Citation issued: January 16, 2006

Re:  Lawyer 11

Citations are issued by the Law Society of BC's Discipline Committee and list allegations against a lawyer which will be considered at a discipline hearing. Please note that allegations in a citation are unproven until a discipline hearing panel has determined their validity.

Nature of conduct to be inquired into:

1. Your conduct in participating in a scheme or design to mislead the Supreme Court of British Columbia by arranging the acquisition and/or registration of security of a loan from GM, a family member, RM, a family member, and/or attempting to obtain a judgment on that loan for the purpose of putting into place a reduction in the assets of RM prior to and for the purposes of his “Rowbotham” application.

2. Your conduct in participating in a scheme or design to misrepresent the expenses or liabilities of the P and/or the K Hotel businesses by:

a) Providing false or misleading information to the Supreme Court of British Columbia on the “Rowbotham” application of RM, and for the purpose of misrepresenting the value of his assets, by claiming the existence of previously undisclosed liabilities for unpaid wages now alleged to be owing to you and/or other family members;

b) In respect of the K Hotel business, providing false or misleading information to the Business Development Bank of Canada, and for the purpose of obtaining or attempting to obtain a benefit dishonestly for the K Hotel business, by failing to disclose liabilities for unpaid wages now alleged to be owing to you and/or other family members;

contrary to Chapter 1, Rule 2(3) and Chapter 4, Rule 6 of the Professional
Conduct Handbook
.

3. As set out in paragraphs 1 and 2 above, your engagement in dishonourable or questionable conduct that casts doubt on your professional integrity and/or competence or reflects adversely on the integrity of the legal profession or the administration of justice contrary to Chapter 2, Rule 1 of the Professional Conduct Handbook.