RESPOND ENT.
THE REMAINING $52,000
RECEIVED BY THE THIRD
PARTIES, HE WAS REIMBURSED
WITH $15,000.
HE RECEIVED $13,000 IN CASH
WITHDRAWALS.
IS THERE SORT OF A BOTTOM
LINE.
THIS A. MONEY, SHE M APROED
FOR HER OWN PERSONAL USE.
THIS MANY PEOPLE SHE TOOK IT
FROM?
>> UNFORTUNATELY UNCLEAR AS
FAR AS WHAT THE BOTTOM LINE
IS.
THE RESPONDENT UNCLEAR AS
FAR AS YOU HOW MUCH MONEY
SHE WITHDRAW.
THERE WERE NO RECEIPTS,
THERE IS NOTHING OF NA
NATURE.
>> MR. MIN, YOU HAVE
UTILIZED OUR TIME.
MISS WEAR, DIFFICULT
CIRCUMSTANCES THAT WERE
CREATED, BUT YOUR EFFORTS
AND PRO BONO WAY ARE
APPRECIATED BY THE COURT
BECAUSE ALL, ALL WHO HAVE
INTERESTS HERE NEED TO BE
REP SEND AND WE THANK YOU
FOR DOING THAT ON PRO BONO
BASIS.
MR. MIN, THANK YOU AS WELL.
>>