Jerome Larkin, Administrator of the Attorney Registration and Disciplinary Commission, by his attorney, Athena T. Taite, pursuant to Supreme Court Rule 762(a), states that on the date that Kenneth Edward Mateas ("Movant") signed a motion requesting that his name be stricken from the Roll of Attorneys, the Administrator's complaint charging conduct related to Movant's conviction for reproduction of child pornography was pending before the Hearing Board. If those charges had proceeded to hearing, the Administrator would have introduced the evidence described below, and that evidence would have clearly and convincingly established the misconduct described below:

Records of the Circuit Court in Kane County, Illinois, in People v. Mateas, case no. 07 CF 1848; law enforcement records and officers; and Movant's admissions would establish that:

1. On June 29, 2007, Movant was charged with possession and reproduction of child pornography in a 49-count indictment filed with the Circuit Court for the 16^th Judicial Circuit, Kane County, Illinois, in a matter docketed as People v. Mateas, case no. 07 CF 1848.

2. The indictment described in paragraph one, above, set forth the following allegations:

1. in Counts 1-11, the indictment charged Movant with child

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pornography in violation of 720 ILCS 5/11-20.1(a)(2)(vii) for knowingly reproducing depictions by computer of children whom Movant knew or reasonably should have known to be under the age of 18 depicted in a pose involving the lewd exhibition of the unclothed genitals of the children;

2. in Counts 12-47, the indictment charged Movant with child pornography in violation of 720 ILCS 5/11-20.1(a)(6)(vii) for knowingly possessing a depiction by computer of children whom Movant knew or reasonably should have known to be under the age of 18 depicted in a pose involving the lewd exhibition of the unclothed genitals of the children;

3. in Count 48, the indictment charged Movant with child pornography in violation of 720 ILCS 5/11-20.1(a)(6)(iv) for knowingly possessing a depiction by computer of two children whom Movant knew or reasonably should have known to be under the age of 18 actually engaged in an act of lewd touching of another person; and

4. in Count 49, the indictment charged Movant with child pornography in violation of 720 ILCS 5/11-20.1(a)(6)(iii) for knowingly possessing a depiction by computer of a child whom Movant knew or reasonably should have known to be under the age of 18 actually engaged in an act of masturbation.

3. On October 27, 2008, Movant entered a plea of guilty to Counts 1-9 of the indictment, stipulating that if witnesses were called, they would testify competently to sufficient facts to support a finding of guilty.

4. On January 7, 2009, having found Movant guilty of Counts 1-9 of the indictment and granting the Kane County State's Attorney's motion to nolle prosequi the remaining counts, Judge Timothy Sheldon sentenced Movant to four years in the Department of Corrections, $3,889 in fines, costs and fees, and registration for life as a sex offender.

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5. As a result of the conduct described above, Movant has engaged in the following misconduct:

1. committing a criminal act that reflects adversely on the lawyer's honesty, trustworthiness or fitness as a lawyer in other respects, by violating 720 ILCS 5/11-20.1(a)(6)(vii), in violation of Rule 8.4(a)(3) of the Illinois Rules of Professional Conduct;

2. conduct which 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 to bring the courts or the legal profession into disrepute, in violation of Supreme Court Rule 770.