State Bar Court of California

Hearing Department

STIPULATION RE FACTS, CONCLUSIONS OF LAW AND DISPOSITION AND ORDER APPROVING

STAYED SUSPENSION; NO ACTUAL SUSPENSION

Case Number(s): 08-O-11773, 10-O-07590

In the Matter of: Steven Zelig, Bar # 94654, A Member of the State Bar of California, (Respondent).

Counsel For The State Bar: Katherine Kinsey, State Bar of California, 1149 S. Hill Street, Los Angeles, CA 90015, 213-765-1503, Bar# 183740

Counsel for Respondent: Arthur L. Margolis, Margolis & Margolis LLP, 2000 Riverside Dr., Los Angeles, CA 90039, 323-953-8996, Bar # 57703

Submitted to: Settlement Judge, State Bar Court Clerk’s office Los Angeles .

Filed: 09/12/2011

  <<not>> checked. PREVIOUS STIPULATION REJECTED

Note:  All information required by this form and any additional information which cannot be provided in the space provided, must be set forth in an attachment to this stipulation under specific headings, e.g., "Facts," "Dismissals," "Conclusions of Law," "Supporting Authority," etc.

A. Parties' Acknowledgments:

1.      Respondent is a member of the State Bar of California, admitted December 16, 1980.

2.      The parties agree to be bound by the factual stipulations contained herein even if conclusions of law or disposition are rejected or changed by the Supreme Court.

3.      All investigations or proceedings listed by case number in the caption of this stipulation are entirely resolved by this stipulation and are deemed consolidated. Dismissed charge(s)/count(s) are listed under "Dismissals."  The stipulation consists of 12 pages, not including the order.

4.      A statement of acts or omissions acknowledged by Respondent as cause or causes for discipline is included under "Facts."

5.      Conclusions of law, drawn from and specifically referring to the facts are also included under "Conclusions of Law".

6.      The parties must include supporting authority for the recommended level of discipline under the heading "Supporting Authority."

7.      No more than 30 days prior to the filing of this stipulation, Respondent has been advised in writing of any pending investigation/proceeding not resolved by this stipulation, except for criminal investigations.

8.      Payment of Disciplinary Costs-Respondent acknowledges the provisions of Bus. & Prof. Code §§6086.10 & 6140.7. (Check one option only):

checked. Costs are added to membership fee for calendar year following effective date of discipline.

<<not>> checked. Costs are to be paid in equal amounts prior to February 1 for the following membership years:  (Hardship, special circumstances or other good cause per rule 5.132, Rules of Procedure.)  If Respondent fails to pay any installment as described above, or as may be modified by the State Bar Court, the remaining balance is due and payable immediately.

<<not>> checked. Costs are waived in part as set forth in a separate attachment entitled "Partial Waiver of Costs".

<<not>> checked. Costs are entirely waived.

B. Aggravating Circumstances [for definition, see Standards for Attorney Sanctions for Professional Misconduct, standard 1.2(b)]. Facts supporting aggravating circumstances are required.

<<not>> checked. (1)      Prior record of discipline [see standard 1.2(f)].

<<not>> checked. (a)           State Bar Court case # of prior case** .
<<not>> checked. (b)           Date prior discipline effective** .
<<not>> checked. (c)           Rules of Professional Conduct/ State Bar Act violations:**
<<not>> checked. (d)          Degree of prior discipline**
<<not>> checked. (e)           If Respondent has two or more incidents of prior discipline, use space provided below or a separate attachment entitled “Prior Discipline”. ** .

<<not>> checked. (2)      Dishonesty:  Respondent's misconduct was surrounded by or followed by bad faith, dishonesty, concealment, overreaching or other violations of the State Bar Act or Rules of Professional Conduct. 

<<not>> checked. (3)      Trust Violation:  Trust funds or property were involved and Respondent refused or was unable to account to the client or person who was the object of the misconduct for improper conduct toward said funds or property.

<<not>> checked. (4)      Harm:  Respondent's misconduct harmed significantly a client, the public or the administration of justice.

<<not>> checked. (5)      Indifference:  Respondent demonstrated indifference toward rectification of or atonement for the consequences of his or her misconduct.

<<not>> checked. (6)      Lack of Cooperation:  Respondent displayed a lack of candor and cooperation to victims of his/her misconduct or to the State Bar during disciplinary investigation or proceedings. 

checked. (7)                     Multiple/Pattern of Misconduct:  Respondent's current misconduct evidences multiple acts of wrongdoing or demonstrates a pattern of misconduct.

<<not>> checked. (8)      No aggravating circumstances are involved.

Additional aggravating circumstances:

C. Mitigating Circumstances [see standard 1.2(e)]. Facts supporting mitigating circumstances are required.

<<not>> checked. (1)      No Prior Discipline:  Respondent has no prior record of discipline over many years of practice coupled with present misconduct which is not deemed serious.

<<not>> checked. (2)      No Harm:  Respondent did not harm the client or person who was the object of the misconduct. 

<<not>> checked. (3)      Candor/Cooperation:  Respondent displayed spontaneous candor and cooperation with the victims of his/her misconduct and to the State Bar during disciplinary investigation and proceedings. 

<<not>> checked. (4)      Remorse:  Respondent promptly took objective steps spontaneously demonstrating remorse and recognition of the wrongdoing, which steps were designed to timely atone for any consequences of his/her misconduct. 

<<not>> checked. (5)      Restitution:  Respondent paid $ **  on **  in restitution to **  without the threat or force of disciplinary, civil or criminal proceedings.

<<not>> checked. (6)      Delay:  These disciplinary proceedings were excessively delayed.  The delay is not attributable to Respondent and the delay prejudiced him/her.

<<not>> checked. (7)      Good Faith:  Respondent acted in good faith.

<<not>> checked. (8)      Emotional/Physical Difficulties:  At the time of the stipulated act or acts of professional misconduct Respondent suffered extreme emotional difficulties or physical disabilities which expert testimony would establish was directly responsible for the misconduct.  The difficulties or disabilities were not the product of any illegal conduct by the member, such as illegal drug or substance abuse, and Respondent no longer suffers from such difficulties or disabilities.

<<not>> checked. (9)      Severe Financial Stress:  At the time of the misconduct, Respondent suffered from severe financial stress which resulted from circumstances not reasonably foreseeable or which were beyond his/her control and which were directly responsible for the misconduct.

checked. (10)                   Family Problems:  At the time of the misconduct, Respondent suffered extreme difficulties in his/her personal life which were other than emotional or physical in nature. During the period of misconduct, Respondent was caring for a son who had been diagnosed with tuberous sclerosis and was developmentally delayed. In addition, Respondent provided core to his parents, who both became ill during the period in question and provided care to another family member who experienced difficulties.

<<not>> checked. (11)    Good Character:  Respondent's good character is attested to by a wide range of references in the legal and general communities who are aware of the full extent of his/her misconduct.

<<not>> checked. (12)    Rehabilitation:  Considerable time has passed since the acts of professional misconduct occurred followed by convincing proof of subsequent rehabilitation.

<<not>> checked. (13)    No mitigating circumstances are involved.

Additional mitigating circumstances: Respondent was admitted to the practice of law on December 16, 1980 and has no prior record of discipline.

D. Discipline:

checked. (1)                     Stayed Suspension:

checked. (a)              Respondent must be suspended from the practice of law for a period of (1) year.
<<not>> checked. i. and until Respondent shows proof satisfactory to the State Bar Court of rehabilitation and present fitness to practice and present learning and ability in the law pursuant to standard 1.4(c)(ii) Standards for Attorney Sanctions for Professional Misconduct.
<<not>> checked. ii.     and until Respondent pays restitution as set forth in the Financial Conditions form attached to this stipulation.
<<not>> checked. iii.    and until Respondent does the following: ** .
The above-referenced suspension is stayed.

checked. (2)                     Probation:  Respondent must be placed on probation for a period of 2 years, which will commence upon the effective date of the Supreme Court order in this matter.  (See rule 9.18, California Rules of Court.)

E. Additional Conditions of Probation:

checked. (1)                     During the probation period, Respondent must comply with the provisions of the State Bar Act and Rules of Professional Conduct.

checked. (2)                     Within ten (10) days of any change, Respondent must report to the Membership Records Office of the State Bar and to the Office of Probation of the State Bar of California ("Office of Probation"), all changes of information, including current office address and telephone number, or other address for State Bar purposes, as prescribed by section 6002.1 of the Business and Professions Code.

checked. (3)                     Within thirty (30) days from the effective date of discipline, Respondent must contact the Office of Probation and schedule a meeting with Respondent's assigned probation deputy to discuss these terms and conditions of probation. Upon the direction of the Office of Probation, Respondent must meet with the probation deputy either in-person or by telephone. During the period of probation, Respondent must promptly meet with the probation deputy as directed and upon request.

checked. (4)                     Respondent must submit written quarterly reports to the Office of Probation on each January 10, April 10, July 10, and October 10 of the period of probation. Under penalty of perjury, Respondent must state whether Respondent has complied with the State Bar Act, the Rules of Professional Conduct, and all conditions of probation during the preceding calendar quarter. Respondent must also state whether there are any proceedings pending against him or her in the State Bar Court and if so, the case number and current status of that proceeding. If the first report would cover less than 30 days, that report must be submitted on the next quarter date, and cover the extended period.
In addition to all quarterly reports, a final report, containing the same information, is due no earlier than twenty (20) days before the last day of the period of probation and no later than the last day of probation.

<<not>> checked. (5)      Respondent must be assigned a probation monitor. Respondent must promptly review the terms and conditions of probation with the probation monitor to establish a manner and schedule of compliance. During the period of probation, Respondent must furnish to the monitor such reports as may be requested, in addition to the quarterly reports required to be submitted to the Office of Probation. Respondent must

checked. (6)                     Subject to assertion of applicable privileges, Respondent must answer fully, promptly and truthfully any inquiries of the Office of Probation and any probation monitor assigned under these conditions which are directed to Respondent personally or in writing relating to whether Respondent is complying or has complied with the probation conditions.

checked. (7)                     Within one (1) year of the effective date of the discipline herein, Respondent must provide to the Office of Probation satisfactory proof of attendance at a session of the Ethics School, and passage of the test given at the end of that session.

<<not>> checked. No Ethics School recommended.  Reason:

<<not>> checked. (8)      Respondent must comply with all conditions of probation imposed in the underlying criminal matter and must so declare under penalty of perjury in conjunction with any quarterly report to be filed with the Office of Probation.

<<not>> checked. (9)      The following conditions are attached hereto and incorporated: 

<<not>> checked. Substance Abuse Conditions.

<<not>> checked. Law Office Management Conditions.

<<not>> checked. Medical Conditions.

<<not>> checked. Financial Conditions.

F. Other Conditions Negotiated by the Parties:

checked. (1)                     Multistate Professional Responsibility Examination:  Respondent must provide proof of passage of the Multistate Professional Responsibility Examination ("MPRE"), administered by the National Conference of Bar Examiners, to the Office of Probation within one year.  Failure to pass the MPRE results in actual suspension without further hearing until passage. But see rule 9.10(b), California Rules of Court, and rule 5.162(A) & (E), Rules of Procedure.

<<not>> checked. No MPRE recommended.  Reason:  .

checked. (2)                     Other Conditions:

PAYMENT OF SANCTIONS:

Within thirty (30) days from the effective date of discipline in these matters, Respondent shall pay the sanctions as ordered by the court in the underlying matters as set forth below:

Case number 08-O-11773 Party Owed Scottsdale Insurance Company Amount $8,250

Case number 08-O-11773 Party Owed Scottsdale Insurance Company Amount $7,500

Respondent must provide to the Office of Probation satisfactory proof of the payments made by Respondent during the applicable reporting period. Such proof must be in a form satisfactory to the Office of Probation

 

ATTACHMENT TO

STIPULATION RE FACTS, CONCLUSIONS OF LAW AND DISPOSITION

 

IN THE MATTER OF: Steven Zelig, State Bar No. 94654

STATE BAR COURT CASE NUMBER: 08-O-11773, 10-O-07590

FACTS AND CONCLUSIONS OF LAW

Respondent admits that the following facts are true and that he is culpable of violations of the specified statutes and/or Rules of Professional Conduct.

 

Case No. 08-O-11773 (State Bar Investigation)

 

Facts related to Regency Complaint

1. On January 17, 1994, Regency Royale Homeowners Association ("Regency") allegedly sustained damaged in the Northridge earthquake. In June 1994, Regency submitted an application for earthquake insurance to Scottsdale Insurance Company ("Scottsdale") stating that it had sustained no losses in the previous five years and Scottsdale issued insurance coverage to Regency.

2. On December 31, 2001, in pursuit of Regency’s earthquake insurance claim, Respondent filed a civil action against Scottsdale entitled Waldman et al. v. Golden Bear et al., Los Angeles County Superior Court, case no. BC265308 (the "Regency complaint").

3. Between January 2002 and May 2002, Scottsdale informed Regency’s insurance adjuster that Scottsdale did not insure Regency until six months after the Northridge earthquake. On July 8, 2002, Respondent served the Regency complaint on Scottsdale.

4. In October 2002, Scottsdale provided documentation in discovery showing that Scottsdale issued its insurance policy to Regency six months after the Northridge earthquake. In addition, Regency’s insurance adjuster told Respondent’s office that Farmers and State Farm insured Regency’s property at the time of the earthquake. However, Respondent did not dismiss the Regency complaint. Subsequently, new counsel associated in as counsel for Regency, acknowledged that Scottsdale was not the proper insurer and dismissed Scottsdale from Regency complaint. Scottsdale incurred in excess of $30,000 in attorney’s fees related to the Regency complaint.

5. On September 10, 2004, Scottsdale filed a malicious prosecution complaint against Respondent and others in order recoup the attorney’s fees from the Regency complaint (the "Scottsdale action").

6. On January 29, 2007, the parties reached a settlement in the Scottsdale action. Pursuant to the settlement, Respondent agreed to pay Scottsdale $45,000 within 45 days. Thereafter, Respondent failed to pay the settlement.

7. Therefore, on March 22, 2007, Scottsdale filed a motion for entry of judgment against Respondent’s law office, which the court granted. On April 3, 2007, the judgment was entered.  

8. As of April 13, 2007, Respondent had not paid the judgment, and Scottsdale filed a motion to amend the judgment to add Respondent personally. In its motion, Scottsdale noted that Respondent had previously testified that he and the law office were one and the same. Respondent opposed the motion to amend.

9. On May 16, 2007, the court in the Scottsdale action granted Scottsdale’s motion and entered an amended judgment against Respondent for $45,000. On June 4, 2007, Respondent appealed the court’s May 16, 2007 ruling (the "judgment appeal")

10. On February 19, 2008, Scottsdale filed a motion for sanctions arguing that the judgment appeal was frivolous.

11. On February 21, 2008, the Court of Appeal wrote Respondent a letter notifying him that he had ten days from the date of the letter to file a supplemental letter in opposition to the imposition of sanctions. On March 10, 2008, Respondent filed opposition to the imposition of sanctions.

12. On April 10, 2008, the Court of Appeal issued an opinion denying the judgment appeal. In its opinion, the Court of Appeal stated that there was substantial evidence supporting the trial court’s order naming Respondent as a judgment debtor and stated that it had little trouble finding Respondent’s appeal to be frivolous. Specifically, the Court of Appeal stated that the appeal indisputably had no merit, appeared to have been filed for the improper purpose of delaying the effect of the judgment adverse to Respondent and continued a pattern throughout the case of abusing the legal system.

13. In the April 10, 2008 order, the Court of Appeal affirmed the judgment and ordered

Respondent to pay $8,250 in sanctions to Scottsdale for prosecuting the judgment appeal. The Court of Appeal ordered Respondent to pay the sanctions within 30 days after the issuance of the remittitur or by July 12, 2008. Respondent was properly served with the court’s order.

14. Respondent did not pay the $8,250 in sanctions as ordered by the Court of Appeal in the judgment appeal.

 

Facts Related to Respondent’s Cross-Complaint

15. On February 14, 2005, Respondent’s law office filed a cross-complaint against Regency, Condominium Administration Company, Inc. ("CAC") and a third cross-defendant in the Scottsdale action.

16. On March 10, 2005, Regency filed an answer to Respondent’s cross-complaint.

17. On July 17, 2006, after a trial date had been set in the Scottsdale action and without leave of the court, Respondent and his law office filed another cross-complaint against Scottsdale, Regency, CAC and additional cross-defendants.

18. Regency and CAC filed motions to strike the July 17, 2006 cross-complaint on the grounds that Respondent did not obtain leave of the court before filing another cross-complaint. On or about September 25, 2006, the trial court granted the motions. On November 27, 2006, Respondent appealed the trial court’s September 25, 2006 ruling.

19. On November 30, 2006, an attorney for Scottsdale wrote a letter to Respondent asking him to dismiss his appeal because the court’s September 25, 2006 order was not appealable. Respondent received the letter but did not dismiss the appeal.

20. On September 17, 2007, Scottsdale filed a motion to dismiss the appeal and on or about October 10, 2007, Respondent filed opposition to the motion to dismiss.

21. On November 13, 2007, the Court of Appeal granted the motion to dismiss and imposed $7,500 in sanctions against Respondent on the grounds that Respondent’s appeal was frivolous. Respondent was properly served with the Court of Appeal’s order.

22. Respondent did not pay the $7,500 in sanctions as ordered by the Court of Appeal.

23. On or about May 13, 2008, Respondent untimely reported to the State Bar of California that sanctions exceeding $1,000 were imposed against him.

 

CONCLUSIONS OF LAW

By pursing a frivolous appeal before the California Court of Appeal related to the Regency complaint, Respondent failed to maintain such action, proceedings, or defenses only as appear to him legal or just in willful violation of Business and Professions Code, section 6068(c).

By failing to pay the $8,250 in sanctions as ordered by the Court of Appeal in the Regency complaint, Respondent disobeyed or violated an order of the court requiring him to do or forbear an act connected with or in the course of Respondent’s profession which he ought in good faith to do or forbear in willful violation of Business and Professions Code, section 6103.

By failing to pay the sanctions as ordered by the Court of Appeal and arising out of Respondent’s cross-complaint, Respondent disobeyed or violated an order of the court requiring him to do or forbear an act connected with or in the course of Respondent’s profession which he ought in good faith to do or forbear in willful violation of Business and Professions Code, section 6103

By reporting to the State Bar of California on May 13, 2008 that sanctions in excess of $1,000 had been imposed against him, Respondent failed to report to the agency charged with attorney discipline, in writing, within 30 days of the time Respondent had knowledge of the imposition of any judicial sanctions against Respondent in willful violation of Business and Professions Code, section 6068(0) (3).

 

Case No. 10-O-07590 (State Bar Investigation)

 

FACTS:

1. On March 26, 2009, Respondent filed a lawsuit on behalf of Classic Yam entitled Classic Yarn Co., Inc. et al. v. LG Insurance Co, et al., Los Angeles County Superior Court, case no. BC410492 (the "Classic Yarn complaint"). On May 11, 2009, the Classic Yam complaint was removed to United States District Court, case no. 2:09-cv-03320 (the "Classic Yam action").

2. On July 15, 2009, the court granted a motion to strike dismissing various plaintiff claims with prejudice. Respondent was properly served with the court’s July 15, 2009 order.

3. On August 27, 2009, Respondent filed a First Amended Complaint ("FAC") in the Classic Yarn action and included causes of actions that had been dismissed or stricken.

4. On August 31, 2009, defense counsel in the Classic Yam action sent a letter to Respondent by facsimile outlining the portions of the FAC that had been ordered stricken by the court. In the August 28, 2009 letter, defense counsel asked Respondent to prepare as stipulation striking the applicable portions of the FAC. In the letter, defense counsel informed Respondent that if they did not receive a stipulation and proposed order, they would likely file a Rule 11 motion. Respondent received the letter.

5. On September 1, 2009, Respondent responded to defense counsel’s August 28, 2009 letter asking defense counsel to prepare the stipulation.

6. On September 3, 2009, defense counsel forwarded a draft stipulation and proposed order striking the improper portions of the FAC. In the letter, defense counsel asked Respondent to let them know by September 4, 2009 if he was willing to sign the stipulation or, alternatively, agree to extend defendant’s time to respond to the complaint. On or about September 3, 2009, defense counsel sent the letter and the proposed stipulation and order to Respondent by facsimile. Respondent received the letter and its enclosures but did not sign the stipulation or otherwise respond to defense counsel’s September 3, 2009 letter.

7. On September 8, 2009, opposing counsel filed a motion to strike portions of the FAC. In addition, on October 5, 2009, opposing counsel filed a motion for Rule 11 sanctions. On October 9, 20.09, the district court granted the motion to strike portions of the FAC.

8. On October 19, 2009, Respondent filed opposition to the motions for sanctions. In his opposition, Respondent stated that he had erroneously included causes of action that were stricken by the court.

9. On November 6, 2009, the district court in the Classic Yam action granted the motion for sanctions and ordered Respondent to pay $4,032 in sanctions finding that Respondent’s FAC "was made for the improper purpose of causing unnecessary delay and needlessly increasing the cost of litigation." The court ordered Respondent to pay the sanctions before December 2, 2009. The court properly served the November 6, 2009 court order on Respondent. Respondent received the court’s November 6, 2009 order.

10. On February 3, 2010, Respondent paid the $4,032 in sanctions to opposing counsel.

 

CONCLUSIONS OF LAW:

By filing a First Amended Complaint in the Classic Yam action that contained actions that had already been stricken by the court, Respondent failed maintain such action, proceedings, or defenses only as appear to him legal or just in willful violation of Business and Professions Code, section 6068(c).

 

By not timely paying the sanctions by December 2, 2009 as ordered by the court, Respondent disobeyed or violated an order of the court requiring him to do or forbear an act connected with or in the course of Respondent’s profession which he ought in good faith to do or forbear in willful violation of Business and Professions Code section 6103.

 

PENDING PROCEEDINGS.

The disclosure date referred to, on page 2, paragraph A(7), was August 26, 2011.

 

AUTHORITIES SUPPORTING DISCIPLINE:

Standard 2.6 (a) states that any violations of Business and Professions Code, section 6068 shall result in disbarment or suspension depending on the gravity of the offense and the harm, if any, to the victim.

Standard 2.6 (b) states that any violation of Business and Professions Code, section 6103 shall result in disbarment or suspension depending on the gravity of the offense and the harm, if any, to the victim.


 

SIGNATURE OF THE PARTIES

Case Number(s): 08-O-11773, 10-O-07590

In the Matter of: Steven Zelig

 

By their signatures below, the parties and their counsel, as applicable, signify their agreement with each of the recitation and each of the terms and conditions of this Stipulation Re Facts, Conclusions of Law and Disposition.

 

Signed by: Steven Zelig, Arthur Margolis, and Katherine Kinsey

 

Respondent: Steven Zelig

Date: 08/31/2011

 

Respondent’s Counsel: Arthur Margolis

Date: 09/06/2011

 

Deputy Trial Counsel: Katherine Kinsey

Date: 09/06/2011


 

STAYED SUSPENSION ORDER

Case Number(s): 08-O-11773, 10-O-07590

In the Matter of: Steven Zelig

 

Finding the stipulation to be fair to the parties and that it adequately protects the public, IT IS ORDERED that the requested dismissal of counts/charges, if any, is GRANTED without prejudice, and:

 

checked. The stipulated facts and disposition are APPROVED and the DISCIPLINE RECOMMENDED to the Supreme Court.

<<not>> checked. The stipulated facts and disposition are APPROVED AS MODIFIED as set forth below, and the DISCIPLINE IS RECOMMENDED to the Supreme Court.

<<not>> checked. All Hearing dates are vacated.

 

The parties are bound by the stipulation as approved unless: 1) a motion to withdraw or modify the stipulation, filed within 15 days after service of this order, is granted; or 2) this court modifies or further modifies the approved stipulation. (See rule 5.58 (E) & (F), Rules of Procedure.) The effective date of this disposition is the effective date of the Supreme Court order herein, normally 30 days after the file date. (See rule 9.18(a), California Rules of Court.)

 

Signed by: Donald F. Miles

Judge of the State Bar Court: Donald F. Miles

Date: 09/12/2011

 


 

CERTIFICATE OF SERVICE

 

[Rules Proc. of State Bar; Rule 5.27(B); Code Civ. Proc., § 1013a(4)]

 

I am a Case Administrator of the State Bar Court of California. I am over the age of eighteen and not a party to the within proceeding. Pursuant to standard court practice, in the City and County of Los Angeles, on September 12, 2011, I deposited a true copy of the following document(s):

 

STIPULATION RE FACTS, CONCLUSIONS OF LAW AND DISPOSITION AND ORDER APPROVING

 

in a sealed envelope for collection and mailing on that date as follows:

 

checked. by first-class mail, with postage thereon fully prepaid, through the United States Postal Service at Los Angeles, California, addressed as follows:

 

ARTHUR LEWIS MARGOLIS, ESQ.

MARGOLIS & MARGOLIS LLP

2000 RIVERSIDE DR

LOS ANGELES, CA 90039

 

checked. by interoffice mail through a facility regularly maintained by the State Bar of California addressed as follows:

 

KATHERINE KINSEY, ESQ., office of Enforcement, Los Angeles

 

I hereby certify that the foregoing is true and correct. Executed in Los Angeles, California, on September 12, 2011.

 

Signed by: Rosie Luthi

Case Administrator

State Bar Court