STATEMENT OF CHARGES PURSUANT TO
SUPREME COURT RULE 762(a)

Jerome Larkin, Administrator of the Attorney Registration and Disciplinary Commission, by his attorney Scott Renfroe, pursuant to Supreme Court Rule 762(a), states that on the date Brian L. Hopkinson (hereinafter "Movant") filed a motion requesting that his name be stricken from the Roll of Attorneys, a one-count complaint was pending before the Hearing Board charging Movant with defrauding investors of more than $540,000. Had Movant’s conduct been the subject of a hearing, the Administrator would have introduced the evidence described below, and that evidence would have clearly and convincingly established the following conclusions of misconduct:

Movant’s admissions, testimony from former investors, and various court and bank records would have established the following facts:

1. Beginning in or around December 1998, and continuing through May 2007, Movant advised his friends, acquaintances, clients and family members ("the investors") of a purported opportunity to invest their savings in a company called Dental Venture Capital Company ("DVCC"), of which Movant was President. Movant told the investors, both orally and in writing: that he would use the investors’ money to finance the purchases of dental practices and other health-care related entities; that they could expect an annual return of approximately

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nine-and-one-half percent (9.5%) on any money they invested through DVCC; and that their investments would be secured by an interest in the tangible assets and the accounts receivable of the health-care practices that were financed through DVCC.

2. Movant’s statements to the investors, described in paragraph one, above, were false. In fact, Movant intended to use, and did use, the investors’ money for his own purposes: there were no actual purchasers of health-care practices, the investors’ money was not used to fund any such purchases, and their purported investments were not secured by any interest in assets or receivables of dental or health-care practices, or by anything else.

3. Between 1998 and June 27, 2007, Movant obtained several million dollars from the investors, provided many of those individuals with purported promissory notes from DVCC relating to nonexistent funding transactions, and promised to repay the investors in a series of installment payments. During the period between June 1, 2002, and June 27, 2007, Movant deposited $4,519,530.19 of the investors’ money into an account, number 1207393, at the Northern Trust Company in Park Ridge. That account was entitled "Dental Venture Capital Company," and Movant used the account to pay his personal obligations, including credit card account balances, and to make periodic payments of purported interest and principal to the investors. Those payments, though, were not made from the purported profits DVCC obtained from financing the acquisition of health-care practices, but were instead made with money obtained from other investors in what is commonly referred to as a "Ponzi scheme."

4. As of June 27, 2007, Northern Trust account number 1207393 was overdrawn by $1,171.44. At that time, Movant owed at least $540,734.32 to various investors.

5. Between 1998 and 2007, in order to keep his Ponzi scheme from collapsing, Movant recruited additional investors, or obtained additional funds from previous investors. In

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doing so, Movant made false statements concerning DVCC’s purported activities and financial condition. For example, in a June 3, 2002 memorandum to "All DVCC Investors," Movant wrote:

Dear Investors:

Thank you for your support since I did my first program in December, 1998. DVCC has gotten to the point where there are 2-3 requests for funds per month. I am establishing, on average, only one program per month. More typically, it is one program every six weeks.

I am sending this brief note to you to gauge your interest in the upcoming programs I anticipate funding. I have one program that is scheduled for July 1, 2002. There is a need for investment to fund that program. Also, I anticipate funding a program on July 26^th and August 16^th. Both programs have a need for investment. If you are interested let me know and I will secure you investment.

The universe from which I draw my investments is an ever-shrinking one. If there is someone you might recommend, please let me know and I will forward information to them. If your referral does invest, I will send you a finder’s fee of $500.

Again, thank you for the opportunity to be of service to you. We live in a very fragile investment environment, but DVCC is rock solid!

Thanks again…

Brian Hopkinson

6. As an additional part of his scheme to defraud the investors, Movant wrote another letter to the investors, dated March, 2004, in which he described fictitious transactions and upcoming investment possibilities. The letter stated:

March, 2004

First, let me thank you for being an investor in Dental Venture Capital Company (DVCC). Your investments continue to pay monthly principal and interest returns.

Since 1999, I have put together 8 to 10 transactions per year for investors. At present, I have 2 transactions that require funding and 2 more that I am

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ready to begin work on. If I had the funds, I would be able to close both transactions immediately. For both the transactions that presently need funding, I require investments of $100,000 per transaction. The other 2 would also require $100,000 each.

As the number of transactions I have increases, the universe of investors decreases. That is why I am writing you. If you have an interest in investing $25,000, $50,000 or $100,000, that would help to fund a transaction. If you would consider referring someone for investment, that would be greatly appreciated. Presently, the rate of return for my investors is 9 ½%. A $25,000 investment would yield a $628.08 monthly pay-out. Of course, the investment would be fully returned in 4 years!

If you were to consider investing thru a qualified plan (self directed Keogh, IRA or corporate plan) the tax-effected yield would be 15.8% (assuming a combined 40% tax bracket). There are not many ‘secured’ investments with that kind of pre-tax yield. On an individual basis, the after-tax yield is 5.7%

Sincerely

Brian L. Hopkinson

7. On June 28, 2006, Movant sent an additional letter to the investors in which he described fictitious transactions and upcoming investment possibilities. The letter stated:

28 June 2006

DEAR INVESTORS:

LET ME BEGIN BY SAYING "THANK YOU" FOR YOUR SUPPORT AND ENCOURAGEMENT THROUGH THE YEARS. I FORMED DVCC IN DECEMBER 1998. WITH YOUR SUPPORT, I HAVE FUNDED OVER 75 TRANSACTIONS. CURRENTLY, I HAVE 43 TRANSACTIONS IN "ACTIVE’ STATUS – WITH OVER $8.0 MILLION CURRENTLY DUE TO INVESTORS.

UNFORTUNATELY, DVCC’S SUCCESS HAS NOT COME WITHOUT DIFFICULTY, FINDING INVESTORS TO FUND TRANSACTIONS IS A CONSTANT BATTLE!

AT PRESENT, I HAVE 4 TRANSACTIONS THAT REQUIRE FUNDING. IT IS IMPERATIVE THAT THESE GET FUNDED ASAP!

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COMPETITORS HAVE ENTERED THE MARKETPLACE AND MY INABILITY TO FUND COULD PROVE TO BE MY UNDOING!

I NEED YOUR HELP. IF YOU ARE INTERESTED IN INVESTING FUNDS, PLEASE CONTACT ME IMMEDIATELY. MORE IMPORTANTLY, I NEED YOU TO REFER DVCC TO YOUR FAMILY, FRIENDS, BUSINESS COLLEAGUES, AND PROFESSIONAL ACQUAINTANCES. NEW BUSINESS IS THE LIFEBLOOD OF SUCCESS!!

INCLUDED HEREWITH IS THE DVCC ‘MARKETING BROCHURE’. REVIEW IT AND FEEL FREE TO PASS IT ALONG! SINCE 1999 I HAVE BEEN ABLE TO OFFER MY INVESTORS A BETTER THAN MARKET RATE OF RETURN (CURRENTLY 9.5%) AND A RELATIVELY SECURE INVESTMENT.

IF YOU ARE INTERESTED, OR IF YOU KNOW OF SOMEONE WHO MAY BE INTERESTED, PLEASE CONTACT ME, OR HAVE THEM CONTACT ME.

AGAIN, I AM LOOKING FOR ADDITIONAL INVESTORS. IF YOU ARE INTERESTED, PLEASE LET ME KNOW!

THANK YOU

BRIAN L. HOPKINSON

PRESIDENT

8. Movant ’s statements to the investors, set forth in paragraphs five, six, and seven, above, were false, and were known by Movant to be false, in at least the following ways: there were no "programs" being funded by DVCC; DVCC was not "rock solid"; the purported investments were not paying "monthly principal and interest returns"; and there had not been any transaction, let alone either "8 to 10 investments per year" since 1999, "over 75 transactions[,]" or "43 transactions in ‘active status…’".

9. In or around May of 2007, Movant’s Ponzi scheme collapsed as Movant was unable to continue to make payments of purported interest and principal to the investors. After initially fleeing to Ireland, Movant returned to the United States and, on or about July 1, 2007,

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sent a letter to the investors in which he admitted: that any purported promissory notes issued on behalf of DVCC were worthless; that he was in default on his obligations to the investors; and that he had taken advantage of their confidence in him.

10. As of the filing of this Statement of Charges, Movant owed various investors a total of at least $540,000, which represented the difference between the amounts he had received from them to invest through DVCC and the amounts he had repaid them as part of his efforts to keep the Ponzi scheme afloat.

II. CONCLUSIONS OF MISCONDUCT

11. By the reason of the conduct described above, Movant has engaged in the following misconduct:

1. conduct involving dishonesty, fraud, deceit or misrepresentation, in violation of Rule 8.4(a)(4) of the Illinois Rules of Professional Conduct;

2. conduct that is prejudicial to the administration of justice, in violation of Rule 8.4(a)(5) of the Illinois Rules of Professional Conduct; and

3. conduct which tends to defeat the administration of justice or bring the courts or the legal profession into disrepute, in violation of Supreme Court Rule 770.