against S&M Auto Brokers and its owners, Saed Ihmud and ... · c. Reply in Support of S&M Auto...

BEFORE THE HEARING BOARD

OF THE

ILLINOIS ATTORNEY REGISTRATION

AND

DISCIPLINARY COMMISSION

In the Matter of:

JOEL ALAN BRODSKY, Commission No. 2018PR00064

Attorney-Respondent,

No. 6182556.

ANSWER TO COMPLAINT

Now comes JOEL ALAN BRODSKY, by his attorney, SAMUEL J. MANELLA,

and for his Answer to the Complaint, states as follows:

COUNT I

{Using means with no substantial purpose other than to embarrass, delay, or burdenthirdpersons - Twyman)

1. On October 16, 2015, Donaldson Twyman ("Twyman") purchased a 2013Infiniti SUV for $35,000 from S&M Auto Brokers. After Twyman purchased the vehicle,he discovered information that had not been disclosed to him at the time of purchase:the vehicle had previously been in a serious accident; had been rebuilt; and theodometer had been rolled back. Twyman consulted with attorney Peter Lubin ("Lubin")to determine his legal options, and Lubin determined that Twyman had a valid claimagainst S&M Auto Brokers and its owners, Saed Ihmud and Mohammed Ihmud, forselling Twyman an automobile without informing him that the vehicle had been in aserious accident, and for manipulating the vehicle's odometer to deceive Twyman aboutthe vehicle's mileage.

ANSWER:

Respondent neither admits nor denies the allegations in paragraph 1 as he has

no knowledge of the facts alleged, except that Respondent denies that

information known to S&M Auto Brokers had not been disclosed to Twyman,

denies that the car Twyman purchased had been in a serious accident or was

andrea

Filed - ARDC Clerk - Today's Date

rebuilt, and denies the car sold to Twyman had the odometer rolled back, as

alleged in Paragraph 1 of Count I of the Complaint.

2. On April 8, 2016, Lubin filed a complaint on behalf of Twyman in theUnited States District Court for the Northern District of Illinois, Eastern Division, againstS&M Auto Brokers, Saed Ihmoud and Mohammed Ihmoud pursuant to 49 U.S.C. §32705(a) ("the Federal Odometer Act"), 625 ILCS 5/3-112.1 ("the Illinois Odometer Act")and 815 ILCS 505/2 ("the Illinois Consumer Fraud and Deceptive Business PracticesAct"). The clerk of the court captioned the matter Donaldson Twyman vs. S&M AutoBrokers, Saed Ihmoud, and Mohammed Ihmoud, docket number 16 cv 4182.

ANSWER;

Respondent admits the allegations contained in Paragraph 2 of Count I of the

Complaint.

3. On or about April 23, 2016, Respondent and Saed and MohammedIhmoud agreed that Respondent would represent S&M Auto Brokers and the Ihmoudsin relation to case number 16 cv 4182 for an agreed-upon fee. On May 4, 2016,Respondent filed his appearance in case number 16 cv 4182 on behalf of S&M AutoBrokers and the Ihmouds.

ANSWER:


Complaint.

4. Between May 4, 2016 and August 25, 2016, Respondent commenced apattern of conduct toward Lubin in case number 16 cv 4182, which eventually becamethe subject of court sanctions and is described further in the following paragraphs.Respondent's conduct was directed at Lubin as well as the plaintiffs expert, DonaldSzczesniak ("Szczesniak").

ANSWER:

Respondent admits that his actions were the subject of court sanctions as

alleged in Paragraph 4 of Count I of the Complaint, and further answering, denies

that his conduct in the case is fully and accurately described in the complaint as

will be addressed below.

5. At a status hearing on or about June 30, 2017, Respondent stated thatLubin was in the business of extorting businesses like S&M and that Lubin files lawsuitslike case number 16 cv 4182 when there is no basis for doing so. In addition, on orabout August 25, 2016, Respondent accused Lubin of "recidivist conduct" because "he[had] filed three other lawsuits" for the same type of claim.

ANSWER:

Respondent denies the allegations contained in Paragraph 5 of Count I of the

Complaint.

6. After Respondent's statements described in paragraph five, above, onAugust 25, 2016, the court entered an order stating that the attorneys "should actprofessionally instead of antagonistically toward each other and recognize that asofficers of the Court they are expected to treat each other reasonably andprofessionally."

ANSWER:

Respondent denies that the August 25, 2016 order was written after the June 30,

2017 court appearance and further answering, denies that the August 25, 2016

Order had anything to do with the actions of the Respondent as alleged in

Paragraph 6 of Count I of the Complaint

7. Despite Judge Kendall's August 25, 2016 written warning, Respondentcontinued a pattern and practice of unprofessional behavior including false allegationsand inappropriate diatribes in pleadings accusing Lubin of lying, extortion, attempting tocreate a false record, and repeatedly requesting sanctions without any good-faith basis;false allegations impugning plaintiffs expert, Donald Szczesniak ("Szczesniak"), andvitriolic emails to Lubin.

ANSWER:


Complaint.

Pleadings Regarding Lubin

8. Between September 21, 2016 and March 13, 2017, Respondentrepeatedly filed pleadings accusing Lubin of having an improper motive for filing casenumber 16 cv4182, and of engaging in criminal wrongdoing, including the following:

a. Motion for a Protective order filed September 21, 2016:

Plaintiff does not consider a lawsuit a way to redress a legitimate grievance byuncovering the truth and applying the law, but instead considers it to be a profitmaking, fee generating, enterprise for attorneys. H1

b. Objection and Response to Plaintiffs Motion to Dismiss Record withProgressive Insurance Documents Because Plaintiff Misrepresents What TheyShow as They do not Show the Car was in a Major Accident filed on October 14,2016:

Plaintiffs attorney keeps on filing false and misleading pleadings to try to run upexorbitant fees in a case in which the Plaintiffs [sic] attorney has proved by hisactions that he has no interest in the truth, and just sees the litigation process asan extortion game, in which his goal is only to extort as much money as possibleout of the Defendants, no matter what the truth is. 1J1

Used car dealers are not fair game targets for unscrupulous attorneys who lookat lawsuits as a means to commit 'legal extortion,' and not as a way to get at thetruth and remedy a wrong.tf4

c. Reply in Support of S&M Auto Broker's Motion in Limine Regarding ExpertWitnesses and for Other Relief filed on January 27, 2017:

Defendant S&M Auto has said from the first that this case was an attempt atextortion by using false hyperbole and fabricated evidence. 1J9

d. Response to Plaintiffs Motion for Partial Summary Judgment andDefendant's Cross-Motion for Summary Judgement filed on February 10, 2017:

The Plaintiffs Motion for Partial Summary Judgment is, like the entire Plaintiffscase, a total and complete fraud, submitted for the sole purpose of assisting thePlaintiffs attorneys in their attempt to use the legal system to extort money from

the Defendant. The entire motion is based on a premise that has no basis in lawand is further supported by a statement of uncontested facts that is anything butuncontested. Never, in over three decades of practice has Defendants [sic]lawyer seen anything like this perpetrated by lawyers in a court of law. This isakin to a situation back in the 1980's where certain personal injury attorneys setup auto-staged accidents and then filed injury lawsuits based on those stagedaccidents. U

e. Motion to Reconsider Order of February 16, 2017, or for an Extension of Timeto Provide Supplemental Expert Reports filed on February 20, 2017:

What is happening in this case is that the Plaintiffs' [sic] attorneys are fabricatinga case, with the help of [their] unscrupulous [expert], where there is none, andare trying to use the fee shifting provisions of the Illinois Consumer Fraud statuteas a tool of extortion by running up an exorbitant amount of fees in the hope thatthey can fool a jury or put the Plaintiff at such risk he will rather pay somethingthan risk losing his business built up over a decade. What Plaintiffs [sic] attorneysare doing reminds Defendant [sic] of cases in the 1990's [sic] where a group ofpersonal injury attorneys were caught staging accidents to defraud insurancecompanies. 1J2

f. Response to Plaintiffs Motion Clarification and Reply in Support ofDefendant's Motion to Strike LR 56.1(c) Statement and for Sanctions filed onMarch 8, 2017:

The only reason for [filing the motion for summary judgment] and filing thehundreds of pages of documents in support, is so that Plaintiffs' [sic] attorneyscan run up a huge legal bill which it intends to try to pass that bill off toDefendants under the fee shifting provisions of the Illinois Consumer Fraud Act.From Plaintiffs' [sic] Attorneys [sic] point of view this case has nothing to do withthe facts or the law and is solely a money-making enterprise where the real partyin interest are [sic] the attorneys for the Plaintiff and not the Plaintiff himself. |̂9

g. Reply in Support of Motion for Sanctions Regarding Plaintiffs Declared"Expert" Donald Szczesniak filed on March 13, 2017:

Defendant asserts that to bring a lawsuit in U.S. District Court to extort money,based entirely on false evidence, and an expert who is [sic] tampers withwitnesses and presents false declarations and/or engages in false lawsuit ... isno small matter. Tj

ANSWER:

Respondent admits the pleadings filed contained the language alleged in

Paragraph 8(a) through (g) of Count I of the Complaint, and further answering,

Respondent states that he denies that Respondent accused Attorney Lubin of

engaging in criminal wrongdoing.

9. Respondent's statements in the pleadings described in paragraph eight,above, that Lubin had filed a fabricated case, filed false and misleading pleadings andengaged in fee churning and extortion had no basis in law or fact, and were frivolous,because Lubin had a basis in law and fact for filing the litigation at issue and was notengaged in fee churning or extortion.

Pleadings Regarding Donald Szczesniak - Plaintiffs Expert

ANSWER:


Complaint.

10. Between January 27, 2017 and March 13, 2017, Respondent filedpleadings containing false and harassing allegations regarding Szczesniak.

ANSWER:


Complaint.

11. On January 27, 2017, Respondent filed a reply in support of S&M AutoBrokers' Motion in limine seeking a ruling that its disclosed experts were qualified togive expert testimony. In that reply, Respondent accused the plaintiffs expert, DonaldSzczesniak ("Szczesniak"), of filing a fabricated report in case number 16 cv 4182 andstated that Szczesniak had a history of filing fabricated expert reports in unrelatedmatters.

ANSWER:


Complaint, except to state that the history referred to was one specific instance

that was supported by documentation attached as exhibits to the reply.

12. Respondent's statements that Szczesniak had fabricated a report in casenumber 16 cv 4182 and that Szczesniak had a history of filing fabricated expert reportshad no basis in law or in fact, were frivolous, and made in bad faith, in an attempt toimproperly impugn Szczesniak's reputation before the court in case number 16 cv 4182.

ANSWER:


Complaint.

13. On February 13, 2017, Respondent filed a motion in case number 16 cv4182 entitled "Motion for an Order Holding Plaintiffs 'Expert' Witness DonaldSzczesniak in Indirect Criminal Contempt of Court and to Refer this Matter to the UnitedStates Attorney." In that motion, Respondent accused Szczesniak of damaging thefence of a woman named Diane Weinberger ("Weinberger"), who was a witness in anunrelated matter, in a purported attempt to intimidate Weinberger.

ANSWER:

Respondent admits that the pleading described in Paragraph 13 of Count I of the

Complaint was filed.

14. Respondent's allegations that Szczesniak had damaged Weinberger'sfence, as described in paragraph 13, above, were solely based on the Weinberger'sunsubstantiated allegations. At the time that Respondent filed the pleading accusingSzczesniak of damaging Weinberger's fence, Respondent had no evidence thatSzczesniak had been questioned or charged in relation to Weinberger's damagedfence, and Respondent took no action beyond speaking with Weinberger to informhimself about the alleged facts of Weinberger's claim.

ANSWER:


Complaint and affirmatively states that in addition to speaking with Weinberger,

the Respondent obtained a copy of the police report filed by Weinberger and

obtained the sworn affidavit of Weinberger.

15. Respondent's allegations that Szczesniak had damaged Weinberger'sfence had no basis in law or fact, were frivolous, and had no other purpose than toharass and intimidate Szczesniak, and to impugn Szczesniak's reputation before thecourt in case number 16 cv 4182.

ANSWER:


Complaint.

16. Respondent's February 13, 2017 motion described in paragraph 13,above, also falsely accused Szczesniak of sending Respondent an anonymousfacsimile in a purported attempt to intimidate Respondent from searching intoSzczesniak's background. At the time that Respondent filed the pleading accusingSzczesniak of sending Respondent an intimidating anonymous facsimile, Respondenthad no evidence to support his accusation that Szczesniak sent him the facsimile.

ANSWER:


Complaint, and further answering, admits the motion accused Szczesniak of

sending an anonymous facsimile to Respondent in an attempt to intimidate

Respondent.

17. Respondent's actions in accusing Szczesniak of sending Respondent ananonymous facsimile were unsubstantiated, false, and frivolous, and had no otherpurpose than to harass and intimidate Szczesniak, and to impugn Szczesniak'sreputation before the court in case number 16 cv 4182.

ANSWER:


Complaint.

18. On February 14, 2017, the court summarily dismissed Respondent'sFebruary 13, 2017 Motion for an Order Holding Plaintiffs "Expert" Witness DonaldSzczesniak in Indirect Criminal Contempt of Court and to Refer this Matter to the UnitedStates Attorney. Then on February 27, 2017, Respondent filed a motion seekingsanctions against Szczesniak and against the plaintiff for retaining Szczesniak.Respondent's February 27, 2017 motion again accused Szczesniak of damaging afence and sought an order barring Szczesniak from testifying due to his allegedlyimproper and illegal behavior.

ANSWER:

Respondent admits the Court denied the Motion filed by Respondent to have

Szczesniak held in indirect criminal contempt of court, and further answering

admits that thereafter Respondent filed a motion seeking sanctions against

Szczesniak based on his damaging Weinberger's fence. Respondent further

states that the Court invited the Respondent to file the motion for sanctions in her

written Order of February 14, 2017.

19. On March 13, 2017, Lubin filed a response to Respondent's motion forsanctions, asserting that Respondent's accusations were false, and attaching affidavitsfrom Szczesniak, his wife, and son Luke who all attested that Szczesniak was homesick at the time the fence had allegedly been damaged.

ANSWER:


Complaint.

20. On March 13, 2017, Respondent filed a pleading entitled "Reply inSupport of Sanctions Motion for Sanctions Regarding Plaintiffs Declared 'Expert'Donald Szczesniak." In that pleading, Respondent called Szczesniak a liar, and

Respondent falsely accused Szczesniak of fabricating a son named Luke in his sworndeclaration, and of fabricating the affidavit filed by Luke, because Respondent'sLexisNexis public records search did not reveal that Szczesniak had a son named Luke.

ANSWER:

Respondent admits the allegation contained in Paragraph 20 of Count I of the

Complaint that the Respondent filed a reply in support of the Motion for

Sanctions, and further answering, denies that Respondent accused Szczesniak of

fabricating a son, and affirmatively states that Respondent only asked the court

for time to look into why the name of Szczesniak's son did not show up on a

LexisNexis public records search.

21. Respondent's actions in accusing Szczesniak of fabricating a son namedLuke and fabricating the affidavit filed by Luke, were unsubstantiated, false, andfrivolous, and had no other purpose than to harass and intimidate Szczesniak, and toimpugn Szczesniak's reputation before the court in case number 16 cv 4182.13.

ANSWER:


Complaint.

Emails to Lubin

22. Between September 20, 2016 and March 29, 2017, Respondentrepeatedly sent emails to Lubin that had no substantial purpose, other than to harass orburden Lubin, including the following:

a. An email dated September 20, 2016 at 7:35 am, stating:

How can I work with a lawyer who will not call the prior owner to see if [sic] carwas in an accident? (It wasn't). This means you have no interest in the truth andthis is only a money-making exercise. The law as a method of extortion. How canI work with an extortionist? I doubt the court will feel that a lawsuit is not forgetting at the truth, but only for making money for the lawyer, but you keepsending those emails. The admissions (or should I say confessions) will be veryuseful in my motion and fee petition.

10

b. An email dated January 9, 2017 at 9:03 at stating:

Your attempt to manufacture a case where none exists is deplorable and yourattempt as using your law license to commit extortion will not succeed and we willbe seeing fees from you after your ridiculous case is dismissed.

c. An email dated January 9, 2017 at 12:39 pm, stating:

As to my remarks, the only thing unprofessional here is what you are doing,which is making up a bogus case and trying to run up hours to extort moneythrough a lawsuit.

d. An email dated March 29, 2017 at 6:23 pm, stating:

I just read the pack of lies on your Motion for Protective Order, even your ownreporter said it was your behavior that caused her to walk out. I love your quoteabout the degrading search for the truth. That is all your case is, a degradation ofthe search for the truth. How do you even call yourself a lawyer? You are anembarrassment to the profession.

ANSWER:

Respondent admits that emails were sent that contained the language quoted in

Paragraphs 22(a), 22(b), 22(c) and 22(d) as alleged in Paragraph 22 of Count I of

the Complaint, and further answering, states that the language quoted is not the

entire email, nor do they represent the entire email chain and therefore does not

fully and accurately represent the facts and circumstances circumstances

surrounding the e-mail exchanges.

23. At the time that Respondent made the statements in the emails describedin paragraph 22, above, calling Lubin an extortionist, Respondent knew that Lubin wasnot extorting money in case number 16 cv 4182, and Respondent did not believe thatLubin was a criminal. Respondent's actions in accusing Lubin of extortion andmanufacturing a case were unsubstantiated, false, and frivolous, and had no otherpurpose than to harass and intimidate Lubin.

li

ANSWER:


Complaint.

24. On April 27, 2017, Lubin filed a motion for sanctions against Respondent,based upon the conduct described in paragraphs 8 through 20, above. On July 7, 2017,a hearing was held on Lubin's motion for sanctions, during which Lubin testifiedregarding his good-faith basis for filing the lawsuit, discussed Szczesniak's integrity andqualifications, denied being in a criminal enterprise. Szczesniak also testified about theimportance of his reputation to his work an expert witness, denied damagingWeinberger's fence, denied sending Respondent an anonymous fax, and confirmed thathe has a son named Luke. Respondent did not submit any evidence contradictingLubin's or Szczesniak's testimony, nor did he provide any explanation for his behaviorthroughout the case, including the allegations against Lubin and Szczesniak.

ANSWER:


Complaint, except to deny that the respondent did not submit any evidence

contradicting Lubin's or Szczesniak's testimony, and Respondent affirmatively

states that the record in the 16CV4182 case contains a great deal of evidence

which refutes Lubin's and Szczesniak's testimony and explains the Respondent's

behavior and allegations against Lubin and Szczesniak.

25. On March 28, 2018, the Honorable Virginia M. Kendall entered an ordergranting Lubin's motion for sanctions. Judge Kendall's order stated, inter alia, that shehad "warned [Respondent] numerous times to curb his vitriolic conduct. Instead ofheeding the Court's advice, at every opportunity, he increased his acerbic behavior,culminating in his unhinged attack against Szczesniak. In doing to, [Respondent] actedin bad faith and if left unpunished, his actions would serve to undermine the integrity ofthis Court."

ANSWER:


Complaint, but Respondent affirmatively states that Judge Kendall's findings are

12

not supported by the record in 16CV4182 and the matter is currently on appeal.

26. Judge Kendall's March 28, 2017 order required Respondent to pay a$50,000 fine to the Clerk of the Court, attend an ethics course approved by the ARDC,and attend and provide the court with verification of successful completion of an angermanagement course. Judge Kendall's order also referred Respondent to the ExecutiveCommittee "for consideration of being barred or suspended from practicing in theNorthern District of Illinois for his failure to abide by the Court rules."

ANSWER:


Complaint.

27. On April 6, 2018, Respondent filed a notice of appeal of Judge Kendall'sorder with the United States Court of Appeals for the Seventh Circuit. As of July 25,2018, the date that this matter was voted by the Inquiry Board, Respondent's appealremained pending. As of the date this matter was voted by the Inquiry Board, theExecutive Committee matter against Respondent also remained pending.

ANSWER:


Complaint.

28. By reason of the conduct described above, Respondent has engaged inthe following misconduct:

a. bringing or defending a proceeding, or asserting or controverting anissue therein, with no basis in law and fact for doing so that was notfrivolous, by conduct including, but not limited to, filing pleadingsthat stated the Lubin was an extortionist and that Szczesniak had ahabit of filing fabricated reports, and that Szczesniak had damagedWeinberger's fence to intimidate the witness, and by seeking anorder holding Szczesniak in indirect criminal contempt and toreferring him to the United States Attorney, in violation of Rule 3.1of the Illinois Rules of Professional Conduct (2010);

b. using means that have no substantial purpose other than toembarrass, delay, or burden a third person, by conduct including,but not limited to, sending emails and filing pleadings accusingLubin of extortion, and by filing pleadings stating that Szczesniakhad damaged a witness' fence, had a history of fabricating reports,

13

ANSWER:

and had no son named Luke, in violation of Rule 4.4 of the IllinoisRules of Professional Conduct (2010); and

conduct prejudicial to the administration of justice, by conductincluding, but not limited to, filing pleadings containing baselessaccusations of wrongdoing against Lubin and Szczesniak, andcausing a degradation of process in case number 16 cv 4182 byignoring multiple warnings of the court thereby challenging thecourt's judicial authority, in violation of Rule 8.4(d) of the IllinoisRules of Professional Conduct (2010).

Respondent denies the allegations contained in Paragraph 28 (a) through (c) of

Count I of the Complaint.

COUNT II

(Failure to abide by client's directives and disclosing confidential information - Gamon)

29. At all times alleged in Count II of this complaint, the Attorneys Lien Act,770 ILCS 5, provided, in part:

[a]ttorneys shall serve notice in writing, which service may be made byregistered or certified mail, upon the party against whom their clients mayhave suits, claims or causes of action, claiming such lien and statingtherein the interest they have in such suits, claim, demands or causes ofaction.

ANSWER:

Respondent admits the allegations contained in Paragraph 29 of Count II of the

Complaint.

30. On September 11, 2014, Respondent and Terry Johnson ("Johnson"),President of Gamon Plus, Inc. and Gamon International, Inc. ("Gamon"), agreed thatRespondent and attorney Andrew Tiajoloff ("Tiajoloff') would represent Gamon in alawsuit against Campbell Soup Company, Inc., and others for patent infringement.Respondent and Johnson agreed that Respondent and Tiajoloff would receive 40% ofany recovery in the matter.

ANSWER:


Complaint.

14

31. On January 23, 2015, Gamon, Respondent, and Tiajoloff entered into asupplemental retainer agreement with the law firm Niro, McAndrews, Dowell, &Grossman, LLC ("Niro McAndrews"), because of the firm's experience with patentlitigation. Pursuant to the January 23, 2015 supplemental retainer agreement, NiroMcAndrews would receive 25% of any recovery in the matter, and Respondent andTiajoloff would each receive 7.5% of any recovery in the matter. Attorneys RaymondNiro, Jr. ("Niro"), Kyle Wallenberg ("Wallenberg"), and Matthew McAndrews("McAndrews") were the attorneys from Niro McAndrews responsible for handling theGamon matter.

ANSWER:

Respondent admits that an Attorney Fee Agreement was entered into on January

23, 2015, for a contingency fee in the event of a successful recovery from the

defendant, but further states that the allegations contained in paragraph 31 of

Count II of the Complaint are denied as they do not accurately represent the

terms of the agreement, which specifically confirms and incorporates the fee

agreement of January 6, 2015, and further provides that it was the Respondent,

Tiajoloff and Gamon who were employing the law firm of Niro, McAndrews, Dowell

& Grossman under the terms of the January 6, 2015 fee agreement. Further, the

Respondent neither admits or denies the allegation that attorneys Niro,

Wellenberg and McAndrews were the attorneys responsible for handling the

Gamon matters for Niro McAndrews as Respondent does not have the knowledge

to either admit nor deny this allegation.

32. On October 8, 2015, Niro filed a complaint in the Northern District ofIllinois on behalf of Gamon. The matter was docketed as Gamon Plus, Inc. et al. v.Campbell Soup Company, et al., and assigned case number 15-cv-8940.

ANSWER:


Complaint.

15

33. On October 8, 2015, Niro, Wallenberg, and McAndrews filed theirappearances as counsel for Gamon in case number 15-cv-8940. On October 9, 2015,Respondent filed his appearance on behalf of Gamon.

ANSWER:


Complaint, except to add that Respondent's name was also on the complaint as

one of the attorneys for Gamon that was filed on October 8, 2015.

34. During the course of representing Gamon, Respondent learned of andparticipated in confidential negotiations between Gamon and a third-party litigationfunding company (hereinafter "TPLF") regarding Gamon financing its legal costs relatedto case number 15-cv-8940 through TPLF. On February 8, 2016, Gamon and TPLFexecuted a written term sheet setting forth the binding terms to which Gamon and TPLFagreed, subject to the completion of a more comprehensive written agreement.Respondent became aware of the terms of the parties' agreement between Gamon andTPLF shortly thereafter.

ANSWER:

Respondent admits that he was aware of negotiations by Gamon for third-party

financing for litigation costs only, not attorney fees, as alleged in Paragraph 34

of Count II of the Complaint, and further answering admits that Respondent

learned of negotiations being conducted by Niro McAndrews with a third-party lender

for advance payment of hourly attorney fees for Niro McAndrews even though Niro

McAndrews was not entitled to any hourly fees. Respondent further admits that at some

point Respondent became aware that Niro McAndrews had attempted to cause Gamon

to enter into a Term Sheet with a third-party lender which called for advance payment of

$600,000 in hourly attorney fees (including an immediate payment of $150,000 of

unearned hourly fees) to Niro McAndrews even though Niro McAndrews was not

entitled to any hourly fees, at a rate to Gamon of up to 100% plus 20% of any recovery.

Respondent also admits that at some point he did become aware of the fact that Gamon

16

did enter into a term sheet. Respondent denies the remaining allegations of paragraph

34.

35. On January 21, 2015, TPLF and McAndrews entered in to a confidentialityand non-disclosure agreement with respect to the litigation funding negotiations andprospective financing agreement between TPLF and Gamon. Shortly thereafter,McAndrews communicated the nature of the confidentiality and non-disclosureagreement to Respondent.

ANSWER:

Respondent neither admits nor denies that Niro McAndrews entered into a

confidentiality and non-disclosure agreement with a third-party lender on January

21, 2015 and denies that shortly thereafter Niro McAndrews communicated the

nature of the confidentiality and non-disclosure agreement to Respondent as

alleged in Paragraph 35 of Count II of the Complaint.

36. On February 10, 2016 at 10:29 am, Johnson sent Respondent an emailthat "instructed [him to] immediately withdraw as counsel of record in the litigation," andfurther stated that Respondent would receive the previously agreed to share of anyjudgment. Respondent received Johnson's email within ten minutes of it being sent.

ANSWER:


Complaint.

37. On February 10, 2016 at 10:35 am, Niro sent an email to Lisa Ferrari andRespondent, notifying Ferrari that Respondent had been terminated as counsel andinstructed to withdraw from the case immediately. Respondent received Niro's emailwithin ten minutes of it being sent.

ANSWER:


Complaint, and further answering, neither admits nor denies Respondent

17

received it within ten minutes of the email being sent.

38. On February 10, 2016 at 10:41 am, Respondent sent an email to Johnsonstating that he would not withdraw until he received a written agreement signed by allattorneys and clients in the matter stating that Respondent would receive his agreedupon 7.5% of the proceeds. Respondent ended the email by asking Johnson if hisproposal was agreeable. At no time did Johnson respond to Respondent's February 10,2016 at 10:41 am email, nor did Johnson agree to allow Respondent to delaywithdrawing as Gamon's attorney until he received a written confirmation of the feeagreement signed by all parties.

ANSWER:

Respondent denies that he sent an email to Johnson on February 10, 2016 at

10:41 a.m. as he has no record of any email sent to Johnson on that date and

time, however Respondent did send an email in which Johnson was one of six

recipients on February 10, 2016 at 1:42 p.m. in which he stated that a motion to

withdraw would be filed "when I am secured in my right with the appropriate lien

and signed documents". Respondent further states that this email was sent

stating that this would be accomplished within a week, and that the motion to

withdraw would then be filed, and further that the Respondent filed his statutory

attorneys lien, which lien rights were also provided for in the parties fee

agreement, on February 10, 2016, and sent out the notice as required by the

statute on the same date.

39. At 10:42 am on February 10, 2016, Respondent sent an email to Ferrari inresponse to Niro's 10:35 am email described in paragraph 37, above, stating that hewas "not out yet" and that he would inform Ferrari when he filed a motion to withdraw.

ANSWER:

Respondent admits the allegations contained in paragraph 39 of Count II of the

complaint.

18

40. At 10:43 am on February 10, 2016, Niro sent an email to Respondentasking him to comply with Gamon's instructions to "immediately withdraw as counsel inthe litigation." Though Respondent received Niro's 10:43 am email, as of February 14,2016 Respondent had not complied with Johnson's request to immediately withdraw ascounsel for Gamon.

ANSWER:


Complaint, and further states that on February 11, 2016 (the next day), the

Respondent sent an email to Niro McAndrews and Johnson that he would be filing

a Motion to Withdraw on Tuesday of the next week (four (4) business days away).

Rather than wait this short period Niro filed a motion to remove Respondent as

attorney on Thursday February 11, 2016, which was to be presented to the Court

as an emergency on Friday February 12, 2016, and which the Court continued the

motion to February 19*. Because Niro filed his motion to remove Respondent as

attorney, it was unnecessary for Respondent to file a motion to withdraw.

41. On February 10, 2016, after Respondent received Johnson's email askingRespondent to withdraw, Respondent filed what purported to be an attorney lien tosecure his fees in case number 15cv8940 that purported to be filed "on behalf of allplaintiffs." Respondent caused his attorney's lien to be served upon TPLF, as well asJohnson, the opposing attorneys, and the registered agents for the Campbell Soup,Meijer, Trinity Manufacturing, and Kroger Co.

ANSWER:


Complaint, except to deny that the lien was filed on behalf of all Plaintiffs.

42. Respondent's purported attorney lien was improper and untimely becauseat the time that Respondent filed it, he had already been terminated. In addition,Respondent's purported attorney lien was improper because TPLF was not a partyagainst whom a litigant had made a claim, and therefore, TPLF was not an appropriate

19

or necessary entity upon whom to serve a lien, pursuant to the Attorney Lien Act,described in paragraph 29, above.

ANSWER:

Respondent denies the allegations contained in Paragraph 42 of Count II of the

Complaint.

43. By serving the lien on TPLF, Respondent revealed the fact of Gamon'snegotiations with TPLF to opposing counsel and to the public, thereby alerting opposingcounsel to the fact that Gamon had sought funding from TPLF, and therefore may beeager to settle because Gamon did not have had sufficient assets to engage in lengthylitigation.

ANSWER:


Complaint.

44. On February 10, 2016, shortly after noon, TPLF emailed McAndrews andNiro asking them to call immediately because Respondent had filed a pleading withTPLF on the service list.

ANSWER:

Respondent neither admits nor denies the allegations contained in Paragraph 44

of Count II of the Complaint due to insufficient knowledge to do so.

45. On February 10, 2016 at 12:41 pm, Niro sent an email to Respondentnotifying him that his lien disclosed to opposing counsel and the public informationcovered by the attorney-client privilege and work product immunity and asked him towithdraw the lien and the service list from the public record. Though Respondentreceived Niro's February 10, 2016 email sent at 12:41 pm, at no time did Respondenttake action to withdraw the lien or service list from the public record.

ANSWER:


Complaint but denies that the allegations regarding the disclosure of attorney-

20

client privilege and work product were accurate.

46. On February 11, 2016, Niro sent Respondent an email requesting thatRespondent "return any and all documents, electronic information, electronic media,and any work product or other information or documents [Respondent had]" within 24hours. Though Respondent received Niro's email shortly thereafter, at no time didRespondent return the requested documents and other information to Gamon or Niro.

ANSWER:


complaint, except to deny that he had any materials except his copies of the

materials he obtained during his representation of Gamon.

47. As of February 11, 2016, Respondent had not withdrawn as counsel forGamon as requested. On that same date, Gamon filed an emergency motion toterminate Respondent as counsel for Gamon and to remove Respondent as counsel ofrecord in case number 15-cv-8940.

ANSWER:


Complaint but further states that on February 11, 2016 Respondent sent an email

to Niro McAndrews and Johnson that he would be filing a Motion to Withdraw on

Tuesday of the next week (four (4) business days away), and further stating that

there was no emergency which required Respondent to file his motion to

withdraw on an emergency basis.

48. On February 14, 2016, Respondent filed a motion in case number15cv8940, purportedly on behalf of Gamon, seeking to disqualify Niro McAndrews fromrepresenting Gamon due to a purported conflict of interest. At no time did Johnson giveRespondent authority to file the February 14, 2016 motion seeking to disqualify Niro andMcAndrews, nor did Johnson give Respondent any authority to take any action onbehalf of Gamon after February 10, 2016. At the time that Respondent filed his motionseeking to disqualify Niro McAndrews, Respondent's services had been terminated, and

21

therefore, he had no authority to do anything on behalf of Gamon except seek towithdraw.

ANSWER:

Respondent admits that he filed a motion in case 15 cv 8940 seeking to disqualify

Niro McAndrews on February 14, 2016, and denies the remainder of paragraph

48 of Count II of the Complaint.

49. In his motion to disqualify Niro McAndrews, Respondent falsely accusedthe firm of illegally attempting to obtain a commission or kickback from TPLF, andRespondent revealed confidential information relating to the representation of Gamon,including the following:

Prior to even seeking additional counsel, Attorney Brodsky and Attorney Tiajoloffprovided the information for, worked with, and obtained from patent Attorney David L.Applegate (of the IP practice group of Williams, Montgomery & John), a fifty-three (53)page "Overview of Potential Litigation Strategies," which was supported by over fivehundred (500) pages of exhibits. The purpose of obtaining this document was to obtainan independent analysis of the strength of Gamon's case, know what defenses werelikely to be presented (if any) and analyze how to best present the case, and defendagainst any defenses. A tremendous amount of work was done by Attorney Brodskyand Attorney Tiajoloff, (tantamount to preparing the case for trial), went [sic] intoproducing this document. Therefore, when Attorney Brodsky first (and later AttorneyTiajoloff) met with Mr. Niro and Mr. McAndrews they knew that when the final patentissued involving the invention at issue in the above referenced litigation, that Gamonhad an extremely strong patent infringement case, with damages in many tens ofmillions of dollars, if not more.

ANSWER:

Respondent admits that the motion to disqualify accused Niro McAndrews of

attempting to illegally obtain a commission or kickback from the third-party lender,

but denies that this accusation was false, or was not based upon a reasonable

inference based on the evidence, and denies that the information revealed in the

motion to disqualify was confidential as alleged in Paragraph 49 of Count II of

the Complaint.

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50. On February 14, 2016, Respondent also filed a response to Gamon'semergency motion to terminate Respondent as counsel for Gamon, described inparagraph, 47, above. Respondent attached an affidavit to his response that disclosedthe nature of the fee agreement between Gamon and Niro McAndrews and disclosedthe content of purported conversations that Respondent had with Johnson andpurported conversations between Mr. Johnson and Niro and McAndrews.

ANSWER:


complaint, but further states that the matters discussed in the response and

attached affidavit were in response to false allegations made by Niro McAndrews

in their motion and the attached affidavit, to which Respondent had a right to

respond, and were also made under Respondent's ethical responsibilities.

51. On February 16, 2016, Gamon filed a motion requesting an order sealingRespondent's motion to disqualify and Response to Gamon's emergency motion toterminate Respondent as counsel due to the fact that both pleadings revealedconfidential business information and communications and information subject to theattorney-client privilege and work product immunity.

ANSWER:


complaint, except to deny that the pleadings revealed confidential business

information, or communications and information subject to the attorney-client

privilege and work product immunity.

52. On February 17, 2016, Respondent filed a response objecting to Gamon'smotion requesting an order sealing Respondent's motion to disqualify and Response toGamon's emergency motion. In his February 17, 2016 response, Respondent againaccused Niro McAndrews of attempting to obtain an illegal kickback from TPLF andattempting to cover up the illegal kickback by sealing Respondent's pleadings.

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ANSWER:


complaint, except to deny that anything in the response filed by Respondent was

false or was not based upon a reasonable inference based on the evidence.

53. On February 19, 2016, the Honorable Charles R. Norgle, Sr. held ahearing on Gamon's motion to terminate Respondent as counsel for Gamon, describedin paragraph 47, above. On that date, Judge Norgle entered an order granting Gamon'smotion to terminate Respondent as counsel for Gamon. Judge Norgle's February 19,2016 order also granted Gamon's motion to seal Respondent's motion to disqualify NiroMcAndrews and to seal Respondenfs Response to "Emergency" Motion to Terminate[Respondent] as Counsel for Plaintiffs, described in paragraphs 48 and 50, above. Inaddition, Judge Norgle's February 19, 2016 order granted Gamon's motion to sealRespondenfs response to Gamon's motion to seal.

ANSWER:


Complaint, and further answering, states that Judge Norgle did not make any

findings, or state the reason he entered the orders.

54. On February 19, 2016, McAndrews sent Respondent a letter, againrequesting that Respondent return to Gamon any of Gamon's documents or electronicfiles that were in Respondenfs possession. As of February 22, 2016, Respondent hadnot returned Gamon's property. On that date, Niro sent Respondent an email, againrequesting that he return Gamon's business documents. Respondent receivedMcAndrews' February 19, 2016 email and Niro's February 22, 2016 email shortly afterthey were sent.

ANSWER:


Complaint, except to deny that the request of February 19, 2016 asked for

anything except for the copies that Respondent had.

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55. On February 24, 2016, Gamon filed a motion to strike, or in the alternative,seal Respondenfs notice of attorney lien, as described in paragraph 41, above, statingthat the lien had been filed without Gammon's authorization, and stating that the liendivulged to opposing counsel Gamon's confidential business information.

ANSWER:


Complaint, but further states that the motion was entitled "Unopposed Motion to

Strike or In the Alternative Seal...", and no copy of the motion was served on

Respondent even though the motion was intended to affect his rights.

56. On that same date, TPLF informed McAndrews that, due to Respondenfspublic disclosure of the fact of the relationship between TPLF and Gamon, TPLF wouldnot continue funding negotiations in the Gamon matter.

ANSWER:

Respondent neither admits nor denies the allegations contained in Paragraph 56

of Count II of the Complaint due to insufficient knowledge of the communications

referenced therein.

57. On February 25, 2016, Judge Norgle entered an order granting Gamon'smotion to strike Respondenfs notice of attorney's lien, as described in paragraph 55,above.

ANSWER:


Complaint, and further answering, states that all Judge Norgle's order did is grant

the unopposed motion, for which no notice had been sent to Respondent.

58. As of July 25, 2018, the date that this matter was voted by the InquiryBoard, Respondent had not returned Gamon's documents and electronic files.

25

ANSWER:


Complaint, and further answering adds that Respondent was under no obligation

to return the copies in his possession.


a. failing to abide by a client's decisions concerning the objectives ofrepresentation, by conduct including, but not limited to, failing to withdrawfrom representing Gamon upon request and filing a motion to disqualifyGamon's other attorney's without direction or authority to do so fromGamon, in violation of Rule 1.2 of the Illinois Rules of ProfessionalConduct (2010);

b. revealing information relating to the representation of a client without theclient's informed consent, by conduct including, but not limited to,disclosing the relationship between Gamon and TPLF, in violation of Rule1.6 of the Illinois Rules of Professional Conduct (2010);

c. failing to withdraw from representation after being discharged, by conductincluding, but not limited to, failing to withdraw immediately upon theGamon's request and by holding himself out as Gamon's attorney by filingpleadings purportedly on behalf of Gamon after being discharged, inviolation of Rule 1.16(a)(3) of the Illinois Rules of Professional Conduct(2010); and

d. Failure to promptly surrender papers and property to which the client isentitled upon termination of representation, by conduct including, but notlimited to, failing to return Gamon's documents and electronic files afterrequested to do so, in violation of Rule 1.16(d) of the Illinois Rules ofProfessional Conduct (2010).

ANSWER:

Respondent denies the allegations contained in Paragraph 59 (a) through (d) of

Count II of the Complaint.

COUNT III

{Using means that have no substantial purpose other than to embarrass, delay, orburden third persons and disclosing confidential information- Fanady)

60. At all times alleged in Count III of this Complaint, Section 110/3 of theMental Health and Developmental Disabilities Confidentiality Act, 740 ILCS 110/3,provided:

26

a) All records and communications shall be confidential and shall not bedisclosed except as provided in this Act. Unless otherwise expresslyprovided for in this Act, records and communications made or created inthe course of providing mental health or developmental disabilitiesservices shall be protected from disclosure regardless of whether therecords and communications are made or created in the course of atherapeutic relationship.

ANSWER:

Respondent admits the allegations contained in Paragraph 60 of Count III of the

Complaint, and further answering states this is only a part of the said Act.

61. Section110/2 of the Mental Health and Developmental DisabilitiesConfidentiality Act defines "Confidential Communication" or "communication" as:

Any communication made by a recipient or other person to a therapist orto or in the presence of other persons during or in connection withproviding mental health or developmental disability services to a recipient.

ANSWER:


Complaint, and further answering states this is only a part of the said Act.

62. In or about November 2016, Respondent and S.F. agreed thatRespondent would represent S.F. in matters relating to the dissolution of his marriage toG.F., Cook County Circuit Court case number 2016 D XXXXXX, In re the Marriage ofG.F. and S.F. Respondent and S.F. agreed that S.F. would pay Respondent $300 perhour for his work in relation to case number 2016 D 230507.

ANSWER:


Complaint.

63. In or about December 2016, S.F. and G.F. agreed to attend counseling toassist them with co-parenting their minor child.

ANSWER:

Respondent denies the allegations contained in Paragraph 63 of Count III of the

27

Complaint but admits that they agreed to meet with Dr. Steingraber to assist them

in working out a joint-parenting agreement.

64. On December 12, 2016, G.F.'s attorney, John Kay, sent Respondent anemail stating that a psychologist named Dr. Karla Steingraber had agreed to assist S.F.and G.F. with co-parenting, and seeking to confirm with Respondent that Dr.Steingraber would be "utilized for counseling purposed only in this case and that sheshall not be called as a witness or otherwise used for any litigation purpose."

ANSWER:

Respondent admits that an email was sent which contains the language quoted

but denies that Paragraph 64 of Count III of the Complaint quotes the entire email,

and therefore the part of the email quoted in Paragraph 64 is taken out of context.

65. Later on December 12, 2016, Respondent sent an email to Kay stating"[w]e agree that Dr. Steingraber is not to be called as a witness or otherwise used forany litigation purpose."

ANSWER:

Respondent admits that an email was sent which contains the language quoted

but denies that paragraph 65 of Count III of the Complaint quotes the entire

email, and therefore the part of the email quoted in paragraph 65 is taken out of

context.

66. On or about December 14, 2016, S.F. and G.F. attended their firstappointment with Dr. Steingraber. During the course of S.F. and G.F.'s appointmentswith Dr. Steingraber, the parties discussed terms of a parenting agreement and theyentered into a preliminary parenting agreement.

ANSWER:


Complaint.

28

67. On December 21, 2016, Dr. Steingraber sent an email to S.F. and G.F.memorializing the terms discussed during their counseling session that would lead tosuccessful co-parenting. The email asked S.F. and G.F. to contact Dr. Steingraber if theterms she outlined did not fit with their understanding. Some of the co-parenting termsoutlined in Dr. Steingraber's email included communication with both parents, handlingof health and medical information and decisions, and the time for certain holiday pickups.

ANSWER:

Respondent admits that on December 21, 2016 Dr. Steingraber sent an email to

SF and GF memorializing the terms of their co-parenting agreement, and admits

that the email stated in part that they should contact her if the terms did not fit

with their understanding, but denies that the sessions with Dr. Steingraber were

counseling sessions, and further states that neither SF or GF ever contacted Dr.

Steingraber to state that the terms in the email did not fit their understanding of

their agreement as alleged in Paragraph 67 of Count III of the Complaint.

68. At the end of Dr. Steingraber's December 21, 2016 email, it stated:

Notice: The information contained in this e-mail is confidential informationintended only for the use of the individual(s) named above. If the reader ofthis message is NOT the intended recipient, you are hereby notified thatany dissemination, distribution or retention of these materials is illegal.Please do not read, copy, or let anyone else see these materials if sent toyou in error. Delete the materials completely and call or email me back atthe number listed above for appointments to identify the error involved inyour receipt of this correspondence.

ANSWER:

Respondent admits the allegations in paragraph 68 of Count III of the complaint

that Dr. Steingraber's email contained the boiler plate language quoted but

denies that what is in the complaint is legally correct or binding on the

Respondent.

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69. On or before December 23, 2016, S.F. forwarded a copy of Dr.Steinberger's December 21, 2016 email to Respondent.

ANSWER:


Complaint.

70. On January 10, 2017, Respondent filed a motion on behalf of S.F. entitled"Motion of S.F. to Continue and Expand Visitation, to Adopt Parties AgreementRegarding Parenting as the Order of this Court, and for Other Relief."

ANSWER:


Complaint.

71. Respondenfs motion disclosed that S.F. and G.F. had entered intocounseling with Dr. Steingraber, attached a copy of Dr. Steingraber's December 21,2016 email to S.F. and G.F., which outlined preliminary terms of successful co-parenting discussed during counseling, and sought to have the court adopt the termsoutlined in Dr. Steingraber's email.

ANSWER:

Respondent denies the allegations contained in paragraph 71 of Count III of the

complaint because the parties were not in counseling andthe parties reached a

full agreement regarding an interim parenting agreement, but admits that the

motion asked the court to adopt the agreement of the parties for co-parenting.

72. Respondenfs actions in referencing and attaching Dr. Steingraber's email,which outlined the terms of co-parenting discussed by S.F. and G.F. when incounseling, to his motion violated the agreement that the parties had reached via theemails described in paragraphs 64 and 65, above, that Dr. Steingraber would not beused for any litigation purpose. Respondenfs actions in referencing and attaching Dr.Steingraber's email to Respondenfs January 10, 2017 motion also violated Section110/3 of the Mental Health and Developmental Disabilities Confidentiality Act, asdescribed in paragraphs 60 and 61, above, because Respondent disclosed records of

30

confidential communications made or created in the course of Dr. Steingraber providingmental health services without G.F.'s consent.

ANSWER:


Complaint.

73. On August 23, 2017, Respondent sent an email to opposing counsel, andcopied it to S.F., G.F., and various personnel in the two school districts in which S.F andG.F's child could have attended school. The email stated that G.F. was "very mentallysick" and stating the "the psychiatric report that [the custody evaluator was] writing[would] confirm that." The email also stated that the following:

[G.F.'s] actions are the sign of someone who is pathologically obsessedwith having to have things her way, and will stop at nothing, who will lie,mislead, and fabricate, to achieve that end. Her other actions in thedivorce case, her starting the case with false allegations in an ex-partepetition for order of protection which was thrown out of court, her falsestatements about the child representative Judge Bender, her falsestatements about her not making agreements that she clearly made, herfalse statements about property ownership, her attempt at stealing$180,000 in corporate money that did not belong to her or [S.F.] (andunfortunately I could go on and on and on) show that [G.F.] doesn't careabout the consequences of her actions no matter who his [sic] hurt, even ifit is her own [child]. [G.F.] is mentally ill and needs serious help. This is afact that anyone can, and does, see, not conjecture.

ANSWER:

Respondent admits that he sent an email which contained the language quoted

in paragraph 73 of Count III of the complaint but denies he knowingly copied GF

on that email. Respondent further states that the quotation in Paragraph 73 of the

complaint does not state all of what was said in his email, and further states that

the email of August 23, 2017, was sent in response to an email sent by GF's

attorney one hour earlier on August 23, 2017, which was sent to Respondent, GF

and the various personnel in two school districts, which made several false

31

disparaging remarks regarding Respondent, SF, and also made other false

statements, including false statements regarding the school placement of SF

and GF's child.

74. At the time that Respondent copied his August 23, 2017 email to G.F.,Respondent knew that G.F. was represented by counsel in relation to case number2016 D230507.

ANSWER:


Complaint but denies that he knowingly copied GF on the email he sent on

August 23, 2017.

75. Respondenfs actions in sending his August 23, 2017 email to opposingcounsel, G.F., and the school district employees had no substantial purpose other thanto embarrass or harass G.F.

ANSWER:


Complaint.


a. communicating with a person known to be represented by counsel aboutthe subject of the representation, in violation of Rule 4.2 of the IllinoisRules of Professional Conduct (2010), by conduct including, but notlimited to, sending an email to G.F. regarding her actions in registering herminor child for school in District 28;

b. using means that have no substantial purpose other than to embarrass,delay, or burden a third person, by conduct including, but not limited to,sending an email to school officials in two school districts stating that G.F.was "very mentally sick" and in need of "serious help," in violation of Rule4.4 of the Illinois Rules of Professional Conduct (2010); and

c. committing a criminal act that reflects adversely on the lawyer's honesty,trustworthiness, or fitness as a lawyer in other respects by disclosing

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* <• *

confidential information (preliminary parenting agreement) made inconnection with receiving mental health services in violation of Section110/3 of the Mental Health and Developmental Disabilities ConfidentialityAct, 740 ILCS 110/3, in violation of Rule 8.4(b) of the Illinois Rules ofProfessional Conduct (2010).

ANSWER:

Respondent denies the allegations contained in Paragraph 76 (a) through (c) of

Count III of the Complaint.

WHEREFORE, the Respondent requests that the Complaint be dismissed.

Respectfully submitted.

SAMUEL J. MANELLA, Attorney for Respondent

SAMUEL J. MANELLA

ATTORNEY FOR RESPONDENT77 WEST WASHINGTON STREET

SUITE 705

CHICAGO, ILLINOIS 60602(708) [email protected]

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