Jerome Larkin, Administrator of the Attorney Registration and Disciplinary Commission, by his attorney, Peter L. Rotskoff, states on the date Movant signed a motion to have his name stricken from the Master Roll of Attorneys who were admitted to practice law in Illinois, Movant was the subject of a second amended complaint pending before the Hearing Board, case no. 08 SH 115, and that if the cause was the subject of a hearing, the evidence would be as stated below and would clearly and convincingly support the conclusions of misconduct indicated below.

1. Bank records, testimony of witnesses, court documents, and other records would establish the following:

2. On November 16, 2007, Movant was appointed by a judge in St. Clair County as temporary public guardian for Francis Moll, who was eighty-six years old. Moll had been found to be mentally incompetent and was residing in a nursing home. Between November 2007 and May 2008, Movant used, without authority, at least $3000.00 belonging to Moll for Movant’s own purposes.

3. On March 22, 2006, Movant was appointed by a judge in St. Clair County as temporary public guardian for Harold Watts. Watts had been declared disabled and had been diagnosed with dementia. Watts died on April 1, 2006. The circuit court subsequently appointed Movant as administrator of the Watts estate.

4. Between February 1, 2008, and January 2, 2009, Movant used, without authority, at least $20,000.00 of funds belonging to the Watts estate for his own purposes.

5. On July 2, 2007, Movant was appointed by a judge in St. Clair County as guardian for the estate of Vernon Denbo after Denbo died in February 2007. In July 2007, Movant used, without authority, at least $2,500.00 of funds belonging to the Denbo estate for his own purposes.

6. In 2002, Movant agreed to represent Trina Hernandez in a workers’ compensation case. Movant never filed a case for Hernandez and did not respond to most of her telephone inquiries. Hernandez subsequently hired new counsel in 2007.

7. In 2006, Movant agreed to represent Barbara Costello, who was the administrator of her brother James Hammel’s estate. Costello paid Movant $3,000.00. After August 2007, Movant took no action to conclude the estate case, nor did he respond to inquires made by Costello or her sister. Movant did not refund any unearned fees.

8. In 2008, Movant agreed to represent Randy Andrews in matters related to child support payments and visitation of Andrews’ children. Movant took no action to pursue Andrews’ case, nor did he refund any portion of the $500.00 fee Andrews paid to him.

9. In 2008, Movant practiced law after he was removed from the master roll for his failure to register and pay the registration fee. Movant engaged in the unauthorized practice of law between February 1, 2008, and April 22, 2008. He was restored to the master roll on April 22, 2008.

10. The evidence outlined above would establish that Movant has engaged in the following misconduct:

1. conversion;

2. breach of fiduciary duties;

3. failure to hold property of a client or third person that is in the lawyer’s possession in connection with a representation separate from the lawyer’s own property in violation of Rule 1.15(a) of the Illinois Rules of Professional Conduct (1990);

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

5. failure to act with reasonable diligence and promptness in representing a client in violation of Rule 1.3 of the Illinois Rules of Professional Conduct;

6. failure to keep a client reasonably informed about the status of a matter and promptly comply with reasonable requests for information, in violation of Rule 1.4 of the Illinois Rules of Professional Conduct;

7. practicing law in a jurisdiction where doing so violates the regulation of the legal profession in that jurisdiction, in violation of Rule 5.5(a) of the Illinois Rules of Professional Conduct and Supreme Court Rule 756(g);

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

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