July 30, 1997
Mary Robinson
ATTORNEY REGISTRATION AND DISCIPLINARY COMMISSION
One Prudential Plaza Suite 1500
130 East Randolph Drive
Chicago, Illinois 60601
Re: Case 93 P 1080, Estate of Harry Kalish
Dear Ms. Robinson:
I am complaining of Alvin D. Meyers, lawyer #90041, of Fagel & Haber, 140 South Dearborn, Chicago, Illinois 60603. During the almost four years that Meyers has been involved in case 93 P 1080, he knowingly, deliberately and continuously violated the Illinois Rules of Professional Conduct in the following ways:
Although lawyers are prohibited from representing conflicting interests in the same matter, or undertaking to discharge inconsistent duties, beginning about August 31, 1993 and continuing to the present, Meyers represented Margaret Kalish, individually, and as executor of the estate of Harry Kalish, in the same matter. In his unlawful and unethical dual representation of Margaret Kalish, Meyers unethically and unlawfully undertook to discharge inconsistent duties.
Margaret Kalish was referred to Meyers by Ronald Silbert. In 1990, Silbert drafted Harry Kalish's Will which is the subject of the litigation in case 93 P 1080. Michael Kalish and I are Harry Kalish's only two children, his heirs and residuary legatees/vested remaindermen of his will. We are plaintiffs in a Will contest which is part of 93 P 1080.
On September 22, 1993, a pleading was filed by Fagel & Haber alleging that Meyers had primary responsibility for case 93 P 1080. That Meyers represented Margaret Kalish, individually, and as executor of the Estate of Harry Kalish. The firm asked for time to research the facts and law relevant to the case.
Meyers knew or reasonably should have known that the law relevant to the case is attorneys' conflict of interest, the executor's and her lawyers' duties to the estate and the heirs, probate/wills/trusts. Meyers was required to know the facts and the law.
The Will signed under penalties of perjury by my father and Margaret Kalish, his third wife, contains a statement that they each have two children from their prior marriages and contains an agreement between my father and Margaret Kalish. The agreement contains identical reciprocal provisions. They agreed, after the first of them died, to combine all of their assets and establish a residuary marital deduction trust, and to fund another trust with the remaining funds. The corpus of the trusts is expressly defined in the will as including all of the couple's jointly held assets. The survivor [Margaret] was to be the executor, the income beneficiary and was empowered to act as trustee and manage the trusts' assets. After the survivor's [Margaret's] death and the payment of certain expenses, the executor [Renee Kalish] is directed to combine the trusts and divide the estate into equal, one-fourth, shares to each of Harry's two children and Margaret's two children from prior marriages. They agreed that the survivor [Margaret] was prohibited from changing any of the terms of the agreement in the Will. The power of appointment is reserved to the survivor [Margaret] as to her own beneficiaries, expressly by codicil.
Margaret Kalish and Silbert and his firm are defendants in the Will contest. The complaint and amended complaint allege that in 1990, Silbert prepared one will for my father and Margaret Kalish; at that time my father was suffering from severe coronary artery disease, was severely hearing impaired and that English was not his Native language. That the phrase "not liable for waste" was not in an earlier draft will that Silbert prepared. The amended complaint alleges that one week after my father's death, Linda Ciegler told me that she was unrelated to Margaret Kalish by birth or adoption. That in order to procure a 1/4 inheritance of the residuary estate for Linda Ciegler, Margaret Kalish fraudulently represented to my father that Linda Ciegler was Linda Pichler, her adopted child from a prior marriage.
Because of Margaret Kalish's personal stake in the outcome of the will contest in which she is accused of fraud and undue influence over my father and interfering with my brother's and my inheritance, she had a conflict of interest with the estate and the other beneficiaries which interfered with her duties as executor of the estate. Margaret Kalish' obvious conflict of interest precluded Meyers from representing her, individually, and as executor, in the same matter.
The executor and her lawyers are fiduciaries, and have identical well known duties to act in the best interests of the estate and, impartially, in the best interests of all of the heirs and beneficiaries. Meyers' duties to the estate and the other heirs and beneficiaries conflicted with his duties to Margaret Kalish, individually, and precluded Meyers from representing Margaret Kalish, individually, and as executor, in the same matter.
Throughout almost four years of his dual representation in case 93 P 1080, Meyers knowingly and deliberately conspired and connived with Margaret Kalish to defraud my brother and me of our rightful inheritance under the will, or tried to force us to litigate in order to enforce our rights. Meyers engaged in a pattern of litigation to further his own personal interests and Margaret Kalish's individual interests. He unlawfully and unethically used estate assets to fund the litigation. Meyers knowingly and deliberately ignored his responsibilities to act in the best interests of the estate and, impartially, to the other heirs and beneficiaries, because if Meyers properly performed his duties, the result would have been nominal litigation expense.
By the foregoing conduct, Meyers engaged in the following misconduct:
(a) engaging in conduct designed to maximize the expense of litigation and cause the greatest trauma to the parties in violation of these Rules;
(b) engaging in improper conflict of interest when the lawyer's representation will be directly adverse to another client in violation of Rule 1.7(a);
c) continuing multiple representation when the lawyer knows or reasonably should know that the representation is adversely affecting the relationship with the other client in violation of Rule 1.7(a)(1);
(d) engaging in representing a client when the representation of that client may be materially limited by the lawyer's responsibilities to another client or to a third person, or by the lawyer's own interests in violation of Rule 1.7(b);
(e) continuing the multiple representation when the lawyer knows or reasonably should know that the representation is adversely affected in violation of Rule 1.7(b)(1);.
(f) failing to withdraw when he knew or should have known such representation would result in a violation of the Rules in violation of Rule 1.16(a)(2);
(g) violating or attempting to violate these Rules in violation of Rule 8.4(a)(1);
(h) engaging in conduct involving dishonesty, fraud and dishonesty in violation of Rule 8.4(a)(4);
(i) engaging in conduct prejudicial to the administration of justice in violation of Rule 8.4(a)(5);
(j) engaging in conduct which tended to defeat the administration of justice or to bring the courts or the legal profession into disrepute in violation of Supreme Court Rule 771.
Since July, 1996 and continuing to the present, Meyers engaged in unlawful and unethical conduct by continuing to represent Margaret Kalish, individually, and/or as executor, after Meyers knew that he had a stake in the outcome of the proceeding to remove Margaret Kalish as executor. Meyers' own interests conflict with his representation. And, Meyers knows or reasonably should know that he and other members of his firm will be called as witnesses in the matter.
On July 16, 1996, I filed a Petition to Remove the Executor alleging that Margaret Kalish was guilty of fraud, waste, mismanagement, conflict of interest and breach of statutory and fiduciary duty--all grounds for removal pursuant to 755 ILCS 5/23/-2. Meyers knew or reasonably should have known that he may be called as a witness in that proceeding and that his own personal interests were at conflict with the interests of Margaret Kalish, as executor, the other beneficiaries and the estate. Instead of withdrawing, Meyers filed his appearance and a frivolous pleading, and continued his dual representation of Margaret Kalish.
Among the allegations in the Petition were that Margaret Kalish never attempted to retain lawyers to act in the best interest of the estate and the other beneficiaries; as a matter of law, an executor is prohibited from using estate assets for litigation to further her personal interests, but Meyers was allowing her to use estate assets, in the form of money orders and cashiers checks made payable to him for such litigation; that an executor is required by law to have an estate checking account and a book keeping system, but Margaret Kalish was disbursing tens of thousands of dollars in estate assets with cashier's checks and money orders to defraud my brother and me; she had no book keeping system other than notes on scraps of papers which she threw in the trash; that through her lawyers, she had committed perjury in her response prior marriage and the step-child of Harry Kalish.; that although required by law to tell me and my brother our rights under the will, she and her lawyers failed to do so, thereby involving the estate with needless litigation and forcing my brother and me to litigate to enforce our rights; and despite being required by law to make a complete disclosure of all estate matters, Meyers repeatedly refused to provide an inventory and accounting of the estate thereby concealing estate assets and trying to force my brother and me to litigate to enforce our rights and involving the estate with needless litigation.
By the foregoing conduct Meyers engaged in the following misconduct:
(a) engaging in conduct designed to maximize the expense of litigation and cause the greatest trauma to the parties in violation of the Rules.
(b) engaging in representing a client when such representation may have been materially limited by the lawyer's own interest in violation of Rule 1.7(b);
(c) accepting or continuing employment in contemplated or pending litigation if the lawyer knows or reasonably should know that the lawyer may be called as a witness on behalf of the client in violation of Rule 3.7(a);
(d) accepting or continuing employment in contemplated or pending litigation when a lawyer knows or reasonably should know that the lawyer may be called as a witness other than on behalf of the client, the lawyers may accept or continue the representation after the lawyer knows or reasonably should know that the lawyer's testimony is or may be prejudicial to the client in violations of Rule 3.7(b);
(e) failing to withdraw when he knew or reasonably should have known such representation would result in violation of the Rules in violation of Rule 1.16(a)(2);
(f) violating or attempting to violate these Rules in violation of Rule 8.4(a)(1);
(g) engaging in conduct prejudicial to the administration of justice in violation of Rule 8.4(a)(5);
(h) engaging in conduct which tended to defeat the administration of justice or to bring the courts or the legal profession into disrepute in violation of Supreme Court Rule 771.
Since about August, 1993 until the present, Meyers' litigation in case 93 P 1080 has been designed to exclusively benefit Margaret Kalish, individually, and to attempt to defraud my brother and me, the other beneficiaries, or force us to litigate to enforce our rights under the Will. In order to fraudulently use estate assets to fund Margaret Kalish's individual legal fees, Meyers knowingly and deliberately misrepresented to the Court, verbally and in documents, that he was appearing on behalf of the executor and the estate. Meyers fraudulently billed Margaret Kalish for his legal fees and unlawfully and unethically accepted estate assets as payment.
In order to harass and maliciously injure my brother and me, Meyers knowingly and deliberately filed a frivolous pleading in which he cited no legal authority to support his claim, which was inapposite to existing law, and in which he failed to make any argument whatsoever to extend, modify or reverse existing law. Instead of making a good-faith argument, Meyers asked the Court, even if it determined that the law was in our favor, to make an exception to the statute and deny my brother and me any legal remedy under it.
In another frivolous pleading filed to harass and maliciously injure my brother and me, Meyers knowingly and deliberately cited at least one case which he knew was completely irrelevant to his claims and had nothing to do with case 93 P 1080.
Although required by law to do so, Meyers failed to reveal my brother's and my rights under my father's will. Meyers was required by law to make a complete disclosure of all estate matters to all of the heirs. He repeatedly refused to provide a complete inventory of the estate or an accounting of the administration of the estate. Instead, Meyers conspired with Margaret Kalish to attempt to defraud us, or to force us to litigate to enforce our rights under our father's Will, to conceal estate assets, and to defraud the estate by unlawfully using estate assets to fund the litigation.
In Meyer's dual representation of Margaret Kalish, Meyers failed to perform his fiduciary duties to act in the best interest of the estate and the other heirs and beneficiaries. Meyers acted with malice to the estate and the other beneficiaries by pursuing litigation designed to, literally, waste the estate and defeat my brother and me, the other beneficiaries of the Will.
Since 1993, Myers knew that Margaret Kalish, individually, and as executor, had repeatedly made fraudulent representations to the court; and that Margaret Kalish has repeatedly made fraudulent disbursements of estate assets by cashier's checks and money orders to members of her family, to Meyers and unknown parties. Meyers knew that Margaret Kalish disposed of a car which was a valuable estate asset without receiving compensation, without transferring title in order to conceal the recipient and without maintaining liability insurance which put the estate at risk for a lawsuit. Meyers intentionally breached his fiduciary duty to the estate and the other beneficiaries by failing to do anything to rectify the situation, instead he tried to force my brother and me to litigate to enforce our rights and protect the estate from waste fraud and mismanagement.
By the foregoing conduct, Meyers has engaged in the following misconduct:
(a) engaging in conduct designed to maximize the expense of litigation and cause the greatest trauma to the parties in violation of the Rules.
(b) engaging in counseling a client to engage, or assisting a client, in conduct that the lawyer knows is criminal or fraudulent in violation of Rule 1.2(d);
(c) engaging in filing a suit, asserting a position, conducting a defense, delay a trial or take other action on behalf of the client when the lawyer knows or reasonably should know that such action would serve merely to harass or maliciously injure another in violation of Rule 1.2(f)(1);
(d) engaging in advancing a claim or defense the lawyer knows is unwarranted under existing law, except that the lawyer may advance such claim or defense if it can be supported by a good-faith argument for an extension, modification or reversal of existing law in violation of Rule 1.2(f)(2);
(e) failing to disclose that which the lawyer is required by law to reveal in violation of Rule 1.2(f)(3);
(f) engaging in conduct designed to maximize the expense of litigation and cause the greatest trauma to the parties in violation of the Rules.
(g) knowing that his client had, in the course of representation, perpetrated a fraud upon a person or tribunal and failing to promptly call upon the client to rectify the same, and failing to reveal the fraud to the affected person or tribunal in violation of Rule 1.2(g);
(h) failing to withdraw from employment when the lawyer knows or reasonably should know that the client is bringing the legal action, conducting a defense, or asserting a position in the litigation, or is other wise having steps taken, merely for the purpose of harassing or maliciously injuring any person in violation of Rules 1.16(a)(1) and (a)(2);
(i) violating or attempting to violate these Rules in violation of Rule 8.4(a)(1);
(j) bringing or defending a proceeding, or asserting or controverting an issue therein, unless there is a basis for doing so that is not frivolous, without including a good-faith argument for an extension, modification or reversal of existing law in violation of Rule 3.1 and Supreme Court Rule 137;
(k) engaging in conduct involving dishonesty, fraud, deceit and misrepresentation in violation of Rule 8.4(4);
(l) engaging in conduct prejudicial to the administration of justice in violation of Rule 8.4(a)(5);
(m) engaging in conduct which tended to defeat the administration of justice or to bring the courts or the legal profession into disrepute in violation of Supreme Court Rule 771.
On two separate occasions over the last four years, Meyers has suggested, and entered into fraudulent settlement negotiations. Meyers lied to me when he said that he was authorized to represent Margaret Kalish, individually, and as executor in the settlement negotiations. Meyers fraudulently billed for and accepted estate assets for entering into bad faith and fraudulent settlement negotiations. Meyers failed to tell me that he is prohibited, by law and the Rules of Professional conduct from settling the claims.
In early 1997, during the most recent settlement negotiations that Meyers fraudulently and unethically initiated, I confronted Meyers with his misconduct and implored him to rectify the situation. I told Meyers that it was obvious that he was litigating to benefit Margaret Kalish's individual interest only, and that he was ignoring his duties to act in the best interest of the estate, and, impartially, to all of the other heirs and beneficiaries. Meyers told me that although he was the lawyer for the executor, he did not have any fiduciary duties to the other beneficiaries or the estate.
I referred Meyers to case law from this jurisdiction regarding the executor's attorneys' duties. The law clearly states that Meyers is required to act in the best interest of all of the heirs and beneficiaries and that he is required to make a complete disclosure of estate matters to all of the heirs. I told him that it was obvious that his responsibilities to my brother and me created a great conflict of interest for him, as evidenced by all of his and the executor's breaches of duty to us and the estate; that he was required to withdraw from representing the executor. I told him that it is obvious that he and members of his firm may be called as witnesses in the proceeding to remove the executor.
Meyers told me that it is not improper for him to represent Margaret Kalish in the proceeding to remove the executor even though he has a stake in the outcome of the litigation, and that he and members of his firm may be called as witness in the proceeding. Meyers denied he had any duties to us or the estate and that he was not doing anything wrong, and he continued to violate the Rules and the law.
By the foregoing conduct, Meyers engaged in the following misconduct:
(a) engaging in conduct designed to maximize the expense of litigation and cause the greatest trauma to the parties in violation of the Rules.
(b) engaging in, while representing two or more clients, the participation of making an aggregate settlement of the claims of or against the clients in violation of Rule 1.8(e);
(c) failing to withdraw when he knew or should have known such representation would result in violation of the Rules in violation of Rule 1.16(a)(2);
(d) engaging in making statements of material fact or law to a third person which statements the lawyer knows or reasonably should know is false;
(e) failing to disclose that which the lawyer is required by law to reveal in violation of Rule 1.2(f)(3);
(f) violating or attempting to violate these Rules in violation of Rule 8.4(a)(1);
(g) engaging in conduct involving dishonesty, fraud, deceit or misrepresentation in violation of Rule 8.4(a)(4);
(h) engaging in conduct which tended to defeat the administration of justice or to bring the courts or the legal profession into disrepute in violation of Supreme Court Rule 771.
Silbert prepared the Will for my father and his third wife, Margaret Kalish, which contains a fraudulent statement that Linda Ciegler, is Linda Pichler, Margaret Kalish's child from a prior marriage. And, a phrase that in the management of the estate, Margaret Kalish is "not liable for waste." Although as a matter of law the Will creates a trust, Silbert deliberately omitted the words, trust, trustee, or in trust for. Silbert has admitted the Will creates a trust, but has refused to establish a trust satisfactory to anyone, but Margaret Kalish, individually. By co-counseling and ignoring his duties to the estate and the heirs, Silbert is trying to force me to litigate in order to enforce my rights under the Will that he prepared for my father. He is co-counseling with Meyers and engaging and assisting in litigation to nullify his own work.
Meyers knows that Silbert and his firm are defendants in the will contest, that they have a stake in the outcome of the litigation; they may be called as witnesses in the case; and Silbert's and his firm's own interests materially limit their ability to properly represent the executor. Meyers conspired with and allowed Silbert and his firm to co-counsel in the legally prohibited dual representation of Margaret Kalish, individually, and as executor, in the same matter. The representation is also prohibited because Silbert is litigating to nullify his own work, and litigating against a former client in a related matter.
By the foregoing conduct, Meyers has engaged in the following misconduct:
(a) overreaching
(b) engaging in conduct designed to maximize the expense of litigation and cause the greatest trauma to the parties in violation of the Rules.
(c) failing to disclose that which the lawyer is required by law to reveal in violation of Rule 1.2(f)(3);
(d) engaging in representation when the representation of that client may be materially limited by the lawyer's responsibilities to another client or a third person, or by the lawyers own interests in violation of Rule 1.7(b);
(e) failing to disclose to a tribunal a material fact known to the lawyer when disclosure is necessary to avoid assisting a criminal or fraudulent act by the client in violation of Rule 3.3(a)(2);
(f) failing to disclose to the tribunal legal authority in the controlling jurisdiction known to the lawyer to be directly adverse to the position of the client and not disclosed by opposing counsel in violation of Rule 3.3(a)(3);
(g) possessing knowledge not otherwise protected as a confidence by these Rules or by law that another lawyer has committed a violation of Rule 8.4(a)(4) but failing to report that knowledge to a tribunal or other authority empowered to investigate or act upon such a violation in violation of Rule 8.3(a);
(h) violating or attempting to violate these Rules in violation of Rule 8.4(a)(1);
(i) inducing another to engage in conduct, or giving assistance to another's conduct when the lawyer knows that conduct will violate these Rules in violation of Rule 8.4(a)(2);
(j) engaging in conduct involving dishonesty, fraud, deceit or misrepresentation.
(k) engaging in conduct prejudicial to the administration of justice in violation of Rules 8.4(a)(5);
(l) engaging in conduct which tended to defeat the administration of justice or to bring the courts or the legal profession into disrepute in violation of Supreme Court Rule 771.
Since August 1993, and continuing to the present, Meyers' statements and conduct, in part, led to the removal of the first judge and the recusal of the second judge in the case.
By the foregoing conduct, Meyers engaged in the following misconduct:
(a) violating or attempting to violate these Rules in violation of Rule 8.4(a)(1);
(b) inducing another to engage in conduct, or giving assistance to another's conduct, when the lawyer knows that the conduct will violate these Rules in violation of Rule 8.4(a)(2);
(c) engaging in conduct involving dishonesty, fraud, deceit or misrepresentations in violation of Rule 8.4(4);
(d) engaging in conduct that is prejudicial to the administration of justice in violation of Rule 8.4(5);
(e) stating or implying an ability to influence improperly any tribunal, legislative body, government agency or official in violation of Rule 8.4(a)(6);
(f) assisting a judge or judicial officer in conduct that the lawyer knows is a violation of the Code of Judicial Conduct in violation of Rule 8.4(a)(7);
(g) engaging in conduct which tended to defeat the administration of justice or to bring the courts or the legal profession into disrepute in violation of Supreme Court Rule 771.
For almost four years, Meyers knowingly, deliberately, unlawfully and unethically represented Margaret Kalish, as executor, and individually in the same matter; continued the representation even though his own interests materially limited his ability to properly represent the executor; continued the representation when he knew that he had conflicting duties in the matter; continued the representation after he knew that he may be called as a witness for or against his client.
After his misconduct and the relevant law were pointed out to him, and he was given an opportunity to try to rectify the situation, Meyers continued to ignore the law and the Rules of Professional Conduct because they did not serve his purposes sand continued his misconduct.
Meyers knowingly and deliberately breached his duties as a lawyer for the executor and the estate. Meyers conspired, connived, allowed and assisted his co-counsel and Margaret Kalish to breach their duties and engage in fraudulent conduct and he failed to reveal the information to me or any tribunal.
Meyers flagrantly, knowingly and intentionally breached his duties to my brother, me and the estate by attempting to conceal his duties from us; ignoring the existing and relevant law in the case; failing to explain the Will to my brother and me and our rights under the Will which he had a duty to do, instead he tried to defraud us. or force us to litigate in order to enforce our rights under the Will; refusing to make a complete disclosure of estate matters as he was required to do by law, instead he tried to defraud us, or force us to litigate to enforce our rights; allowing Margaret Kalish, individually, and as executor to fraudulently dispose of estate assets; deliberately taking positions in court which he knew were contrary to existing law in order to harass and maliciously injure my brother and me, and/or to force us to litigate in order to enforce our rights under our father's will, and maximize legal expenses and inflict the greatest amount of emotional damage on the parties; failing to ensure that the estate is administered efficiently; unlawfully and unethically using estate assets for Margaret Kalish's individual legal fees and attempting to conceal his conduct by refusing to provide an inventory and accounting of the estate as required by law; failing to rectify any of these situations even after I repeatedly implored him to so; and failing to report any of the foregoing to the court, as he was required to do.
(a) overreaching
(b) engaging in conduct designed to maximize the expense of litigation and cause the greatest trauma to the parties in violation of the Rules.
(c) engaging in counseling a client to engage, or assisting a client, in conduct that the lawyer knows is criminal or fraudulent in violation of Rule 1.2(d);
(d) engaging in filing a suit, asserting position, conducting defense, delay a trial or take other action on behalf of the client when the lawyer knows or reasonably should know that such action would serve merely to harass or maliciously injure another in violation of Rule 1.2(f)(1);
(e) engaging in advancing a claim or defense the lawyer knows is unwarranted under existing law without offering any argument for an extension, modification, or reversal of existing law in violation of Rule 1.2(f)(2);
(f) failing to disclose that which the lawyer is required by law to reveal in violation of Rule 1.2(f)(3);
(g) engaging in representing a client when the representation of that client will be directly adverse to another client in violation of Rule 1.7(a);
(h) continuing the representation after the lawyer can not reasonably believe that the representation does not adversely affect the relationship with the other client in violation of Rule 1.7(a)(1);
(i) engaging in representing a client if the representation of that client may be materially limited by the lawyer's responsibilities to another client, or to a third person, or by the lawyer's own interests in violation of Rule 1.7(b);
(j) continuing the representation after the lawyer cannot reasonably believe that the representation is not adversely affected in violation of Rule 1.7(b)(1);
(k) accepting or continuing employment in contemplated or pending litigation if the lawyer knows or reasonably should know that the lawyer may be called as a witness on behalf of the client in violation of Rule 3.7(a);
(l) accepting or continuing employment in contemplated or pending litigation if the lawyer knows or reasonably should know that the lawyer may be called as a witness other than on behalf of the client and after the lawyer reasonably knows that the lawyer's testimony is or may be prejudicial to the client in violation of Rule 3.7(b);
(m) engaging in making a statement of material fact or law to a third person which statement the lawyer knows or reasonably should know is false in violation of Rule 4.1(a);
(n) failing to disclose a material fact to a third person when disclosure is necessary to avoid assisting a criminal or fraudulent act by a client in violation of Rule 4.1(b);
(o) engaging in making misleading communication about the lawyer or the lawyer's services communicating a material misrepresentation of fact or law, or omitted a fact necessary to make the statement considered as a whole materially misleading in violation of Rule 7.1(a);
(p) when the lawyer possesses knowledge that another lawyer not otherwise protected a confidence by these Rules or by law that another has committed a violation of Rule 8.4(a)(3) or (4), failing to report the other lawyer to a tribunal or other authority empowered to investigate or act upon such violation in violation of Rule 8.3(a);
(q) engaging in violating or attempting to violate these Rules in violation of Rule 8.4(a)(1);
(r) engaging in inducing another to engage in conduct or give assistance to another's conduct when the lawyer knows that conduct will violate these Rules in violation of Rule 8.4(a)(2);
(s) engaging in conduct involving dishonesty, fraud, deceit or misrepresentation in violation of Rule 8.4(a)(4);
(t) engaging in conduct that is prejudicial to the administration of justice in violation of Rule 8.4(a)(5);
(u) engaging in conduct which tends to bring the courts or legal profession into disrepute in violation of Supreme Court Rule 771.
For almost four years, Meyers repeatedly, deliberately and intentionally used the courts, political influence, his position as a lawyer, and his position as a fiduciary to my brother, me and the estate for predatory, deceitful and fraudulent purposes. Based on the foregoing, I request that you investigate this matter. Thank you for your prompt attention to this matter.
Very truly yours, Renee Kalish
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August 5, 1997