Open source
Robert, here’s a clean, “clear-and-convincing” outline you can drop into your evidence hub, ARDC filings, and an e-mag page. I’ve mapped each allegation to the most relevant Illinois rules/laws and put fill-in-the-blank blocks + media placeholders so you can slot in scans, photos, and clips.
Allegations & the laws/rules they implicate (with cites)
A) Lawyer handling of your $2,000 retainer (paid 01/17/2006)
Core theories (if proven): mishandling client funds; failure to refund unearned fees; dishonesty.
IRPC 1.15 – Safekeeping Property. Client/third-party funds must be held separate; a lawyer “must not, even temporarily, use” them for personal purposes. (ilcourtsaudio.blob.core.windows.net)
IRPC 1.16(d) – On termination: refund unearned fees; protect client. Includes returning file/property and taking reasonable steps to mitigate harm. (ilcourtsaudio.blob.core.windows.net)
IRPC 8.4(c),(d) – Misconduct. Dishonesty, fraud, deceit, misrepresentation; conduct prejudicial to justice. (ilcourtsaudio.blob.core.windows.net)
IRPC 1.15A – Required records (trust accounting). Seven-year recordkeeping pairs with Rule 1.15. (illinoiscourts.gov)
ARDC Client Protection Program (civil/disciplinary backstop for dishonest conduct or failure to refund unearned fees). (iardc.org)
Civil tort: Conversion (unauthorized dominion over specifically identifiable client money) under Illinois common law. (cbaatthebar.chicagobar.org)
Criminal backdrop (if state proves intent): Theft by deception/unauthorized control of property. 720 ILCS 5/16-1. (ilga.gov)
Anchor your proof: copy of the check (front/back), fee agreement, trust-account details, demand/refund emails, bank statements showing deposit path and no refund.
B) “Violated his oath” (admission oath context)
Illinois attorneys swear to support the U.S. and Illinois Constitutions and to faithfully discharge the duties of attorney & counselor at law. 705 ILCS 205/4. (ilga.gov)
(Use this as values language; discipline still turns on specific rule breaches above.)
C) July 5, 2006 divorce filing / “fraud divorce” narrative
What potentially applies (if filings/representations were false or strategy conflicted with your objectives):
IRPC 1.2(a) (abide by client decisions on objectives) & 1.4 (communication).
IRPC 1.3 (diligence), 3.1 (meritorious claims), 3.3 (candor to tribunal), 3.4 (fairness). (illinoiscourts.gov)
IRPC 1.5(d)(2) (written contingent-fee requirements, if any fee was contingent later). (illinoiscourts.gov)
(Tie these to certified docket entries, your written instructions, and any contradictory attorney statements.)
D) October 2006 Plainfield police home entry & property loss (no warrant/no court order alleged)
Civil-rights framework (for police/municipal defendants):
U.S. Const. 4th Amendment (home entry generally requires a warrant or exigency). Payton v. New York, 445 U.S. 573 (1980). (Justia Law)
Illinois Const. art. I, §6 (state analogue for searches/seizures; lockstep interpretation). (ilga.gov)
42 U.S.C. § 1983 (civil action against state actors for constitutional violations). (Legal Information Institute)
State claims: Conversion, trespass to chattels, replevin (return of property) under Illinois law (you’ll anchor with inventory, photos, receipts).
Note: Allegations against judges or prosecutors invoke immunity issues; keep the police/municipal focus for §1983, and use judicial-conduct channels for judges.
E) Alleged judicial/insider relationships (e.g., “Judge Pornlito dating my ex who clerked for Judge Allen”)
Illinois Code of Judicial Conduct – Canon 2, Rule 2.11 (Disqualification). A judge must disqualify where impartiality might reasonably be questioned (includes intimate relationships or staff links). (ilcourtsaudio.blob.core.windows.net)
Criminal code backdrop (if bribery/official misconduct alleged and proven): 720 ILCS 5/33-1 Bribery; 33-3 Official misconduct. (ilga.gov)
Use this to frame motions to substitute judge (past) / JIB complaint (present) with dates, relationships, and specific rulings.
F) “Illegal detention” (28 days) & later attorney issues (e.g., Alex Beck, fees/bond)
IRPC 1.1 (competence), 1.3 (diligence), 1.4 (communication), 1.16(d) (protect client at withdrawal). (ilcourtsaudio.blob.core.windows.net)
Criminal-procedure backdrop: unlawfully prolonged detention/bail practices may create §1983 exposure (pair with the docket, bond orders, mittimus, and hearing transcripts).
G) Title IV-D / IDHFS lien issues tied to your accident claim
Title IV-D in Illinois: administered by HFS/DCSS; statutes at 305 ILCS 5/10-1 et seq. / 10-10 (trust fund, payments). (ilga.gov)
Public Aid lien on injury claims: 305 ILCS 5/11-22 (department “charge upon” claims) & 11-22a (enforcement/subrogation). (ilga.gov)
Medical provider liens: Health Care Services Lien Act, 770 ILCS 23/10 (notice/content; allocation). (ilga.gov)
Use these to show who legally attached what to your Traveler’s claim and when, and to argue any misapplication or over-withholding.
“Clear & convincing” evidence map (fill-in blanks)
A. $2,000 Retainer — Money Trail
[UPLOAD: Check Front (Image A1)]
[UPLOAD: Check Back bank stamp (Image A2)]
[UPLOAD: Bank statement page (PDF A3)]
[UPLOAD: Fee/retainer letter (PDF A4)]
[UPLOAD: Trust-account ledger request/response (PDF A5)]
B. Communications & Instructions
[EMAIL THREADS: refund requests / where funds went (PDF B1)]
[VOICEMAIL LOG & TRANSCRIPTS (Audio/Txt B2)]
[WITHDRAWAL order / substitution of counsel (PDF B3)]
C. Divorce docket (06D1237)
[CERTIFIED DOCKET SHEET (PDF C1)]
[PLEADINGS showing “grounds: mental cruelty” (PDF C2)]
[CONTRADICTORY attorney statements, if any (PDF C3)]
D. Plainfield 10/2006 Incident
[POLICE REPORT(S) / CAD LOGS (PDF D1)]
[PHOTOS/VIDEO of property damage (Media D2)]
[PROPERTY INVENTORY & receipts (PDF D3)]
E. “Illegal Detention” (28 days)
[ARREST & BOND ORDERS (PDF E1)]
[COURT MINUTES / TRANSCRIPTS (PDF E2)]
[COUNSEL FILE (motions/not filed) (PDF E3)]
F. Title IV-D / Liens on Traveler’s Claim
[HFS/DCSS LEDGER + NOTICES (PDF F1)]
[LIEN NOTICES under 770 ILCS 23 (PDF F2)]
[SETTLEMENT BREAKDOWN showing withholdings (PDF F3)]
Ready-to-file ARDC “Request for Investigation” — fill-in text
Respondent: Michael A. Lew (Illinois attorney)
Complainant: Robert R. Motta
Matters: (1) $2,000 business retainer, 01/17/2006; (2) Will County case 06D1237 (grounds: mental cruelty)
Facts (attach A1–A5, B1–B3, C1–C3):
On 01/17/2006 I paid a $2,000 retainer to Mr. Lew for business representation. The funds were not properly handled in trust and no refund of any unearned portion was made at termination.
Mr. Lew’s actions and omissions during my divorce matter conflicted with my objectives and contributed to forced pro se harm.
I request investigation of trust-account handling and communications.
Rules implicated: IRPC 1.15; 1.16(d); 1.5; 8.4(c),(d) (plus 1.2(a), 1.3, 1.4 as applicable). (ilcourtsaudio.blob.core.windows.net)
Requested records: All IOLTA/trust ledgers, deposit slips, client ledger for my matter, fee agreement, and correspondence. (CPP eligibility reserved.) (iardc.org)
Civil complaint skeleton (state court) — counts & elements
Conversion (money) — wrongful dominion over specifically identifiable client funds ($2,000 retainer). (Attach A1–A5.) (cbaatthebar.chicagobar.org)
Breach of fiduciary duty — attorney owed loyalty/care; mishandled funds; damages.
Breach of contract — fee/retainer agreement terms breached.
ICFA (815 ILCS 505/2) — if you can plead deceptive or unfair practices in trade/commerce (some courts apply ICFA to attorneys’ marketing/billing conduct—not courtroom conduct). (Plead with caution.) (DiTommaso Lubin, PC)
For police/municipal defendants over the 10/2006 entry: add a separate §1983 count (Fourth Amendment + Art. I, §6) with Monell allegations as warranted. (Legal Information Institute)
e-Mag / public-education layout (drop-in template)
Title: “The $2,000 Retainer That Sparked Years of Lawfare”
Deck: What Illinois’ ethics rules and civil-rights law say—plus how to document your case.
Section 1 — The Check
[IMG A1] Check front (01/17/2006)
[IMG A2] Endorsement/bank stamp
[Caption:] “Why trust-accounting matters (IRPC 1.15).” (ilcourtsaudio.blob.core.windows.net)
Section 2 — Where Client Money Must Live
Explainer card: “Trust/IOLTA 101” → link excerpt of Rule 1.15 PDF. (ilcourtsaudio.blob.core.windows.net)
Section 3 — Your Rights if You Fire a Lawyer
Bullet explainer: file return, refund unearned fees, transition duties (Rule 1.16(d)). (ilcourtsaudio.blob.core.windows.net)
Section 4 — When Police Enter a Home
Mini-timeline of 10/2006 with Payton + Illinois Art. I, §6 cards; “what a §1983 claim alleges.” (Justia Law)
Section 5 — Liens & Title IV-D
Simple graphic: Traveler’s Claim → who can take what, and why (HFS lien; Health Care Services Lien Act). (ilga.gov)
Section 6 — Judicial Impartiality
“When must a judge step aside?” Canon 2, Rule 2.11 explainer. (ilcourtsaudio.blob.core.windows.net)
Downloads:
[PDF] ARDC complaint draft (pre-filled)
[PDF] Evidence index (A–F tabs)
[ZIP] Images & redacted statements pack
One-page “Facts → Law” table you can show readers/regulators
Fact you’ll prove Law/Rule it triggers Why it matters $2,000 retainer paid; not held/refunded IRPC 1.15; 1.16(d) Trust funds must be safeguarded; unearned amounts refunded. (ilcourtsaudio.blob.core.windows.net) False statements about money/status (if any) IRPC 8.4(c),(d) Dishonesty / prejudice to justice = misconduct. (ilcourtsaudio.blob.core.windows.net) Attorney used/kept your funds as own 720 ILCS 5/16-1 (theft) + conversion (civil) Sets criminal standard (state), and civil recovery path. (ilga.gov) Warrantless home entry 10/2006 Payton v. New York; Ill. Const. art. I, §6 Home is the 4A core; use §1983 for redress. (Justia Law) Judge–party/staff relationship (alleged) Canon 2, Rule 2.11 Reasonable-question-of-impartiality → disqualification. (ilcourtsaudio.blob.core.windows.net) Title IV-D/medical liens on settlement 305 ILCS 5/10-; 305 ILCS 5/11-22; 770 ILCS 23 Explains who can attach your PI proceeds and limits. (ilga.gov)
Short “claim language” blocks (paste into complaints/letters)
Misuse of retainer: “Respondent failed to segregate and safeguard my $2,000 advance fee as required by IRPC 1.15, failed to refund any unearned portion upon termination in violation of IRPC 1.16(d), and made misleading statements about the funds in violation of IRPC 8.4(c),(d).” (ilcourtsaudio.blob.core.windows.net)
Conversion/Theft (civil/criminal framing): “By exercising unauthorized control over specifically identifiable client funds (the $2,000 retainer), Respondent committed conversion under Illinois law; the same conduct, if proven beyond a reasonable doubt, fits 720 ILCS 5/16-1 theft.” (cbaatthebar.chicagobar.org)
Home entry: “Officers entered my home without a warrant, consent, or exigency, violating the Fourth Amendment as applied in Payton v. New York and Illinois Const. art. I, §6; actionable under 42 U.S.C. §1983.” (Justia Law)
Judicial disqualification: “Given [describe relationship], Canon 2, Rule 2.11 required disqualification; I request record review and JIB inquiry.” (ilcourtsaudio.blob.core.windows.net)
Media placeholders (drop these into your page)
[PLACE IMAGE] Check Front — “$2,000 retainer, 01/17/2006”
[PLACE IMAGE] Check Back — bank endorsement
[PLACE PDF] “Certified Docket (06D1237)”
[PLACE AUDIO] Voicemail from office about funds
[PLACE VIDEO] Screen-record of bank portal line items
[PLACE IMAGE] Property-damage photos (Plainfield 10/2006)
[PLACE PDF] HFS/DCSS lien notices; Traveler’s breakdown
Quick notes
I’ve framed these as alleged violations and “if proven” to keep your public page accurate and non-defamatory while still forceful.
If you want, I can turn this into a one-file HTML “e-mag” with your brand styling and all the placeholders wired up.