The ARDC has amended its complaint against Maurice J. Salem, a New York lawyer who does not have a license to practice in Illinois. The ARDC is seeking to bar Salem from practicing in Illinois.
The scope of the alleged work done by Salem after his application to practice law in Illinois was rejected by Character and Fitness is simply remarkable:
1. On January 8, 2003, Respondent was admitted to practice law in the State of New York.
2. In December 2003, Respondent moved to Illinois and leased a single-family house located at 7400 Choctaw Road, Palos Heights, Illinois (“the Choctaw Road house”), from Said and Nancy Ghusein (“the Ghuseins”), for one year. Respondent agreed to pay monthly rent to the Ghuseins in the amount of $1,650. Respondent and the Ghuseins thereafter agreed to extend the term of the lease each year, until 2013.
3. At all times alleged in this complaint, the Ghuseins owned and operated a retail bridal clothing business located in Oak Lawn, Illinois, which operated under several trade names, including the names, “Eva’s Bridal” and “Exclusives for the Bride.”
4. In September 2004, Respondent and the Ghuseins agreed that Respondent would represent them and their business in pending and future Cook County legal matters relating to their business. At that time, Respondent and the Ghuseins agreed that the Ghuseins would pay Respondent’s legal fees by waiving his $1,650 monthly rent obligation for the Choctaw Road house and allow Respondent to reside in the Choctaw Road house.
5. On October 21, 2004, Respondent applied for admission to the Illinois Bar.
6. On November 1, 2005, the Committee on Character and Fitness rejected Respondent’s application citing, in part, concerns that Respondent was engaging in the unauthorized practice of law by holding himself out as an attorney by providing an Illinois address on his letterhead without any limitations indicating that he is not in fact admitted to practice law in Illinois.
7. On August 8, 2006, Respondent filed with the Illinois Supreme Court a Petition for Review of the Committee’s denial of his application to practice law in Illinois. Since Respondent attached a copy of the Character and Fitness Committee’s findings to his petition as an exhibit, that opinion is now public record. On September 21, 2006, the Illinois Supreme Court denied Respondent’s Petition for Review of the Committee’s decision. In re Salem, M.R. 21103 (September 21, 2006).
8. At no time alleged in this complaint has Respondent ever been admitted to practice law in Illinois.
9. Between September 2004 and March 2012, Respondent represented the Ghuseins and their business in the following matters in the Circuit Court of Cook County:
Miller v. EFTB, 04 M1 153369;
Terman v. Exclusives for the Bride (“EFTB”), 04 M1 116476;
Monale NY v. Exclusives for the Bride, 04 M1 164625;
Devon Clark Currency Exhange, Inc. v. EFTB, 04 M1 169930;
Pronovias USA, Inc. v. EFTB, et al, 03 M1 153841;
Superior Street v. Exclusives for the Bride, 04 M1 183565;
Advance Magazine v. Exclusives for the Bride, 05 M1 110560;
Oak Lawn Bank v. Exclusives for the Bride, 03 CH 5175;
Midwest Bank v. EFTB, 05 L 10570;
Eva’s Bridal v. Integrity Payment Systems, 06 CH 18755;
Chicago Sedgewick v. EFTB, 06 M1 106834;
Kishore v. Eva’s Bridal, 07 M1 703669;
Washington Mutual Bank v. Ghusein, et al, 07 CH 29020;
Symphony Bridal v. Eva’s Bridal, 07 M1 216827;
Deutsche Bank v. Ghusein, et al, 07 CH 25954;
Eva’s Bridal v. Halanack Enterprises, 11 L 7306; and,
Sarmiti v. Ghusein, 11 L 8145.
10. With regard to each of the matters referenced in paragraph nine, above, Respondent communicated with the Ghuseins regarding the matters, gave them legal advice, filed appearances and pleadings on their behalf, and appeared on their behalf before the Circuit Court, obtaining leave of the court to appear pro hac vice in each matter.
11. Between at least January 1, 2010 and August 2013, Respondent resided at 7400 Choctaw Road, Palos Heights, Illinois, and used a portion of his residence as an office from which he performed legal work on behalf of the Ghuseins in Illinois State Court matters, including the matter of Eva’s Bridal v. Halanack Enterprises, 11 L 7306 and Sarmiti v. Ghusein, 11 L 8145.
12. On November 19, 2011, Respondent filed incorporation documents for the entity entitled “Law Offices of Salem and Associates, Professional Corporation” with the Illinois Secretary of State. In the articles, Respondent indicated that the primary business of the Law Offices of Salem and Associates, Professional Corporation, was the handling of legal matters on behalf of clients.
13. In August 2013, Respondent relocated his residence and law office to a house located at 6201 West 124th Street, Palos Heights, Illinois, and from August 2013 to at least June 2014, Respondent used a portion of his residence at 6201 West 124th Street in Palos Heights as an office from which he performed legal work for clients whom he represented in Illinois State Court matters.
14. From January 1, 2010 to the present, Respondent also maintained a mailing address at a UPS storefront facility in Palos Heights, Illinois, which was designated, “7156 West 127th Street, B-149, Palos Heights, Illinois” (“UPS facility”). Respondent used the UPS facility as his address on his letterhead, in pleadings, and on his business cards in his communication with attorneys and members of the public in the following Illinois State Court matters:
Amalgamated Bank of Chicago v. Wauconda Shopping Plaza, LLC, et al, 14 CH 316;
Marayah Diagnostics, LLC v. Westfield Plaza, LLC, et al., 12 CH 22853;
Massad Naim, et al. v. Amin Ijbara Equity Corp., 13 L 3588;
Anwar Elmosa et al., v. Nabil Haffar et al., 12 L 4811; and,
Prime Builders & Development, Inc., et al. v. Allstate Indemnity Co., et al., 15 L 7034.
15. From January 1, 2010 through at least August 2015, Respondent’s representation of the Ghuseins and the other clients referred to in paragraph 14, above, in Illinois legal matters was systematic and continuous and was not temporary.
Disclaimer: these are allegations that have not been proved true before a finder of fact. Salem has filed an answer to these charges which can be found at the ARDC’s website.
Edward X. Clinton, Jr.