Jerome Larkin, Administrator of the Attorney Registration and Disciplinary Commission, by his attorney Tracy L. Kepler, states that on the date Movant signed a motion pursuant to Supreme Court Rule 762(a) requesting that her name be stricken from the Roll of Attorneys admitted to practice law in this state, there was pending before the Commission’s Hearing Board a six-count complaint against her. If the charges in the pending complaint were the subject of a hearing, the following evidence would be presented and would clearly and convincingly support the conclusions of misconduct set forth below:

1. Movant’s admissions, bank records obtained from W2X, Inc.’s corporate account at LaSalle Bank, bank records obtained from D’Mona Ross’ personal account at Bank of America, bank records obtained from RYM Technology Holdings, LLC’s corporate account at National City Bank, bank records obtained from IJCN Investments’ corporate account at Bank of America, records obtained from Movant’s client files, the Illinois Attorney General’s office, the Illinois Secretary of State, the Illinois Department of Financial & Professional Regulation, the Cook County Recorder of Deeds, American Home Mortgage Corporation, American Brokers

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Conduit, Fremont Investment & Loan, First American Title Insurance Company, Amtrust Funding, Lawyers Title Insurance Company, Chicago Title Land Trust Company, Harris Trust & Savings Bank, Argent Mortgage Company, IJCN Investments, pleadings submitted before the Circuit Court of Cook County in case nos. 06 CH 15839, Hatchett v. W2X Inc., et al., 06 CH 9240, Fremont Investment & Loan v. Breckenridge, et al., 06 CH 9986, U.S. Bank v. Breckenridge, et al., 06 CH 25056, Muhammad v. RYM Tech, et al., 07 CH 9295, Davis, et al. v. Betts-Gaston, et al., 08 CH 3396, Fremont Investment & Loan, et al. v. Ross, et al., 09 L 62, Woodall, et al. v. Betts-Gaston, et al., 08 CH 18412, Saxon Mortgage Services v. Betts, et al., the testimony of attorneys Michelle A. Weinberg, Lea A. Weems, and Susan Malone, the testimony of other third parties, including Warren Jackson, Shunté D. Thomas, Kendra Thomas, Shirley A. Muhammad, Eva S. Breckenridge, Onshelle Jackson, Surrina Hamb, James Betts, Bobbie Ross, Terri Reis-Schmidt, Helen K. Kmiec, Mitchelle H. Kmiec, Tanisha Blanchard, Clennie Hernandez, Carol Cuzick, April Czech, Patricia Scully, Rhonda L. Griffen, Tralyn McDowell, Gale O’Hanley, Martha Jones, Valerie Davis, Steven Davis, Charles Williams, André Davis, Avon M. Ashford, and the testimony of Movant’s former clients, including Helen Hatchett, Jacqueline Judge, Leatrice Howard, Shakeela Muhammad, and Sandra Spikes-Davis would establish the following facts:

2. In 2005, W2X, Inc., was an Illinois corporation engaged in the business of real estate investments which purported to assist homeowners in foreclosure retain their homes. Warren Jackson, the President of W2X, located investors willing to purchase properties in foreclosure from homeowners. Through a combination of mortgage loans and closing costs credits, the W2X investors paid no money out of pocket to purchase the properties, received

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proceeds from the closing to pay the mortgage payments on the properties for six months and received a fee for their participation as the investors. W2X also had referral relationships with real estate brokers and mortgage loan originators, who prepared real estate contracts for the purchase and sale of the properties and the residential loan applications to secure financing for the purchase the properties. W2X real estate brokers and mortgage loan originators received commissions for their participation.

3. Between May 2004, and October 2005, W2X referred eleven clients who were in foreclosure to Movant for her assistance in ordering and clearing title and for her legal representation of the homeowner.

4. In 2005, Helen Hatchett was in foreclosure on a property she owned at 10458 S. Vernon in Chicago, Illinois. Hatchett owed approximately $16,000 on the mortgage, and she had approximately $120,000 in equity in the property.

5. In late August 2005, at Jackson’s request, Movant agreed to represent Hatchett. Jackson provided Movant with a real estate contract, prepared by a W2X real estate broker and between Hatchett and Kendra Thomas, a W2X investor, for a purchase price of $145,000. Hatchett was not aware of the real estate contract and never communicated with Movant about the terms of the real estate contract.

6. Prior to October 6, 2005, Movant provided the documents required for closing to Jackson for Hatchett to sign. On October 6, 2005, Jackson, at the direction of Movant, advised Hatchett to sign the documents Movant had prepared. Jackson did not specifically explain what each document meant, and Jackson did not provide Hatchett with copies of any of the documents after she signed them.

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7. Three of the documents Movant prepared and gave to Jackson for Hatchett to sign were as follows:

(1) a "Disclosure Statement – Controlled Business Arrangement," that disclosed (a) that Movant had a financial interest in the title company she employed to provide title services; (b) stated that the estimated costs for owner’s and mortgage title policies and escrow or closing fees would be "per RESPA"; and (c) informed Hatchett and Thomas that they were not required to use Movant and were free to "shop around" to determine that they were receiving the best rate and services;

(2) an Illinois Statutory Short Form Power of Attorney for Property which authorized Movant to execute, in Hatchett’s name and on her behalf, all the documents at the closing on the property. At the direction of Movant, Movant’s secretary notarized Hatchett’s purported signature. At no time did Movant’s secretary observe Hatchett sign the power of attorney; and

(3) a warranty deed transferring the property from Hatchett to Thomas. Movant notarized the purported signature of Hatchett on the deed without observing Hatchett sign the deed.

8. On October 7, 2005, the closing on the property took place. The property was conveyed to the W2X investor for a purchase price of $145,000. Of the settlement funds, Movant received $1,186 as her attorney and title fees. Hatchett received a payoff of her outstanding mortgage and of the accrued interest and fees in the amount of $16,873.46. The closing agent tendered to Jackson a check payable to Hatchett for $117,959.50, representing her proceeds from the sale. Jackson later placed Hatchett’s purported signature on the reverse side of the check and deposited it into W2X’s account at LaSalle Bank. Hatchett did not receive any portion of the settlement proceeds.

9. At no time did Movant meet with or communicate privately with Hatchett regarding any issues related to the sale of the property to Thomas, including but not limited to the terms of the power of attorney, the terms of the disclosure statement, as required pursuant to 215 ILCS 155/18(b), or the terms of the sales contract or the settlement statement. Movant did

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not take any steps to ascertain if the actions she was taking on Hatchett’s behalf related to the sale of the property accurately reflected Hatchett’s desires or protected Hatchett’s legal interests. Further, Movant did not tell Hatchett that her own business or personal interest in the referral relationship with Jackson and W2X and as agent on behalf of the title company might materially affect her representation of Hatchett in the sale of the property.

10. In May 2006, Jackson and Thomas demanded that Hatchett pay $700 to $900 in monthly rent on the property. The amounts requested equaled approximately Hatchett’s entire monthly income, and she was unable to pay the rent requested. Jackson and Thomas informed Hatchett that in order for her to continue to reside in the property, she could pay the rent requested or repurchase the property for a purchase price of $138,000.

11. In 2004 and 2005, RYM Technology Holdings, LLC, was a Michigan-based, limited liability company engaged in real estate investment, debt elimination and financing. RYM Tech purported to assist individuals, specifically minorities, in a mortgage elimination program that utilized the equity in distressed properties to reduce a homeowner’s monthly liabilities through sale-lease-buy back contracts between the homeowner and third-party investors.

12. In each state of its operation, RYM Tech had a network of realtors, mortgage brokers, attorneys, and third-party investors who received fees for participating and assisting in each program transaction. Through a combination of mortgage loans and closing costs credits, the third-party investors paid no money out of pocket to purchase the properties. Further, RYM Tech used the equity in the property to pay the mortgage taken by the third-party investor. Movant served as the attorney for the homeowner in twenty-two RYM Tech transactions.

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13. The following three transactions all involved referrals of distressed homeowners from RYM Tech to Movant: in each transaction, the homeowners met with a representative of RYM Tech, who had the homeowner sign documents that were necessary to transfer the property, including but not limited to real estate sales contracts, warranty deeds, disclosure statements-controlled business arrangements for title services, and residential lease and trust agreements between RYM Tech and the homeowner. Each homeowner signed the documents, most of which were either incomplete or blank at the time of signing. In each instance, the homeowner did not fully read the documents she was signing, was encouraged to sign the documents quickly, and was not advised that she was selling the property to an investor, that a new mortgage was being placed on the property or that she would have to repurchase the property from the investor. In each transaction, Movant provided legal and title services to the homeowner.

14. Movant did not communicate privately with the homeowner regarding any issues related to the transfer of the property. Movant never told the homeowners that her own business or personal interest in the relationship with RYM Tech or as agent on behalf of the title company providing title services, might materially affect her representation of the homeowners in the transactions or that they should consult with an independent attorney regarding the transactions. Movant never took any steps to ascertain if the actions she was taking on the homeowners’ behalf related to the sale of their properties accurately reflected their desires or protected their legal interests.

15. In November 2004, Jacqueline Judge owned property located at 3213 West Walnut Avenue in Chicago, Illinois. Judge owed approximately $197,000 on her mortgage, had

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approximately $133,000 in equity, but could not secure refinancing of the mortgage due to her low credit score.

16. On November 19, 2004, the closing on the property took place. The property was conveyed to a RYM Tech third-party investor for $360,000. Of the settlement funds, Movant received $1,400 for her services as attorney and title agent, and Judge received a payoff of her outstanding mortgage and of the accrued interest and fees in the amount of $197,945.24. Pursuant to a lease agreement between RYM Tech and Judge, Judge would make no rental payment for six months, and then she would make monthly payments of $988.47 for the remaining term of the lease.

17. Judge was to receive $133,635.15 as her proceeds from the sale of the property, which the title company sent to her home following the closing. Movant requested that Judge endorse the check and forwarded the check to RYM Tech. Of the settlement proceeds, Judge received the benefit of no rental payments for six months or $5,930.82. Between June 2005, and October 2005, Judge made monthly rent payments in the amount of $988.47 to RYM Tech.

18. Between December 2005 and May 2006, neither the RYM Tech third-party investor nor RYM Tech paid the monthly mortgage payments or the 2004 real estate taxes on the property. On May 9, 2006, the RYM Tech third-party investor’s mortgage provider filed a complaint to foreclose, and on July 5, 2006, a default judgment was entered against the RYM Tech third-party investor.

19. In October 2004, Leatrice Howard owned property located at 6810 South Parnell in Chicago, Illinois. At that time, Howard had approximately $51,000 in equity, but she was facing foreclosure for an outstanding mortgage totaling approximately $80,000.

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20. On February 7, 2005, the closing on the property took place. The property was conveyed to a RYM Tech third-party investor for a purchase price of $145,000. Of the settlement funds, Movant received $1,011 as her attorney and title fees, and Howard received a payoff of her outstanding mortgage and of the accrued interest and fees in the amount of $81,431.88. Howard was to receive $51,452.59 as her proceeds from the sale of the property, which was turned over to RYM Tech. Pursuant to a lease agreement between RYM Tech and Howard, no rent payments were due for the first six months after the closing, and then Howard was to make monthly payments of $381.91 for the remaining term of the lease.

21. From July 2005 to March 2006, Howard made monthly rental payments of $381.91 to RYM Tech. In March 2006, Howard stopped making rental payments when she learned that the real estate taxes on her home had not been paid.

22. On May 18, 2006, the RYM Tech third-party investor’s mortgage provider filed a foreclosure complaint on the property, and on July 17, 2006, a judgment of foreclosure and sale was entered.

23. In 2005, Shakeela Muhammad owned property located at 5816 South Rockwell in Chicago, Illinois. Muhammad’s mortgage payment, including taxes and insurance, was $867.79 per month, and she had approximately $79,000 in equity.

24. On July 14, 2005, the closing on the property took place. The property was conveyed to a RYM Tech third-party investor for a purchase price of $185,000. Of the settlement funds, Movant received $350 as her attorney fee, and Muhammad received a payoff of her outstanding mortgage and of the accrued interest and fees in the amount of $111,371.70.

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Muhammad also received the benefit of satisfaction of a $12,004.43 lien owed to the Internal Revenue Service and satisfaction of a $1,713 lien owed to the Illinois Department of Revenue.

25. On July 17, 2005, Movant requested that Muhammad endorse a check for $44,156.71 representing Muhammad’s portion of the proceeds from the sale. Muhammad endorsed the check and tendered it to Movant, who turned it over to RYM Tech.

26. Between July 29, 2005, and May 1, 2006, Muhammad paid a total of $3,182.04 in rent payments to RYM Tech. In December 2005, Muhammad learned that the 2004 real estate taxes on the property had not been paid. At that same time, Muhammad learned that RYM Tech had not made her homeowner’s insurance payments.

27. On May 18, 2006, the RYM Tech third-party investor’s mortgage provider filed a foreclosure complaint on the property.

28. In 2006, In Jesus Christ’s Name Investments, Inc. ("IJCN"), was an Illinois limited liability company, co-owned and co-managed by Movant and one of W2X’s and RYM Tech’s mortgage loan originators, D’Mona Ross. Movant served as IJCN’s registered agent and corporate attorney. IJCN held a business checking account at LaSalle Bank on which Movant and Ross were the only signatories.

29. IJCN’s primary business purpose purported to be assisting individuals in foreclosure through a mortgage elimination program that utilized the equity in distressed properties to reduce a homeowner’s monthly liabilities through sale-lease-buy back contracts between the homeowner and third-party investors.

30. In each IJCN transaction, IJCN used the legal and title services of Movant and used Ross as the mortgage loan originator to prepare residential loan applications to secure

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financing for the third-party investors to fund the purchase of the properties. Movant’s father and Ross’ mother were third-party investors associated with IJCN who received a payment of between $5,000 to $10,000 for each transaction. Through a combination of mortgage loans and closing costs credits, the third-party investors paid little or no money out of pocket to purchase the properties. Further, IJCN used the equity in the property to pay the mortgages obtained by the third-party investors.

31. In 2006, Sandra Spikes-Davis and her husband, André Davis, owned property located at 7759 S. Trumbull, Chicago, Illinois, that was the subject of a foreclosure complaint. At that time, their monthly mortgage payment was approximately $1,000.

32. On July 28, 2006, the closing on the property took place. The property was conveyed to Movant’s father from IJCN’s land trust for a purchase price of $225,000. Of the settlement funds, Movant received $1,507.50 as her attorney and title fees, and Sandra received a payoff of her outstanding mortgage and of the accrued interest and fees in the amount of $168,183.05. Sandra also received $31,533.48, representing her proceeds from the sale of the property, which she tendered to Movant. Movant, or someone acting on her direction, deposited these funds into the IJCN account and used the funds to pay Movant’s father’s monthly mortgage payment on the property.

33. Between July 28, 2006, and August 30, 2006, Sandra called Ross to inquire as to when the closing to transfer the property would occur. Ross told Sandra that it had already occurred, and that her presence was not required. At that time, Ross further informed Sandra that the payoff on her existing mortgage and the costs involved with the transaction had been more than anticipated. As a result, in order for Sandra to remain in the IJCN program, she would

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not receive any grace period and would need to start making a monthly payment of $1,042 for five months beginning in September 2006, and thereafter the payment would increase to $1,887.71 until the termination of the program in July 2007.

34. On August 30, 2006, Surrina Hamb, an employee of IJCN, met with Sandra and presented her with a "Residential Lease Agreement and Option to Purchase" for Sandra’s signature. The lease was between IJCN, as the lessor, and Sandra, as the lessee, and provided for a rental payment by Sandra to IJCN of $1,041.99 per month for the first four months of the lease and payments of $1,887.71 for the remaining eight months. André and Sandra executed the document as lessees, and Movant executed the document as "Member-Manager" on behalf of IJCN.

35. Between September 2006 and December 2006, Sandra paid approximately $5,000 in monthly rent payments to IJCN.

36. Prior to January 23, 2007, Sandra, concerned about the status of her property, retained counsel to file a complaint for fraud, rescission, and for damages on her and André’s behalf.

37. Movant did not disclose any potential conflict between Movant, individually as Sandra’s attorney, or Movant as agent on behalf of IJCN and Sandra that might be created as a result of the transactions between Movant, IJCN and Sandra. Movant did not recommend that Sandra seek independent legal representation regarding her interests, nor did Movant tell Sandra that her own business or personal interests might materially affect her representation of her in the transactions between Movant, IJCN and Sandra.

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38. In 2005, Charles Kmiec owned property at 5140 W. Howard in Skokie, Illinois. Between September 2005 and July 2006, Charles sought assistance from IJCN to attempt to refinance his home and avoid foreclosure.

39. On August 30, 2006, the closing on the property took place. The property was conveyed to Ross’ mother for a purchase price of $395,000. Of the settlement funds, Movant received $1,686 as her attorney and title fees, and Charles received a payoff of his outstanding mortgage and of the accrued interest and fees in the amount of $252,163.39. Charles was to receive $83,955.07 as his proceeds from the sale of the property, which was turned over to IJCN, held in escrow by IJCN and used to pay Ross’ mother’s monthly mortgage payment on the property.

40. On August 31, 2006, Charles died. On September 1, 2006, Mitchelle H. Kmiec, Charles’ sister, and Helen Kmiec, Charles’ mother, his only heirs, found the settlement statement from the closing on the property and informed Movant that Charles had died.

41. On October 10, 2006, the title company issued a $5,200 check, payable to Charles, and sent it to IJCN’s offices, representing the release of monies it withheld at the closing. On or about November 1, 2006, Movant, or someone acting on her direction, endorsed the reverse side of the check, and deposited it into the IJCN account. Charles did not place his endorsement on the check, nor did he give Movant, or anyone acting on her direction, permission to place his endorsement on the check, as he died on August 30, 2006.

42. In several letters and phone calls between September 2006 and March 2007, Michelle informed Movant that neither she nor Helen wished to participate in the IJCN program, requested an accounting of the remaining escrow funds held by IJCN and copies of any

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agreements, contracts and leases that Charles had entered into in relation to the property and asked that no more funds be deducted from the escrow account.

43. Between September 2006 and March 2007, Movant continued to pay Ross’ mother’s monthly mortgage on the property from the escrowed funds held by IJCN, and at no time did Movant return any portion of the escrowed funds to Mitchelle or Helen.

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

1. overreaching;

2. breach of fiduciary duty by failing to protect her clients’ interests and advancing her own self-interests above those of her clients;

3. failing to consult with clients concerning the objectives of the representation and the means by which they are to be pursued in violation of Rule 1.2(a) of the Illinois Rules of Professional Conduct;

4. failing to keep clients reasonably informed about the status of a matter in violation of Rule 1.4(a) of the Illinois Rules of Professional Conduct;

5. failing to explain a matter to the extent reasonably necessary to permit the clients to make informed decisions about the representation in violation of Rule 1.4(b) of the Illinois Rules of Professional Conduct;

6. representing clients where the representation of that client was materially limited by the Respondent’s responsibilities to a third person or by Respondent’s own interests in violation of Rule 1.7(b) of the Illinois Rules of Professional Conduct;

7. entering into a business transaction with a client without obtaining the client’s consent to a conflict of interest after full disclosure in violation of Rule 1.8(a) of the Illinois Rules of Professional Conduct;

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8. committing a criminal act, violation of the Illinois Notary Act, 5 ILCS 312/6-102 and 5 ILCS 312/7-105, that reflects adversely on the lawyer’s honesty, trustworthiness or fitness as a lawyer in other respects, in violation of Rule 8.4(a)(3) of the Illinois Rules of Professional Conduct;

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

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