Tag: Dishonesty

ARDC Review Board Recommends 60 day suspension for Lawyer Who Created Fake Corporations To Contest a Mechanic’s Lien

A lawyer was hired to defend a mechanic’s lien action. Typically, a mechanic’s lien is filed by a contractor who did work on a construction project. The lien is designed to force the owner of the property to pay the outstanding invoice. Lien law is tricky and complex.

Here the respondent was retained by two homeowners to defend a mechanic’s lien lawsuit. Instead of defending the lien, the respondent created two spurious entities to apparently convince the court that the lien was invalid. The Hearing Board found that this conduct involved dishonesty and false statements to a tribunal and recommended a 30-day suspension. The Review Board increased the suspension to 60 days.

The Review Board recites the facts in this manner:

In July 2011, Respondent began representing David and Jody Bilstrom in a mechanic’s-lien action that was filed against them in 2006 by Artisan Design Build, LLC, a Wisconsin limited liability company. Respondent took over the case after the Bilstroms’ prior counsel withdrew. Respondent believed that he would not have difficulty resolving the matter, because it was his opinion that the mechanic’s lien was invalid.
In the initial complaint, as well as in an amended complaint filed in 2008, the plaintiff was incorrectly named “Artisan Design Build, Inc.” Soon after filing his appearance in the matter, Respondent prepared articles of incorporation for an Illinois entity named “Artisan Design Build, Inc.” – the exact name of the plaintiff as captioned in the complaint and amended complaint. Respondent designated his employee, Steven Schwartz, as the registered agent for Artisan Design Build, Inc. He listed the company’s registered business address as 2101 St. John’s Avenue in Highland Park, Illinois, which was Mr. Schwartz’s home address at the time.
At Respondent’s direction, Mr. Schwartz signed the Articles of Incorporation and filed them with the Illinois Secretary of State. Respondent paid the filing fee. Respondent admitted in his answer to the disciplinary complaint against him that Artisan Design Build, Inc. never undertook any work or transacted any business in Illinois or anywhere else.
On or about July 26, 2011, Respondent drafted a letter to himself purportedly from Mr. Schwartz as the sole shareholder of Artisan Design Build, Inc. Respondent directed his secretary to type the letter and Mr. Schwartz to sign it. The letter stated, among other things, that Mr. Schwartz knew nothing about the lawsuit involving a corporation with the name Artisan Design Build, Inc.; was concerned that the pending lawsuit could have a negative impact on his corporation; and wanted the lawsuit terminated. Respondent admitted at his disciplinary hearing that these statements purportedly by Mr. Schwartz were false, in that Mr. Schwartz knew all about the lawsuit because he was working for Respondent, and was not concerned about the effect of the lawsuit on his corporation.
About nine days after drafting the letter, Respondent drafted and filed a motion to dismiss the complaint against the Bilstroms. In the motion, he argued that the only corporation with the name “Artisan Design Build, Inc.” that has ever been qualified to do business in Illinois was the corporation for which articles of incorporation were filed in July 2011. He attached the July 26 letter signed by Mr. Schwartz and claimed that it was from the individual who filed those articles of incorporation and who is its sole shareholder. He further argued that the plaintiff in the lawsuit had not obtained authority to conduct business in Illinois, never existed in Illinois, and had not paid a franchise tax or license fee, and that its authority to conduct business in Illinois had been revoked, so that it could not maintain a civil action in an Illinois court.
At his disciplinary hearing, Respondent admitted that he did not inform the court that Mr. Schwartz was his employee and had formed the corporation at Respondent’s direction.
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He testified that he believed Artisan Design Build, LLC’s original lien was invalid, and that the company was being sneaky in creating a lien under a different name and foreclosing on that lien, and he wanted the court to understand that that was something that should not be done. He acknowledged that he should have made his points in a straightforward manner rather than by drafting and attaching the letter. He testified that his intent in preparing and attaching the letter was to make sure that Artisan Design Build, LLC could not proceed under the name Artisan Design Build, Inc., and that his goal was to have the plaintiff proceed as Artisan Design Build, LLC. He denied that he was trying to deceive anyone with the letter.
On November 29, 2011, the court granted Artisan Design Build, LLC leave to file a second amended complaint to correct its captioned name, and denied as moot Respondent’s motion to dismiss.
In August 2012, while the mechanic’s-lien lawsuit was still pending, the Bilstroms sought to get a mortgage from a bank. The bank was concerned about the litigation and wanted to make sure that the mechanic’s lien did not exist. Respondent provided a title report that did not show the lien and offered to provide his professional opinion that the lien was invalid, but that was not sufficient to assuage the bank’s concern about the litigation. According to Respondent, the bank wanted “external documentation.”
Respondent thus drafted a “Release of Mechanic’s Lien” using the same lien number as the one that Artisan Design Build, LLC had recorded in 2006. The purported release listed the lienholder’s name as “Artisan Design Build, Inc.” and stated that Artisan Design Build, Inc. released the claim for lien against the Bilstroms and authorized the DuPage County Recorder of Deeds to enter satisfaction and release of the lien.

Respondent directed his employee Mr. Schwartz, as registered agent for Artisan Design Build, Inc., to sign the release, and directed his secretary to notarize it. Respondent or
someone acting at his direction presented the purported release to the DuPage County Recorder of Deeds and caused it to be recorded. Respondent paid the filing fee.
At his hearing, Respondent admitted he knew that Artisan Design Build, Inc. did not file a lien; that, at no time on or after the date the lien was filed, had the mechanic’s lien been satisfied or released; that, at no time did he have the authority of Artisan Design Build, LLC to release the mechanic’s lien; and that Mr. Schwartz did not have authority to release the lien.
A few weeks after filing the purported release, Respondent realized the release referred to “Artisan Design Build, Inc.” instead of “Artisan Design Build, LLC,” so he drafted a second release for the same lien number, but under the name of “Artisan Design Build, LLC.” Respondent directed Mr. Schwartz to sign, and his secretary to notarize, the second release. He presented the second release to the DuPage County Recorder of Deeds and caused the release to be recorded. He paid the filing fee.
Respondent admitted that Artisan Design Build, LLC did not satisfy or release the mechanic’s lien; that he knew that Mr. Schwartz was not authorized to release the lien; that Artisan Design Build, LLC did not authorize him to release the lien; and that he had no rights in the Artisan Design Build, LLC name.
In September 2012, Respondent or someone acting at his direction filed an application to cancel the assumed corporate name of Artisan Design Build, Inc. At Respondent’s direction, Mr. Schwartz signed the application as the company’s president. On the same day, to comport with the information in the second purported release, Respondent drafted and caused to be filed with the Illinois Secretary of State articles of incorporation for an entity named “Artisan Design Build, LLC,” with the same registered business address as Artisan Design Build, Inc. – Mr. Schwartz’s home address. Respondent directed Mr. Schwartz to sign the articles of incorporation for Artisan Design Build, LLC as its manager. Respondent paid the filing fee.
Respondent admitted that Artisan Design Build, LLC, the Illinois company that he organized, never transacted business in Illinois, and that neither he nor Mr. Schwartz transacted business on behalf of Artisan Design Build, LLC in Illinois.
At his hearing, Respondent testified that he created the purported releases because the bank wanted outside documentation. He testified that he knew the liens “were gone” and “invalid to begin with.” He testified that he did not think he was doing anything wrong because he “was filing a release of something that didn’t exist,” so “wasn’t releasing anything.” He testified that he had planned to use the releases, but did not use them outside of recording them.

My opinion: given the amount of deceptive conduct involved here and the creation of fake documents purporting to release mechanic’s liens and the failure to express remorse, I’m surprised the suspension was for only 60 days. For anyone who is facing a harsh penalty, this case can be used as an example of why your client should not be suspended for more than 60 days.

Edward X. Clinton, Jr.

www.clintonlaw.net

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ARDC Accuses Lawyer of Defrauding Blue Cross

BEFORE THE HEARING BOARD:

The ARDC has accused a lawyer of defrauding Blue Cross to obtain maternity coverage. The ARDC alleges that the lawyer wrongfully claimed to be employed by a company where her father worked.

Comment: if true, the allegations are serious and will merit discipline. This illustrates the trouble people have in getting insurance in the United States, particularly those who work in small firms. That difficulty, however, is no excuse and Blue Cross has a right to be made whole.

Edward X. Clinton, Jr.

www.chicagolegalmalpracticelawyerblog.com

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Report: Trump’s Private Attorney Tells White House Staff Not To Lawyer Up – Talking Points Memo

Report: Trump’s Private Attorney Tells White House Staff Not To Lawyer Up – Talking Points Memo:

This post is not about politics, but it is very important.

Trump hired Marc Kasowitz, an attorney, to defend him. Kasowitz has told other White House staffers not to get their own lawyers. If you are part of an organization and you are advised not to retain an attorney by an attorney, think long and hard before following this advice.

The other guy’s lawyer (in this case Marc Kasowitz) has no duty to you and, indeed, does not care about you at all. He might be planning to throw you under the bus to save his own client.

In sum, if you had some meaningful conduct that might be questioned, you should seek legal advice immediately.

Being told you don’t need a lawyer, means that you probably need one!

Edward X. Clinton, Jr.

www.clintonlaw.net

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Idaho Reprimands Lawyer For Misleading Communications

Notice of Public Discipline | Idaho State Bar:

A lawyer was given a public reprimand by the Professional Conduct Board of the Idaho State Bar for violating Rule 7.1 (communications concerning a lawyer’s services and Rule 7.3(a) (solicitation of clients). Essentially the Board found that the lawyer’s communications to a sales representative and to certain homeowners were misleading.

This disciplinary case related to Mr. Winward’s communications with sales representatives of a Boise homebuilder and his communications with two homeowners who had purchased homes from that homebuilder. Mr. Winward falsely indicated to the sales representatives that he was interested in buying a home from the homebuilder. He also falsely indicated to homeowners that he represented another homeowner regarding the homebuilder’s allegedly defective foundations. Although not Respondent’s intent, the homeowners understood from their communications with Respondent that their foundations may be defective and that Respondent was offering to provide legal services to pursue a lawsuit on behalf of homeowners regarding the allegedly defective foundations. Bar Counsel considered as mitigation the fact that Mr. Winward sought the advice of counsel regarding his communications with the homeowners.

Edward X. Clinton, Jr.

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www.clintonlaw.net

Ohio Supreme Court Suspends Lawyer Indefinitely For Dishonesty In Several Matters

CLEVELAND METROPOLITAN BAR ASSOCIATION v. DONCHATZ, 2017 Ohio 2793 – Ohio: Supreme Court 2017 – Google Scholar:

This case is worth reading because it is a summary of all the ways a lawyer can get himself in serious trouble. There were four allegations of misconduct, and all were found proven.

The first allegation was that a creditor obtained a judgment against the lawyer. Rather than paying the judgment, the lawyer forged and filed a satisfaction of judgment with the Court. The Ohio Supreme Court found:

¶ 7} Thereafter, Davey Tree’s counsel informed Donchatz that a balance remained due and asked him to withdraw the satisfaction of judgment. Donchatz confirmed that the judgment remained unpaid, but he did not withdraw his filing. The court later granted Davey Tree’s motion to vacate the satisfaction and reinstated the judgment.{¶ 8} In October 2013, more than three years after the default judgment was entered and nearly 18 months after it was reinstated, Donchatz moved the court to reconsider the default judgment. Determining that the motion was frivolous and without merit, the court denied it and awarded sanctions to Davey Tree. But Donchatz did not pay the judgment or sanctions until April 15, 2014.{¶ 9} Based on this conduct, the board found that Donchatz violated Prof.Cond.R 3.1 (prohibiting a lawyer from bringing or defending a proceeding that is unsupported by law or lacks a good-faith argument for an extension, modification, or reversal of existing law), 3.3(a)(1) (prohibiting a lawyer from knowingly making a false statement of fact or law to a tribunal), 3.4(c) (prohibiting a lawyer from knowingly disobeying an obligation under the rules of a tribunal), 8.4(c) (prohibiting a lawyer from engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation), and 8.4(d) (prohibiting a lawyer from engaging in conduct that is prejudicial to the administration of justice). We adopt these findings of fact and misconduct.

The second matter involved the lawyer’s business transaction with his client, in which he borrowed $100,000 from a client.

The findings:

{¶ 12} At the hearing, Donchatz admitted that he accepted the $100,000 check from Cracknell without providing the written notices required by Prof.Cond.R. 1.8(a) (prohibiting a lawyer from entering into a business transaction with a client unless the client is advised in writing of the desirability of obtaining independent legal counsel and the terms of the transaction are fair, reasonable, and fully disclosed in a writing signed by the client) and therefore violated the rule the moment he took the loan. In addition to finding a violation of that rule, the board found that he violated Prof.Cond.R. 1.5(b) (requiring an attorney to communicate the basis or rate of the fee and expenses within a reasonable time after commencing the representation, preferably in writing). Donchatz does not dispute these findings of fact or misconduct, and after independently reviewing the record, we adopt them.

The third allegation of wrongdoing concerned a disciplinary matter in which the lawyer wrongfully accused the attorney prosecuting the disciplinary action of wrongfully hiding evidence. Because the allegations were baseless, the court concluded that the attorney had violated several rules. It explained:

{¶ 16} The board found that by filing the motion in limine that contained false statements and misrepresentations, Donchatz violated Prof.Cond.R 3.1, 3.3(a)(1), 3.4(c), 8.4(c) (prohibiting a lawyer from engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation), and 8.4(d)

In the fourth matter, the attorney became involved in a fee dispute with a client. He engaged in mediation with the client but prepared a purported stipulation of judgment, when the other party had not agreed to any such stipulation.

The finding: {¶ 30} Before the board, Donchatz argued that the “stipulated entry and consent judgment” was proper under Loc.R. 25.01 of the Court of Common Pleas of Franklin County, General Division. As explained below, however, the board determined that Loc.R. 25.01 did not apply in this case. And, based on the foregoing, the board found that by filing the “stipulated entry and consent judgment,” Donchatz violated Prof.Cond.R. 3.1, 3.3(a)(1), 3.4(c), 8.4(c), and 8.4(d).

The court suspended the lawyer indefinitely. The court relied upon what it found to be significant dishonesty in three of the four matters.

Edward X. Clinton, Jr.

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ARDC Accuses Lawyer of Converting Bond Refunds

BEFORE THE HEARING BOARD:

The ARDC has accused an attorney of converting bond refunds that were due to his clients. When a defendant is arrested he can often post a bond to allow him to remain free while the case is proceeding through the courts. Here, the ARDC has alleged that in four instances the attorney received a refund of the bond at the conclusion of the criminal case and that he was required to deposit the refund in his trust account and pay it (minus his legal fees) to the defendant.

These allegations have not been proven and there has been no finding of fact.

Edward X. Clinton, Jr.

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ARDC Accuses Lawyer of Creating False Documents in Loan Transaction

BEFORE THE HEARING BOARD:

The ARDC has accused a lawyer of creating false documents in a loan transaction. The pertinent allegations are these:

“2. In late 2010 or early 2011, Respondent was engaged in discussions with another lender, Prime Equity of Atlanta, Georgia, about borrowing $25,000 from Prime Equity. Respondent intended to use the proceeds of that loan to reduce the amount of LOP’s obligation to American Community. Prime Equity told Respondent that it would not lend the money to LOP unless Prime Equity received a first security interest in the Stephens County property, which would require American Community to agree to subordinate its own security interest in that property.

3. On or about January 10, 2011, Respondent created a document entitled “Subordination Agreement” that purported to show that American Community had “waive[d] and subordinate[d] all right, title or interest under its outstanding security deed in or to the [Stephens County] property as against the loan to be made by [Prime Equity] to [LOP] so that the security deed to be executed by [LOP] to [Prime Equity] shall convey title to the property superior to the outstanding security deed of [American Community] and superior to the indebtedness secured thereby.” Respondent added the purported signatures of American Community’s executive vice president (Rick Francois) and chief financial officer (Robert W. Getty) to the document, and then added the purported signature and notary stamp of Mark Taranelli, a notary and attorney with whom Respondent was acquainted.

4. At no time did Respondent request or receive authority from anyone at American Community to take any action concerning the Stephens County property on the bank’s behalf, nor did he have the authority of Mr. Francois, Mr. Getty or Mr. Tarinelli to add their purported signatures (and, in Mr. Tarinelli’s case, to use his notary stamp) on the purported agreement.

5. Respondent knew that the purported subordination agreement was false, because he knew that American Community had not agreed to waive or subordinate its interest in the Stephens County property, and because he knew that he had created the document and affixed purported signatures and a notary stamp to it without authority.

6. After he prepared the purported subordination agreement, Respondent delivered the document to representatives of Prime Equity in order to induce that entity to lend $25,000 to LOP based on the false representation that American Community had agreed to subordinate its interest in the Stephens County property. Respondent then caused the purported subordination agreement to be filed with the office of the Clerk of the Superior Court for Stephens County, Georgia.

7. On or about June 1, 2012, Respondent created a second document, entitled “Cancellation of Subordination Agreement,” that purported to show that American Community had cancelled the agreement described in paragraphs three through six, above. Respondent then added the purported signature of Mr. Francois and the purported signature and notary stamp of Mr. Taranelli to the document, which Respondent later caused to be filed with the office of the Clerk of the Superior Court for Stephens County, Georgia.

8. At no time did Respondent request or receive authority from anyone at American Community to take any action concerning the bank’s interest in the Stephens County property, nor did he have the authority of Mr. Francois or Mr. Tarinelli to add their purported signatures (and, in Mr. Tarinelli’s case, to use his notary stamp) on the purported cancellation document.

9. Respondent knew that the purported cancellation of the subordination agreement was false, because he knew that he had created the document, that he did not have authority from anyone at American Community to take any action on the bank’s behalf, and because he had affixed purported signatures and a notary stamp to the document without authority.

10. By reason of the conduct described above, Respondent has engaged in the following misconduct: conduct involving dishonesty, fraud, deceit or misrepresentation, by knowingly creating and signing documents without authority that contained false signatures and notary stamps, in violation of Rule 8.4(c) of the Illinois Rules of Professional Conduct (2010).

In sum, these are allegations and have not been proven. The ARDC tends to be very concerned about cases where lawyers created false documents.

Edward X. Clinton, Jr.

The ARDC Claims Patent Lawyer Was Not Diligent And Deceived Clients

BEFORE THE HEARING BOARD:

The ARDC has brought a complaint against Jerry Allen Schulman (“Respondent”) and has alleged that the Respondent allowed numerous patent applications and trademarks to become abandoned because he did not respond to correspondence from the United States Patent Office. Unfortunately, the lawyer also allegedly made false representations to the clients that their patent applications were pending and proceeding normally. In Count II of the Complaint, the Administrator alleges as follows:

12. Respondent did not communicate to ASICO that the applications referred to in Count I had been abandoned. Periodically, Respondent would provide ASICO with a document called the “ASICO PATENT DOCUMENT” that purported to give the status of each of the company’s patent applications. These dockets did not show that the patent applications had been abandoned. In fact, many of the patents had been abandoned, and Respondent knew that but did not include that information on the chart, in an effort to conceal his inaction from his client.
13. In many instances, the dockets stated that action had been taken by Respondent and the application was “awaiting action,” presumably by the USPTO.
14. For example, Respondent had a docket dated June 17, 2009 (“Sample Docket”). The Sample Docket falsely stated that patent application number 11/534,573 was “pending.” In fact, that application had been abandoned on June 15, 2007. Respondent knew that his statement that patent application number 11/534,573 was pending was false, because he knew the application had been abandoned.

15. The Sample Docket did not show that patent application 11/864,865 had been abandoned on June 12, 2008. On June 17, 2009, Respondent knew that the application had been abandoned, but chose not to include that with the information conveyed to ASICO.
16. The Sample Docket falsely stated that patent application number 12/050,167 was “undergoing preexam processing.” In fact, the application had been abandoned on December 2, 2008. Respondent knew that his statement that patent application 12/050,167 was undergoing preexam processing was false, because he knew the application had been abandoned.
17. The Sample Docket falsely stated that patent application number 12/263,315 was “undergoing preexam processing.” In fact, Respondent had received a Notice to File Missing Parts on November 18, 2008, a notice to which Respondent never provided a response. Respondent knew that his statement that patent application number 12/263,315 was undergoing preexam processing was false, because he knew that he had received the Notice to File Missing Parts.
18. The Sample Docket falsely stated that patent application number 12/408,715 was filed and awaiting action. In fact, Respondent had received a Notice to File Missing Parts on April 15, 2009, a notice to which Respondent never provided a response. Respondent knew that his statement that patent application number 12/408,715 was awaiting action was false, because he knew he had received the Notice to File Missing Parts.

19. Respondent also prepared another document he titled “ASICO Trademarks.” This charts purported to represent the status” of each ASICO trademark that Respondent handled. The charts do not show that some of the trademark applications had been abandoned. Respondent knew that some of the trademark applications had been abandoned but did not convey that information to ASICO.
20. Respondent knew that the representations he made to ASICO regarding the status of the patent and trademark applications were false because he had received notices from the USPTO advising him that the applications had been abandoned due to his inaction.
21. By reason of the conduct described above, Respondent has engaged in the following misconduct:
conduct involving dishonesty, fraud, deceit or misrepresentation by providing ASICO with charts purporting to show the status of patent and trademark applications that contained false statements, or intentionally omitted truthful information in an effort to conceal his inactivity, in violation of Rule 8.4(a)(4) of the Illinois Rules of Professional Conduct (1990 and 2010).

Comment: these allegations have not been proven and the Respondent has not filed his response to the complaint. What made this case interesting for the ARDC was the repeated efforts to deceive the client that the patent and trademark applications were pending.

Edward X. Clinton, Jr.

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Arizona Attorney Disciplined For Misrepresenting Prior Discipline To An Employer

The presiding disciplinary judge has ordered a 30 day suspension of Patrick Camunez. The case is captioned In the Matter of a Member of The State Bar of Arizona, Bar No. 028662.

The attorney was previously disciplined. He then failed to accurately report the prior discipline when he applied for a general counsel position.

The decisions explains that: “Mr. Camunez’s transgressions arose when he misrepresented to a potential employer the substance of his prior disciplinary offenses. Mr. Camunez was admonished by the Attorney Discipline Probable Cause Committee on August 29, 2014, for “alter[ing] an e-mail he obtained from the Office of the Chief Counsel, National Guard Bureau, to help facilitate his efforts to secure a promotion while serving in the Arizona National Guard as a civilian government attorney.” While interviewing for a general counsel position in February 2015, Mr. Camunez misrepresented that he was disciplined in 2014 for failing to report a supervisor’s breach of attorney/client privilege, not for altering an e-mail.”

The decision explains the rationale for the discipline as follows: “The truth matters. The object of lawyer discipline is to protect the public, the legal profession, the administration of justice, and to deter other attorneys from engaging in unprofessional conduct. In re Peasley, 208 Ariz. 27, 38, 90 P.3d 764, 775 (2004). When the truth is not accepted, but instead covered over, then the insights of attorney discipline may never take root and grow. Whatever the cause, Mr. Camunez is encouraged to identify it, uproot it, and determine to be truthful. While attorney discipline is not intended to punish the offending attorney, the sanctions imposed may have that incidental effect. Id. As the proposed sanction of suspension and probation meets the objectives of discipline, it is accepted.”

This is a rare case where an attorney was disciplined for statements made to a potential employer.

Edward X. Clinton, Jr.

ARDC Charges Lawyer With Wrongfully Obtaining Opposing Party’s Credit Report

BEFORE THE HEARING BOARD:

The ARDC has charged a lawyer with wrongfully obtaining a credit report of the opposing party. Obtaining a credit report would not normally be a problem. However, if the allegations are true, the lawyer misrepresented his identity in seeking the report.

These are the key allegations:

“ On April 29, 2014, Respondent entered his appearance on behalf of Bozena Wysocki (“Bozena”) in her petition for dissolution of marriage from her husband, Jacek Wysocki (“Jacek”), in Cook County Circuit Case No. 2013 D 7670.

2. Between April 29, 2014, and December 5, 2014, through the course of pretrial discovery, Respondent obtained Jacek’s personal identifying information, including his social security number, as well as information concerning Jacek’s financial history.

3. On or about December 5, 2014, Respondent visited the website http://www.creditreport.com, an online consumer credit reporting site which allows consumers to access their own credit reports.

4. Pursuant to 15 U.S.C. § 1681q, any person who knowingly and willfully obtains information on a consumer from a consumer reporting agency under false pretenses shall be fined, imprisoned for not more than two years, or both.

5. On or about December 5, 2014, Respondent entered Jacek’s identifying information, including Jacek’s name, address, date of birth, and social security number, into the http://www.creditreport.com website for the purpose of obtaining Jacek’s credit report.

6. On or about December 5, 2014, Respondent obtained Jacek’s credit report from the http://www.creditreport.com website.”

These allegations have not been proven.

Edward X. Clinton, Jr.

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