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STATE BAR OF CALIFORNIA
OFFICE OF THE CHIEF TRIAL COUNSEL
JAYNE KIM, No. 174614
CHIEF TRIAL COUNSEL
JOSEPH R. CARLUCCI, No. 172309
DEPUTY CHIEF TRIAL COUNSEL
ALAN B. GORDON, No. 125642
ASSISTANT CHIEF TRIAL COUNSEL
ROSS E. VISELMAN, No. 204979
DEPUTY TRIAL COUNSEL
1149 South Hill Street
Los Angeles, California [protected]
Telephone: [protected]
FILED
DEC
STATE BAR COURT
CLERK’S OFFICER
LOS ANGELES
STATE BAR COURT
HEARING DEPARTMENT - LOS ANGELES
In the Matter of:
GRETA SEDEAL CURTIS,
No. 175248,
A Member of the State Bar.
Case No. 10-O-07369, 12-O-12879,
12-O-13731
NOTICE OF DISCIPLINARY CHARGES
NOTICE - FAILURE TO RESPOND!
IF YOU FAIL TO FILE A WRITTEN ANSWER TO THIS NOTICE
WITHIN 20 DAYS AFTER SERVICE, OR IF YOU FAIL TO APPEAR AT
THE STATE BAR COURT TRIAL:
(1) YOUR DEFAULT WILL BE ENTERED;
(2) YOUR STATUS WILL BE CHANGED TO INACTIVE AND YOU
WILL NOT BE PERMITTED TO PRACTICE LAW;
(3) YOU WILL NOT BE PERMITTED TO PARTICIPATE FURTHER IN
THESE PROCEEDINGS UNLESS YOU MAKE A TIMELY MOTION
AND THE DEFAULT IS SET ASIDE, AND;
(4) YOU SHALL BE SUBJECT TO ADDITIONAL DISCIPLINE.
SPECIFICALLY, IF YOU FAIL TO TIMELY MOVE TO SET ASIDE
OR VACATE YOUR DEFAULT, THIS COURT WILL ENTER AN
ORDER RECOMMENDING YOUR DISBARMENT WITHOUT
FURTHER HEARING OR PROCEEDING. SEE RULE 5.80 ET SEQ.,
RULES OF PROCEDURE OF THE STATE BAR OF CALIFORNIA.
The State Bar of California alleges:
JURISDICTION
1. Greta Sedeal Curtis ("Respondent") was admitted to the practice of law in the State ot
California on December 30, 1994, was a member at all times pertinent to these charges, and is
currently a member of the State Bar of California.
COUNT ONE
Case No. 10-O-07369
Business and Professions Code, section 6068(a)
[Failure to Support Laws of the United States]
2. Respondent willfully violated Business and Professions Code, section 6068(a), by
failing to support the Constitution and laws of the United States and of this state, as follows:
3. In or about April 2007, Mt. Zion Missionary Baptist Church, a California nonprofit
corporation ("Mt. Zion") hired Respondent to prepare and file a bankruptcy petition.
4. On or about May 24, 2007, Respondent prepared and filed a Chapter 11 bankruptcy
petition on behalf of Mt. Zion (the "Bankruptcy Petition") in the United States Bankruptcy Court
for the Central District of California, case number 6:07-bk-12883-PC (the "Bankruptcy Matter").
5. In the Bankruptcy Petition, Mt. Zion was identified as the owner of property, as
reflected on a recorded grant deed, located at 1895 Del Rosa Avenue, San Bernardino, California
(the "Del Rosa Property"). The Del Rosa Property was part ofMt. Zion’s estate in the
Bankruptcy Matter.
6. As a result of the Bankruptcy Petition, an automatic stay went into effect, pursuant to
the applicable bankruptcy rules, including 11 U.S.C. §362.
7. On or about August 1, 2008, Respondent filed a petition in San Bemardino County
Superior Court, case no. CIVSS 810403 (the "Superior Court Petition") on behalf of a nonbankrupt
entity, Mount Zion Missionary Baptist Church, an unincorporated association
("MZMBC-UA"), to change the identity of the owner of the Del Rosa Property from Mt. Zion to
MZMBC-UA.
8. On or about August 27, 2008, asa result of the Superior Court Petition, Respondent
obtained a court decree that changed the recorded grant deed to reflect that MZMBC-UA, and
not Mt. Zion, owned the Del Rosa Property (the "Decree").
9. As a result of the Decree, the Del Rosa Property was removed from Mt. Zion’s estate
10. By filing the Superior Court Petition, Respondent violated the automatic stay.
11. At no time, did Respondent apply for relief from the automatic stay from the
bankruptcy court in the Bankruptcy Matter (the "Bankruptcy Court") prior to proceeding with
the Superior Court Petition.
12. At no time during the pendency of the Superior Court Petition did Respondent inform
the judge that issued the Decree that the Bankruptcy Matter was pending. Similarly, Respondent
did not inform the Bankruptcy Court of the Superior Court Petition before she obtained the Decree.
13. On or about September 8, 2008, Respondent disclosed to the Bankruptcy Court for
the first time that the Superior Court Petition had been filed and that the Decree was obtained
changing the identity of the grantee on the Del Rosa Property recorded grant deed from Mt. Zion
to MZMBC-UA.
14. On or about January 23, 2009, the Bankruptcy Court filed a Memorandum Decision
holding Respondent and MZMBC-UA, jointly and severally, in civil contempt for willful
violation of the automatic stay and imposed sanctions in the amount of $18, 656.50.
15. By filing the Superior Court Petition in violation of the automatic stay rules,
Respondent failed to support the laws of the United States.
COUNT TWO
Case No. 10-O-07369
Business and Professions Code, section 6068(a)
[Failure to Support Laws of the United States]
16. Respondent willfully violated Business and Professions Code, section 6068(a), by
failing to support the Constitution and laws of the United States and of this state, as follows:
17. The allegations of paragraphs 1 through 15 are incorporated herein by reference.
18. Pursuant to 11 U.S.C. § 329(a) and related rules, Respondent, as counsel for Mt.
Zion, was required to accurately and timely disclose Respondent’s fee arrangements and
transactions with Mt. Zion in connection with the Bankruptcy Matter.
19. On or about June 7, 2007, Respondent disclosed in a filing with the Bankruptcy Court
that Respondent had received from Mt. Zion the sum of $2, 000 for legal services to be rendered
in the Bankruptcy Matter. Then, on or about October 15, 2007, Respondent filed a declaration
asserting that she had "received payments [from Mt. Zion] pre-petition in the amount of $5, 000."
Finally, on or about November 7, 2008, Respondent stated that she had received only $2, 000
from Mt. Zion or any other source for legal services rendered or to be rendered in connection
with the Bankruptcy Matter. At no time did Respondent reconcile or explain these
inconsistencies to the Bankruptcy Court during the Bankruptcy Matter.
20. Moreover, Respondent was obligated to obtain approval of her employment as
attorney for Mt. Zion and to seek allowance of fees and expenses incurred as counsel for Mt.
Zion, in accordance with 11 U.S.C. §327 and related rules. Respondent continued in her
employment as attorney for Mt. Zion and received fees for legal services rendered in connection
with the Bankruptcy Matter without obtaining the required Bankruptcy Court approval.
21. By willfully failing to disclose completely and accurately her fee arrangements with
Mt. Zion on June 7 and October 15, 2007, and/or November 7, 2008, and by willfully receiving
fees and expenses as counsel for Mt. Zion in the Bankruptcy Matter without first obtaining the
necessary court approvals for employment as Mt. Zion’s counsel, Respondent failed to support
the laws of the United States.
COUNT THREE
Case No. 10-O-07369
Business and Professions Code, section 6068(a)
[Failure to Support Laws of the United States]
22. Respondent willfully violated Business and Professions Code, section 6068(a), by
failing to support the Constitution and laws of the United States and of this state, as follows:
23. The allegations of paragraphs 1 through 21 are incorporated herein by reference.
24. On or about February 25, 2008, the Bankruptcy Court appointed Christopher Barclay
as the Chapter 11 Trustee for the Bankruptcy Matter (the "Trustee"). At the time the Bankruptcy
Court appointed the Trustee, Respondent had a duty to assist Mt. Zion in cooperating with the
Trustee, in accordance with applicable bankruptcy law and regulations, including 11 U.S.C.
§521(3) and (4).
25. From about February 25, 2008 until about May 5, 2008, the Trustee repeatedly
requested that Respondent and Mt. Zion each turn over Mt. Zion’s financial records.
failed to advise Mt. Zion to promptly turn over its financial records to the Trustee. Respondent
herself failed to turn over Mt. Zion’s financial records that she had in her possession to the
Trustee.
26. By willfully failing to advise Mt. Zion to turn over financial records to the Trustee
and by failing to turn over Mt. Zion’s financial records in her possession to the Trustee,
Respondent failed to support the laws of the United States.
COUNT FOUR
Case No. 10-O-07369
Business and Professions Code, section 6068(d)
[Seeking to Mislead a Judge]
27. Respondent willfully violated Business and Professions Code, section 6068(d), by
seeking to mislead the judge or judicial officer by an artifice or false statement of fact or law, as
follows:
28. The allegations of paragraphs 1 through 26 are incorporated herein by reference.
29. By failing to inform the court that granted the Decree.of the Bankruptcy Petition, by
failing to inform the Bankruptcy Court of the Superior Court Petition until after the Decree had
been obtained, and by failing to accurately disclose the nature of her fee agreement with Mt. Zion as required to the Bankruptcy Court, Respondent sought to mislead the judge or judicial officer by an artifice or false statement of fact or law.
COUNT FIVE
Case No. 10-O-07369
Business and Professions Code, section 6103
[Failure to Pay Sanctions and Obey Court Order]
30. Respondent willfully violated Business and Professions Code, section 6103, by
willfully disobeying or violating an order of the court requiting her to do or forbear an act
connected with or in the course of Respondent’s profession which she ought in good faith to do
or forbear, as follows:
31. The allegations set forth in paragraphs 1 through 29 are incorporated by reference.
32. On or about January 23, 2009, in its Memorandum Decision, the Bankruptcy Court
ordered Respondent to pay $2, 000 to the Trustee by no later than March 6, 2009, due to
Respondent’s "materially defective disclosures" under 11 U.S.C. §329(a) and the applicable
bankruptcy rules. Respondent received the Memorandum Decision and knew of her obligation
to pay $2, 000 to the Trustee by no later than March 6, 2009.
33. Between about January 23, 2009 and April 1, 2012, Respondent did not pay to the
Trustee the $2, 000 as ordered by the court in the Bankruptcy Matter.
34. By failing to pay the sanctions by March 6, 2009, as ordered by the Bankruptcy
Court, Respondent disobeyed an order requiting her to do or forbear an act connected with or in
the course of Respondent’s profession.
COUNT SIX
Case No. [protected]
Business and Professions Code, section [protected])
[Failure to Report Judicial Sanctions]
35. Respondent willfully violated Business and Professions Code, section 6068(o)(3), by
failing to report to the agency charged with attorney discipline, in writing, within 30 days of the
time Respondent had knowledge of the imposition of any judicial sanctions against Respondent,
as follows:
36. The allegations set forth in paragraphs 1 through 34 are incorporated by reference.
37. Respondent did not report to the State Bar of California that $2, 000 in sanctions were
imposed against her in the Bankruptcy Matter.
38. Respondent did not report to the State Bar of California that $18, 656.50 in sanctions
were imposed against her and MZMBC-UA, jointly and severally, for willfully violating the
automatic stay in the Bankruptcy Matter.
39. By not reporting to the State Bar of California either of the sanctions that were
imposed against her by the Bankruptcy Court, Respondent failed to report to the agency charged
with attorney discipline, in writing, within 30 days of the time Respondent had knowledge of the
imposition of any judicial sanctions against Respondent.
COUNT SEVEN
Case No. 12-O-12879
Rules of Professional Conduct, rule 4-100(A)
[Failure to Maintain Client Funds in Trust Account]
40. Respondent wilfully violated Rules of Professional Conduct, rule 4-100(A), by
failing to maintain client funds in a bank account labeled "Trust Account, " "Client’s Funds
Account, " or words of similar import, as follows:
41. On or about June 26, 2009, Anna and Larry Troup ("Troup") hired Respondent to
prepare and file a Chapter 13 bankruptcy petition with the goal of obtaining a modification of
Troup’s home mortgage. At this time, Troup and Respondent executed a written retainer
agreement, which provided that, among other things, Respondent’s billing rate was $350 per
hour, the initial retainer was $4, 500, and any additional payments would be held in a client trust
account until earned by Respondent.
42. Troup paid the initial retainer of $4, 500 to Respondent.
43. On or about October 12, 2009, Respondent prepared and filed a Chapter 13
bankruptcy petition on behalf of Troup in the United States Bankruptcy Court for the Central
District of California, case number 6:09-bk-34202-PC (the "First Troup Bankruptcy").
44. The First Troup Bankruptcy was dismissed on or about December 18, 2009.
45. Because the First Troup Bankruptcy was dismissed, Respondent and Troup agreed
that Respondent would prepare and file a second Chapter 13 bankruptcy petition on behalf of
Troup, again as part of the effort to obtain a loan modification.
46. In or about January 2010, Respondent told Troup to pay to her what Troup would
ordinarily pay to his lender, Bank of America, as his monthly mortgage payments. Respondent
told Troup that this payment arrangement was necessary to effectuate a loan modification after a
Chapter 13 bankruptcy, and that these funds would be held in trust until after the bankruptcy was
dismissed.
47. As a result of this discussion with Respondent, Troup made the following seven
payments to Respondent (which payments approximated his monthly mortgage payments)
(collectively, the "Troup Funds"): $2, 366.20 in February 2010; $2, 366.70 in March 2010; and
$2, 388.08 in April, May, June, July and August 2010.
48. Upon receiving payment of the Troup Funds, Respondent deposited such payment
into her business account (i.e., not a client trust account) at Wells Fargo Bank N.A., account
number 754601xxx1.
49. On or about April 9, 2010, Respondent prepared and filed a second Chapter 13
bankruptcy petition on behalf of Troup in the United States Bankruptcy Court for the Central
District of California, case number 6:10-bk-20531-PC (the "Second Troup Bankruptcy").
50. The Second Troup Bankruptcy was dismissed on or about July 1, 2010.
51. Because the Second Troup Bankruptcy was dismissed, Respondent and Troup agreed
that Respondent would prepare and file a third bankruptcy petition, this time under Chapter 11,
again as part of the effort to obtain a loan modification.
52. On or about November 12, 2010, Respondent prepared and filed a Chapter 11
bankruptcy petition on behalf of Troup in the United States Bankruptcy Court for the Central
District of California, case number 6:10-bk-46700-DS (the "Final Troup Bankruptcy").
53. On or about June 17, 2011, the Final Troup Bankruptcy was dismissed. Troup did
not obtain a loan modification, and, in or about December 2011, the Troup’s home was in
foreclosure.
The last three digits of the account number of Respondent’s account have been redacted for privacy considerations.
54. In or about November 2011, Troup terminated the employment of Respondent and
requested that Respondent return the Troup Funds. Respondent refused. Respondent has not
refunded any portion of the Troup Funds to Troup or paid any amount to Bank of America (or
any other lender) on behalf of Troup.
55. Respondent was required to maintain the Troup Funds in a client trust account, on
behalf of Troup.
56. By not maintaining any portion of the Troup Funds in a client trust account,
Respondent willfully failed to maintain client funds in a trust account.
COUNT EIGHT
Case No. 12-O-12879
Business and Professions Code, section 6106
[Moral Turpitude - Misappropriation]
57. Respondent willfully violated Business and Professions Code, section 6106, by
committing an act, or acts, involving moral turpitude, dishonesty or corruption, as follows:
58. The allegations of paragraphs 40 through 56 are incorporated by reference.
59. Upon the final payment of the Troup Funds in August 2010, the Troup Funds paid to
Respondent totaled at least $16, 673.30. Because the Troup Funds were to be held in trust,
Respondent was required to maintain a minimum balance of $16, 673.30 on behalf of Troup.
60. Following the deposit of the final Troup Fund payment in August 2010, the balance
in Respondent’s bank account in which Respondent deposited the Troup Funds fell below the
sum of $16, 673.30. On or about October 31, 2010, the balance was approximately $2, 588.12.
61. Respondent dishonestly or with gross negligence misappropriated the Troup Funds.
62. By misappropriating at least $14, 085.18 (i.e., the difference between the Troup Funds
and the remaining balance), Respondent committed an act involving moral turpitude, dishonesty
or corruption.
-9-
COUNT NINE
Case No. 12-O-12879
Rules of Professional Conduct, rule 4-100(B)(3)
[Failure to Render Accounts of Client Funds]
63. Respondent willfully violated Rules of Professional Conduct, rule 4-100(B)(3), by
failing to render appropriate accounts to a client regarding all funds coming into Respondent’s
as follows:
64. The factual allegations of paragraphs 40 through 62 are incorporated herein by
reference.
65. At no time during Respondent’s representation of Troup did Respondent provide an
accounting of the services rendered.
66. By failing to provide an accounting to Troup of the services rendered on Troup’s
behalf, Respondent failed to render appropriate accounts to a client regarding all funds coming into Respondent’s possession.
COUNT TEN
Case No. 12-O-12879
Business and Professions Code, section 6068(d)
[Seeking to Mislead a Judge]
67. Respondent willfully violated Business and Professions Code, section 6068(d), by
seeking to mislead the judge or judicial officer by an artifice or false statement of fact or law, as follows:
68. The allegations of paragraphs 40 through 66 are incorporated herein by reference.
69. Pursuant to 11 U.S.C. § 329(a) and related rules, Respondent, as counsel for Troup, was required to accurately and timely disclose Respondent’s fee arrangements and transaction with Troup in connection with the First Troup Bankruptcy, the Second Troup Bankruptcy and the Final Troup Bankruptcy. Moreover, Respondent was obligated to obtain approval of her employment as attorney for Troup and to seek allowance of fees and expenses incurred as
counsel for Troup, in accordance with 11 U.S.C. §327 and related rules.
70. On or about October 12, 2009, Respondent certified in a filing in the First Troup
Bankruptcy that "For legal services, I have agreed to accept $4, 000, " and "Prior to the filing of
this statement I have received $2, 288.00." At no time during the First Troup Bankruptcy, did
Respondent file an application for employment (or otherwise seek approval of her fees);
nonetheless, Respondent continued in her employment as attorney for the First Troup
Bankruptcy and received fees for legal services rendered in connection with the First Troup
Bankruptcy without obtaining the required court approval.
71. On or about April 26, 2010, Respondent certified in a filing in the Second Troup
Bankruptcy that "For legal services, I have agreed to accept $4, 000, " and "Prior to the filing of
this statement I have received $2, 288.00." At no time during the Second Troup Bankruptcy, did
Respondent file an application for employment (or otherwise seek approval of her fees);
nonetheless, Respondent continued in her employment as attorney for the Second Troup
Bankruptcy and received fees for legal services rendered in connection with the Second Troup
Bankruptcy without obtaining the required court approval.
72. On or about December 30, 2010, Respondent filed in the Final Troup Bankruptcy a
declaration stating: "Professional retained by the Debtor are [sic] Greta S. Curtis ... Amount of
compensation is expected to be $5, 000.00 as the Debtors did pay some compensation in the prior
two (2) bankruptcy cases."
73. On or about November 29, 2010, Respondent filed an employment application with
the bankruptcy court in the Final Troup Bankruptcy. On or about January 10, 2011, the
bankruptcy court denied the application; nonetheless, Respondent continued in her employment
as attorney for the Final Troup Bankruptcy and received fees for legal services rendered in
connection with the Final Troup Bankruptcy without obtaining the required court approval.
74. By failing to accurately disclose her fee arrangements and compensation in the First,
Second and Final Troup Bankruptcies, and continuing to accept attorney fees without the court
approval to do so, Respondent sought to mislead the judge or judicial officer by an artifice or
false statement of fact or law.
COUNT ELEVEN
Case No. 12-O-12879
Business and Professions Code, section 6068(a)
[Failure to Support Laws of the United States]
75. Respondent willfully violated Business and Professions Code, section 6068(a), by
falling to support the Constitution and laws of the United States and of this state, as follows:
76. The allegations of paragraphs 40 through 75 are incorporated herein by reference
77. By failing to disclose completely and accurately her fee arrangements with Troup on
October 12, 2009, April 26, 2010 and/or December 30, 2010, and by willfully falling to obtain
the necessary court approvals for employment as Troup’s counsel and for receiving fees and
expenses as counsel for Troup, Respondent failed to support the laws of the United States.
COUNT TWELVE
Case No. 12-O-12879
Rules of Professional Conduct, rule 4-200(A)
[Unconscionable Fee]
78. Respondent wilfully violated Rules of Professional Conduct, rule 4-200(A), by
entering into an agreement for, charging, or collecting an unconscionable fee, as follows:
79. The allegations of paragraphs 40 through 78 are incorporated herein by reference.
80. On or about September 24, 2012, Respondent submitted an account of services
rendered to Troup, almost a year after her employment had been terminated.
81. Respondent worked approximately 6.9 hours on behalf of Troup and charged
fees of at least $21, 165.00, which amounts to $3, 067.39 per hour.
82. On or about November 12, 2010, Respondent billed $9, 600.00 for one day’s work to
"prepare documents for [the Final Troup Bankruptcy], " "professional legal services, " and to
"prepare declaration."
83. Pursuant to the written agreement executed by Troup and Respondent: "Time is
charged in minimum units of one tenth (. 10) of an hour. The following have higher minimum
charges: Cellular Telephone calls: $158.00, Letters: $158.00, Other: $158.00."
84. By charging Troup at a rate of $3, 067.39 per hour (contrary to the contracted rated of
$350 per hour), by billing Troup $9, 600.00 for one day of work, and by charging a minimum of
$158.00 for any service provided, Respondent entered into an agreement for, charged and
collected an unconscionable fee.
COUNT THIRTEEN
Case No. 12-O-13731
Business and Professions Code, section 6106
[Moral Turpitude - Misappropriation]
85. Respondent willfully violated Business and Professions Code, section 6106, by
committing an act, or acts, involving moral turpitude, dishonesty or corruption, as follows:
86. On or about February 15, 2010, Kathryn Penn Carr ("Carr") employed Respondent to
represent her in a probate matter, In Re Marie Moore Penn Rowe, case no. BP 121209, and to
handle Carr’s own trust and estate documents. At this time, Carr paid Respondent $4, 400 as a
retainer for Respondent’s services.
87. On or about February 18, 2010, Carr wrote three checks to Respondent totaling
$289, 410.38 (the "Carr Funds"). At this time, Respondent provided Carr with a hand-written
receipt noting that the payments were "for safekeeping in Arty-Client Trust."
88. Respondent was required to maintain the Carr Funds in a client trust account on
behalf of Carr.
89. Respondent deposited the Carr Funds in her client trust account, account number
[protected] at Wells Fargo Bank N.A.
90. On or about March 29, 2012, Carr terminated her employment of Respondent and
requested a return of the Carr Funds.
91. Following the deposit of the Carr Funds in February 2010, the balance in
Respondent’s client trust account fell below the sum of $289, 410.38, and never exceeded that
amount for at least the next two years until April 2012, by which time Carr had terminated
employment of Respondent. On or about April 1, 2012, Respondent’s client trust had a balance
of approximately $8, 984.96.
92. Respondent dishonestly or with gross negligence misappropriated the Carr Funds.
93. By misappropriating at least $280, 425.42 (i.e., the difference between the Carr Funds
and the balance as of April 1, 2012 when Carr’s employment of Respondent was terminated),
Respondent committed an act involving moral turpitude, dishonesty or corruption.
COUNT FOURTEEN
Case No. 12-O-12879
Rules of Professional Conduct, rule 4-100(B)(3)
[Failure to Render Accounts of Client Funds]
94. Respondent willfully violated Rules of Professional Conduct, rule 4-100(B)(3), by
failing to render appropriate accounts to a client regarding all funds coming into Respondent’s
as follows:
95. The allegations of paragraphs 86 through 94 are incorporated herein by reference.
96. At no time during Respondent’s representation of Carr did Respondent provide an
accounting of services rendered.
97. By failing to provide an accounting to Carr of the services rendered on Carr’s behalf,
Respondent failed to render appropriate accounts to a client regarding all funds coming into
Respondent’s possession in willful violation of rule 4-100(B)(3), Rules of Professional Conduct.
NOTICE - INACTIVE ENROLLMENT!
YOU ARE HEREBY FURTHER NOTIFIED THAT IF THE STATE BAR
COURT FINDS, PURSUANT TO BUSINESS AND PROFESSIONS CODE
SECTION 6007(c), THAT YOUR CONDUCT POSES A SUBSTANTIAL
THREAT OF HARM TO THE INTERESTS OF YOUR CLIENTS OR TO
THE PUBLIC, YOU MAY BE INVOLUNTARILY ENROLLED AS AN
INACTIVE MEMBER OF THE STATE BAR. YOUR INACTIVE
ENROLLMENT WOULD BE IN ADDITION TO ANY DISCIPLINE
RECOMMENDED BY THE COURT.
NOTICE - COST ASSESSMENT!
IN THE EVENT THESE PROCEDURES RESULT IN PUBLIC
DISCIPLINE, YOU MAY BE SUBJECT TO THE PAYMENT OF COSTS
INCURRED BY THE STATE BAR IN THE INVESTIGATION, HEARING
AND REVIEW OF THIS MATTER PURSUANT TO BUSINESS AND
PROFESSIONS CODE SECTION 6086.10.
Respectfully submitted,
THE STATE BAR OF CALIFORNIA
OFFICE OF THE CHIEF TRIAL COUNSEL
: December 28, 2012
Ross E. Viselman
Deputy Trial Counsel
-15-
DECLARATION OF SERVICE
by
U.S. FIRST-CLASS MAIL / U.S. CERTIFIED MAIL / OVERNIGHT DELIVERY / FACSIMILE-ELECTRONIC TRANSMISSION
CASE NUMBER(s): [protected], [protected], [protected]
I, the undersigned, am over the age of eighteen (18) years and not a party to the within action, whose business address and place of employment is the State Bar of
California, 1149 South Hill Street, Los Angeles, California 90015, declare that:
on the date shown below, I caused to be served a true copy of the within document described as follows:
NOTICE OF DISCIPLINARY CHARGES - service for Case Number: [protected] *
By U.S. First-Class Mail: (CCP ~ 1013 and 1013(a)) L~J By U.S. Certified Mail: (CCP §§ 1013 and t013(a))
in accordance with the practice of the State Bar of California for collection and processing of mail, I deposited or placed for collection and mailing in the City and County
of Los Angeles.
By Overnight Delivery: (CCP ~ 1013(c) and 1013(d))
I am readily familiar with the State Bar of California’s practice for collection and processing of correspondence for overnight delivery by the United Parcel Service (’UPS’).
By Fax Transmission: (CCP §§ 1013(e) and 1013(f))
Based on agreement of the parties to accept service by fax transmission, I faxed the documents to the persons at the fax numbers listed herein below. No error was
reported by the fax machine that I used. The odginal record of the fax transmission is retained on file and available upon request.
By Electronic Service: (CCP § 1010.6)
Based on a court order or an agreement of the parties to accept service by electronic transmission I caused the documents to be sent to the person(s) at the electronic
addresses listed herein below./did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transm ss on was
unsuccessful.
[] I~u.s. R, ~t.Ct, , , ~, , Itj in a sealed envelope placed for collection and mailing at Los Angeles, addressed to: (see below)
[] t~orc~, iO in a sealed envelope placed for collection and mailing as certified mail, return receipt requested,
Article No.: [protected] at Los Angeles, addressed to: (see below)
[] t~oro~, , ighte¢i, ~, ~ together with a copy of this declaration, in an envelope, or package designated by UPS,
Tracking No.: addressed to: (see below)
:
Ollie P. Manago 3460 Wilshire Blvd. Ste. 1214
Los Angeles, CA 90010 Electronic Address
[] via inter-office mail regulady processed and maintained by the State Bar of California addressed to:
NIA
I am readily familiar w~ the State Bar of California’s practice for collection and processing of correspondence for mailing with the United States Postal Service, and
overnight delivery by the United Parcel Service (’UPS’). In the ordinary course of the State Bar of California’s practice, correspondence collected and processed by the State Bar of
California would be deposited with the United States Postal Service that same day, and for overnight delivery, deposited with delivery fees paid or provided for, with UPS that same
day.
I am aware that on motion of the PaR served, service is presumed invalid if postal cancellation date or postage meter date on the envelope or package is more than one day
after date of deposit for mailing contained in the affidavit.
I declare under penalty of perjury, under the laws of the State of California, that the foregoing is true and correct. Executed at Los Angeles,
California, on the date shown below.
DATED: December 28, 2012 SIGNED: ~
State Bar of California
DECLARATION OF SERVICEDATED: December 28, 2012 SIGNED:
Declarant
State Bar of California
DECLARATION OF SERVICE
DECLARATION OF SERVICE
by
U.S. FIRST-CLASS MAIL / U.S. CERTIFIED MAIL / OVERNIGHT DELIVERY / FACSIMILE-ELECTRONIC TRANSMISSION
CASE NUMBER(s): 10-O-07369, 12-O-12879, 12-O-13731
I, the undersigned, am over the age of eighteen (18) years and not a party to the within action, whose business address and place of employment is the State Bar of
California, 1149 South Hill Skeet, Los Angeles, California 90015, declare that:
on the date shown below, I caused to be sewed a true copy of the within document described as follows:
NOTICE OF DISCIPLINARY CHARGES - service for Case Number: [protected] *
By U.S. First-Class Mail: (CCP ~ 1013 and 1013(a)) L~J By U.S. Certified Mail: (CCP §§ 1013 and t013(a))
in accordance with the practice of the State Bar of California for collection and processing of mail, I deposited or placed for collection and mailing in the City and County of Los Angeles.
By Overnight Delivery: (CCP ~ 1013(c) and 1013(d))
I am readily familiar with the State Bar of California’s practice for collection and processing of correspondence for overnight delivery by the United Parcel Service (’UPS’).
By Fax Transmission: (CCP §§ 1013(e) and 1013(f))
Based on agreement of the parties to accept service by fax transmission, I faxed the documents to the persons at the fax numbers listed herein below. No error was
reported by the fax machine that I used. The original record of the fax transmission is retained on file and available upon request.
By Electronic Service: (CCP § 1010.6)
Based on a court order or an agreement of the parties to accept service by electronic transmission I caused the documents to be sent to the person(s) at the electronic
addresses listed herein below./did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was
unsuccessful.
In a sealed envelope placed for collection and mailing at Los Angeles, addressed to: (see below)
in a sealed envelope placed for collection and mailing as certified mail, return receipt requested,
Article No.: [protected] at Los Angeles, addressed to: (see below)
together with a copy of this declaration, in an envelope, or package designated by UPS,
Tracking No.: addressed to: (see below)
:
Ollie P. Manago 3460 Wilshire Blvd. Ste. 1214
Los Angeles, CA 90010 Electronic Address
[] via inter-office mail regularly processed and maintained by the State Bar of California addressed to:
NIA
I am readily familiar w~ the State Bar of California’s practice for collection and processing of correspondence for mailing with the United States Postal Service, and
overnight delivery by the United Parcel Service (’UPS’). In the ordinary course of the State Bar of California’s practice, correspondence collected and processed by the State Bar of
California would be deposited with the United States Postal Service that same day, and for overnight delivery, deposited with delivery fees paid or provided for, with UPS that same
day.
I am aware that on motion of the par served, service is presumed invalid if postal cancellation date or postage meter date on the envelope or package is more than one day
after date of deposit for mailing contained in the affidavit.
I declare under penalty of perjury, under the laws of the State of California, that the foregoing is true and correct. Executed at Los Angeles,
California, on the date shown below.
DATED: December 28, 2012 SIGNED: ~
State Bar of California
DECLARATION OF SERVICE