In the Matterof: HTINMYAT WINDeLong and Glendal French, two correctional officers at Pontiac...
Transcript of In the Matterof: HTINMYAT WINDeLong and Glendal French, two correctional officers at Pontiac...
FeldmanWasser
1307 S. Seventh St.
Post Office Box 2418
Springfield, IL 62705217/544-3403
FILEDBEFORE THE HEARING BOARD OF THE JAN - 8 ZOIfiILLINOIS ATTORNEY REGISTRATION
AND DISCIPLINARY COMMISSION flflY R£© &DISC COMMCHICAGO
In the Matter of: HTIN MYAT WIN
Attorney-Respondent, Commission No.: 2015PR00112
ANSWER
Now comes Htin Myat Win, Respondent herein, by his attorney, Carl R. Draper,
and for his Answer to the Complaint, he states as follows:
COUNT 1
(Misrepresentation to a Tribunal and Lack of Communication)
1. Between March 18, 2013 and December 15, 2014, Respondent was employed
as an Assistant Attorney General in Springfield, Illinois.
ANSWER: Respondent admits the allegations in this paragraph.
2. During his employment, Respondent was assigned to represent Kevin
DeLong and Glendal French, two correctional officers at Pontiac Correctional
Center, who were defendants in a suit filed by Marlin Mintor, Sr., an inmate at
Pontiac Correctional Center. The case was docketed as: Minter v. DeLong and French,
13 CV 1497, United States District Court, Central District of Illinois, Peoria Division.
ANSWER: Respondent admits the allegations in this paragraph.
3. On October 15, 2014, the judge in case number 13 CV 1497, Joe Billy McDade,
ordered the warden of Pontiac Correctional Center, Randy Pfister ("Pfister"), to
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personally appear at a hearing scheduled on November 12, 2014, or produce certain
records at least five days prior to the scheduled hearing. Judge McDade ordered
Respondent to notify Pfister about the order.
ANSWER: Respondent admits the allegations in this paragraph.
4. At no time prior to November 12, 2014, did Respondent forward Judge
McDade's order to Pfister or anyone at Pontiac Correctional Center, nor did
Respondent notify Pfister or anyone at Pontiac Correctional Center about the contents
of the order.
ANSWER: Respondent admits the allegations in this paragraph.
5. At no time prior to November 12, 2014, did Pfister provide any documents in
response to the court's order of October 15, 2014, nor did Pfister appear for the hearing
on November 12, 2014.
ANSWER: Respondent admits the allegations in this paragraph.
6. On November 12, 2014, during questioning by Judge McDade, Respondent
stated that he had forwarded a copy of the Judge McDade's October 15, 2014 order to
the Litigation Coordinator at Pontiac Correctional Center, Jennifer Robison
("Robison").
ANSWER: Respondent admits the allegations in this paragraph.
7. Respondent's statement to Judge McDade that he had forwarded a copy of the
October 15, 2014 order to Robison was false because he had not sent a copy of the order
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to Robison or otherwise notified her or Pfister about the contents of the order, or the
hearing on November 12, 2014.
ANSWER: Respondent admits the allegations in this paragraph.
8. At the time Respondent made the statement to Judge McDade set forth
m paragraph six, above, Respondent knew that his statement was false.
ANSWER: Respondent denies the allegations in this paragraph. Respondent was
unsure whether he had forwarded the matter but answered that he did
based on Respondent's usual and customary practice of forwarding
matters requiring the attention ofdefendants, witnesses, or other parties
employed with IDOC facilities to the facility litigation coordinator.
9. During the hearing on November 12, 2014, Judge McDade made the following
statement concerning Pfister's failure to comply with the October 15, 2014 order:
THE COURT: Mr. Win, you may tell the warden that I'm extremely upset; andif he refuses to comply with an order of mine in the future, I will have himarrested by the United States Marshall.
MR. WIN: Yes, Your Honor.
THE COURT: Okay? Tell him I mean this. And I still may. I still may becausethe information that you intended to get should have been in my hands fivedays before this hearing, so he's not off the hook yet.
ANSWER: Respondent admits the allegations in this paragraph.
10. By reason ofthe conduct outlined above respondent has engaged in the following
misconduct:
a. knowingly making a false statement of fact or law to a tribunal, inviolation of Rule 3.3(a)(1) of the Illinois Rules of Professional Conduct (2010),by conduct including falsely representing to Judge McDade that he had
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forwarded the October 15, 2014 order to Robison, and thereafter failing tocorrect that false statement;
ANSWER: Respondent admits in part and denies in part the allegations in
paragraph 10 part a. Respondent did not have specific knowledge or
recollection as to whether he sent a correspondence to the prison
litigation coordinator during the hearing. Respondent answered that he
did based on respondent's usual and customary practice of forwarding
matters requiring the attention ofdefendants, witnesses, or other parties
employed with IDOC facilities to the facility litigation coordinator.
Respondent admits that he failed to correct the misstatement concerning
sending a correspondence to the prison litigation coordinator upon
discovering that no correspondence was sent following the November 12,
2014 hearing.
b. conduct involving dishonesty, fraud, deceit or misrepresentation, inviolation of Rule 8.4(c) of the Illinois Rules of Professional Conduct (2010),by conduct including falsely representing to Judge McDade that he hadforwarded the October 15, 2014 order to Robison;
ANSWER: Respondent admits in part and denies in part the allegations in
paragraph 10 part a. Respondent did not have specific knowledge or
recollection as to whether he sent a correspondence to the prison
litigation coordinator during hearing. Respondent answered that he did
based on respondent's usual and customary practice of forwarding
matters requiring the attention ofdefendants, witnesses, or other parties
employed with IDOC facilities to the facility litigation coordinator.
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Respondent admits that he failed to correct the misstatement concerning
sending a correspondence to the prison litigation coordinator upon
discovering that no correspondence was sent following the November 12,
2014 hearing.
c. failing to act with reasonable diligence and promptness inrepresenting a client, in violation ofRule 1.3 ofthe Illinois Rules ofProfessionalConduct (2010), by conduct including failing to forward the October 15, 2014order to Robison or Pfister, or inform Robison or Pfister of the order or theNovember 12, 2014 hearing.
ANSWER: Respondent admits the allegations in this paragraph.
COUNT II
(Misrepresentation and Creation of a False Letter)
11. The administrator re-alleges and incorporates paragraphs 1 through 9 above.
ANSWER: Respondent incorporates by reference his answers to paragraphs 1
through 9 above.
12. On November 12, 2014, at 10:38 p.m., at the office of the Illinois Attorney
General in Springfield, Respondent created a letter which he dated October 22, 2014,
which was addressed to Jennifer Robison. The letter stated as follows:
Re: Minter v. DeLong
USDC-CD 13-1496 [sic]
Dear Ms. Robison:
This Court has ordered Warden Pfister to appear at a hearing in the matter ofMinter v. DeLong scheduled for November 12, 2014 at 2:00 p.m. However, inlieu of personal appearance, Warder Pfister may produce a copy of relevant
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grievances from Inmate Minter's master file five days prior to the hearing alongwith an affidavit. Please refer to the Order enclosed with this letter. Please
note that the Order sets the hearing at10:00 a.m. but the Court later reset the hearing for 2:00p.m.
Thank you for your cooperation. If you have any question regarding thismatter, please contact me at (217) 782-9014.
Sincerely, Htin M. Win, Assistant Attorney General
ANSWER: Respondent admits the allegations in this paragraph.
13. On November 13, 2014, at approximately 8:45 a.m., Respondent met with his
supervisor, Christopher Higgerson ("Higgerson"), an Assistant Attorney General who
was the Unit Supervisor of Prison Litigation.
ANSWER: Respondent admits the allegations in this paragraph.
14. In the meeting, Respondent stated to Higgerson that he had sent a letter
notifying Pfister of the November 12,2014 hearing in case 13 CV 1497, but that Pfister
did not appear at the hearing.
ANSWER: Respondent admits the allegations in this paragraph.
15. Respondent's statement to Higgerson that he sent a letter to Pfister notifying
him of the November 12, 2014 hearing was false because Respondent did not notify
Pfister or anyone at Pontiac Correctional Center about the November 12, 2014
hearing, and Respondent did not create the letter concerning the hearing until the
evening of November 12, 2014.
ANSWER: Respondent admits the allegations in this paragraph.
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16. At the time Respondent made the statement to Higgerson, set forth in
paragraph 15, above, Respondent knew that his statement to Higgerson was false and
Respondent intended to mislead Higgerson into believing that he sent a letter on
October 22, 2014, notifying Pfister of the hearing.
ANSWER: Respondent admits the allegations in this paragraph.
17. During the meeting with Higgerson, Respondent produced the back-dated
October 22, 2014 letter, referred to in paragraph 12, above. Respondent represented
to Higgerson that the letter was a copy of the letter he sent to Robison on October 22,
2014.
ANSWER: Respondent lacks present recollection sufficient to admit or deny the
allegations in this paragraph. However, Respondent admits that he
produced the back-dated October 22, 2014 letter to Higgerson at some
point.
18. Respondent's representation to Higgerson that the letter he produced was a copy
of the letter he sent to Robison on October 22, 2014, was false because Respondent did
not create the letter until the evening of November 12, 2014.
ANSWER: Respondent admits the allegations in this paragraph.
19. At the time Respondent made the representation to Higgerson described
in paragraph 17, above, Respondent knew that his representation was false and
Respondent intended to mislead Higgerson into believing that he prepared and sent
the letter on October 22, 2014.
ANSWER: Respondent admits the allegations in this paragraph.
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20. On November 13, 2014, Respondent traveled to Pontiac Correctional Center
where he met with Pfister and Robison. Respondent took a copy of the letter described
in paragraph 12, above.
ANSWER: Respondent admits the allegations in this paragraph.
21. Without disclosing or discussing the letter described in paragraph 12, above,
with Robison or Pfister, Respondent purposely left a copy of the letter dated October
22. 2014 on Pfister's desk. Pfister's secretary later found the letter and placed it in
Robison's mailbox.
ANSWER: Respondent denies that he did not discuss the letter described in
paragraph 12 with Robison or Pfister, and lacks present recollection as
to whether he left a copy of the letter described in paragraph 12.
Respondent inquired as to whether a correspondence containing Order
35 was received in the meeting with Robison and Pfister.
22. Respondent purposely left a copy of the letter dated October 22, 2014 on
Pfister's desk without discussing or disclosing the letter in order to make it appear as
though Pfister received the letter prior to November 13, 2014.
ANSWER: Respondent denies the allegations in this paragraph.
23. By reason of the conduct outlined above, Respondent has engaged m the
following misconduct:
a. conduct involving dishonesty, fraud, deceit or misrepresentation inviolation of Rule 8.4(c) of the Illinois Rules of Professional Conduct (2010),by conduct including creating a letter on November 12, 2014, dated
October 22, 2014, addressed to Robison, in an attempt to deceive Higgerson,Pfister, and Robison; representing to Higgerson that he sent a letter to
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Robison on October 22, 2014; and by surreptitiously placing the letter onPfister's desk without discussing the letter with him.
ANSWER: Respondent admits having engaged in conduct in violation of Rule 8.4c
by creating a letter on November 12, 2014 dated October 22, 2014 and by
representing to Higgerson that he sent a letter to Robison on October 22,
2014. Respondent denies having engaged in conduct in violation of Rule
8.4c by surreptitiously placing the letter on Pfister's desk without
discussing the letter with him.
b. knowingly making a false statement of material fact or law to a thirdperson in violation of Rule 4.1(a) of the Illinois Rules of Professional Conduct(2010), by conduct including falsely stating to Higgerson that he had createdand sent the letter to Robison on October 22, 2014.
ANSWER: Respondent admits the allegations in this paragraph.
COUNT III
(False Affidavit)
24. The Administrator re-alleges and incorporates paragraphs 1 through 22 above.
ANSWER: Respondent incorporates by reference his answers to paragraphs 1
through 22 above.
25. On November 21, 2014, Pfister, Robison, and Respondent all filed affidavits in
case number 13 CV 1497 after Judge McDade requested that the U.S. Attorney's Office
investigate whether Pfister should be held in contempt of court.
ANSWER: Respondent admits the allegations in this paragraph.
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26. In their affidavits, both Pfister and Robison attested to the fact that they were
unaware of Judge McDade's October 15, 2014 order in case number 13 CV 1497, until
after the hearing was concluded on November 12, 2014.
ANSWER: Respondent admits the allegations in this paragraph.
27. In Respondent's affidavit, he stated as follows:
4. On October 22, 2014, I prepared a letter addressed to the litigationcoordinator at Pontiac Correctional Center and enclosed the above referenced
Order and subsequent text order entered on September 17, 2014 reflecting achange in the time of the Pavey Hearing from 10:00 a.m. to 2:00 p.m. Thelitigation coordinator is a staff member within an IDOC facility who, amongother things, schedules staff members for court appearances.
5. It is my belief that on October 22, 2014, I placed the letter in a tray forthe outgoing mail and that the letter was mailed. However, I do not have a clearrecollection of exactly what steps I took to mail the letter.
6. My secretary was not present on October 22, 2014. My usual practicewhen my secretary is not present is to prepare letter and place them with theoutgoing mail myself.
7. I assumed that I provided the Warden with sufficient notice. I now realizethat I should have followed up with the litigation coordinator at PontiacCorrectional Center and the Warden to determine whether the letter was
received by Warden Pfister and ensure that he would comply with its terms. Isincerely apologize to the Court for failing to do so.
ANSWER: Respondent admits the allegations in this paragraph.
28. Respondent's statement in the affidavit that he prepared a letter on October 22,
2014, addressed to the Litigation Coordinator regarding case 13 CV 1497, was false
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because Respondent did not create the letter until November 12, 2014, after the
hearing in case 13 CV 1497.
ANSWER: Respondent admits the allegations in this paragraph.
29. At the time Respondent drafted and signed the affidavit, Respondent knew that
his statement concerning the preparation of the letter was false.
ANSWER: Respondent admits the allegations in this paragraph.
30. Respondent's statements in the affidavit that he believed that the letter had
been mailed on October 22, 2014, and that he assumed he provided the Warden with
sufficient notice of the hearing, were false and misleading because Respondent knew
that he had not created the letter until November 12, 2014 and that the letter had not
been mailed to Robison in October 2014.
ANSWER: Respondent admits the allegations in this paragraph.
31. At the time he prepared and signed the affidavit, Respondent knew that his
statements in the affidavit as described above in paragraph 30, above, were false.
ANSWER: Respondent admits the allegations in this paragraph.
32. By reason of the conduct outlined above, respondent has engaged in the
following misconduct:
a. knowingly making a false statement of fact or law to a tribunal inviolation of Rule 3.3(a)(1) of the Illinois Rules of Professional Conduct (2010) byconduct including filing an affidavit in which he falsely stated he prepared andmailed a letter to Robison on October 22, 2014, and that he provided notice ofthe hearing to Pfister;
b. failing to correct a false statement ofmaterial fact previously made to thetribunal by the lawyer, in violation of Rule 3.3(a)(1) of the Illinois Rules ofProfessional Conduct (2010) by conduct including his failure to correct his
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statements to the court on November 12, 2014, as set forth in paragraph six,above.
c. conduct involving dishonesty, fraud, deceit or misrepresentation inviolation of Rule 8.4(c) of the Illinois Rules of Professional Conduct (2010),by conduct including filing an affidavit in which he falsely stated he preparedand mailed a letter to Robison on October 22, 2014 and that he provided noticeof the hearing to Pfister; and
d. conduct prejudicial to the administration of justice in violation of Rule8.4(d) of the Illinois Rules of Professional Conduct (2010), by conduct includingfiling a false affidavit in a court proceeding.
ANSWER: Respondent admits the allegations in this paragraph.
COUNT IV
(False statements to ARDC)
33. The Administrator re-alleges and incorporates paragraphs 1 through 31 above.
ANSWER: Respondent incorporates by reference his answers to paragraphs 1
through 31 above.
34. On March 25, 2015, the Administrator docketed an investigation of Respondent
after receiving a report from the Illinois Attorney General's Office.
ANSWER: Respondent admits the allegations in this paragraph.
35. On March 26, 2015, the Administrator sent a copy of the report to Respondent
and requested that he respond to the report within 14 days.
ANSWER: Respondent admits the allegations in this paragraph.
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36. On April 8, 2015, following receipt of the letter from the Administrator,
Respondent used his personal computer to recreate the letter he purportedly sent on
October 22, 2014 to Robison. Respondent then used a software program entitled
"Attribute Changer" to change the creation date of the letter to Robison from April 8,
2015, to October 21, 2014. Respondent then uploaded the letter onto a zip drive.
ANSWER: Respondent admits the allegations in this paragraph.
37. On April 24, 2015, Respondent sent a written response to the Administrator's
report from the Attorney General's Office. In the response, Respondent stated:
As stated in my affidavit, I believe that on October 22, 2014,1 forwarded a letterinforming Warden Pfister of the Court's Order to the prison litigationcoordinator...
. . .After the Pavey hearing on November 12, 2014, I went home to eat andreturned to my office in the evening. In the case file for Minter v. DeLong,I found 2 signed original copies of my letter to the prison litigationcoordinator and 1 copy of the Court's October 15, 2014 Order.
...Additionally, I did not save a copy of the letter on my office computer.However, I had brought my personal laptop computer and zip drive with me andfound a copy of the letter titled "(letter draft)" in a wordpad documents on boththe zip drive and laptop. On October 22,1 likely transferred a copy of the letterto my office computer as I usually do when I work from home, and printed it formailing. On November 12,1 specifically recall that I also scanned a copy of theletter and saved it as a pdf document. I believe that I titled the pdf (Letter re:Order 35).
ANSWER: Respondent admits the allegations in this paragraph.
38. Respondent's statements above: 1) that he sent a letter to the Warden on
October 22, 2014; 2) on November 12, 2014, he found two original copies of the letter
to Robison at his office; and 3) he found the letter to Robison on his personal laptop
and then he uploaded the letter to a zip drive at that time; and 4) he transferred a copy
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of the letter to his officecomputer, where he printed it for mailing, were false because
Respondent did not send a letter to Pfister or Robison on October 22, 2014, and he did
not create the letter on his personal computer until April 8, 2015.
ANSWER: Respondent admits the allegations in this paragraph.
39. At the time he prepared and sent the written response to the Administrator,
Respondent knew that his statements set forth in paragraph 37, above, were false and
he made the statements in order to mislead the ARDC and conceal his misconduct.
ANSWER: Respondent admits the allegations in this paragraph.
40. On August 4, 2015, Respondent appeared at the ARDC Springfield office and
gave sworn testimony. In his sworn testimony, Respondent stated that he created the
letter to Robison in October 2014, on his personal computer and transferred the letter
to a zip drive at that time. He further stated that he transferred a copy of the letter to
his office computer using the zip drive in October 2014.
ANSWER: Respondent admits the allegations in this paragraph.
41. Respondent's statements set forth in paragraph 40, above, were false because
Respondent did not create the letter to Robison on October 22, 2014, and he did not put
the letter on a zip drive until April 8, 2015.
ANSWER: Respondent admits the allegations in this paragraph.
42. At the time Respondent made the statements under oath set forth in paragraph
40 above, Respondent knew the statements were false and he made the statements in
an attempt to mislead the ARDC.
ANSWER: Respondent admits the allegations in this paragraph.
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43. On August 6, 2015, Respondent's counsel was served with a subpoena requiring
Respondent to produce his personal laptop computer on August 18, 2015 for analysis
by Forensicon, a computer forensics company.
ANSWER: Respondent admits the allegations in this paragraph.
44. On August 17, 2015, Respondent indicated that he would not produce his
personal laptop for analysis and that he would submit a written response "correcting"
his previous written and oral responses to the Administrator.
ANSWER: Respondent admits the allegations in this paragraph.
45. On August 31,2015, Respondent submitted a revised response in which he
admitted that his previous written response and his sworn statement testimony were
false.
ANSWER: Respondent admits the allegations in this paragraph.
46. By reason of the conduct outlined above, Respondent has engaged in the
following misconduct:
a. in connection with a disciplinary matter, knowingly making a falsestatement of material fact in violation of Rule 8.1(a) of the Illinois Rules ofProfessional Conduct (2010), by conduct including: making false statements inhis letter to the ARDC; falsely stating under oath that he created the letter toRobison in October 2014; falsely stated that he transferred the letter to a zipdrive in October 2014; and falsely stated that he transferred the letter to hisoffice computer using the zip drive in November 2014.
b. conduct involving dishonesty, fraud, deceit, or misrepresentation inviolation of Rule 8.4(c) of the Illinois Rules of Professional Conduct(2010), by conduct including making false statements in his letter to theARDC; falsely stating under oath that he created the letter to Robison inOctober 2014; falsely stated that he transferred the letter to a zip drive in
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October 2014; and falsely stated that he transferred the letter to his officecomputer using the zip drive in November 2014.
ANSWER: Respondent admits the allegations in this paragraph.
WHEREFORE, the Respondent respectfully requests that this matter be assigned to
a panel of the Hearing Board, that a hearing be held, and that the panel make findings
of fact, conclusions of fact and law, and a reasonable recommendation for discipline if
such is warranted.
DISCLOSURE PURSUANT TO ARDC RULE 231
Now comes Respondent, Htin Myat Win, by Carl R. Draper, his attorney, and
pursuant to ARDC Rule 231(a) he states that he has not been admitted to practice law
before any other state court other than the State of Illinois. He has been authorized
to practice law before the federal courts in Illinois, particularly, in the central district
and southern district of Illinois, and as an Assistant Attorney General, he was
authorized to practice before any state administrative agency of the State of Illinois.
Pursuant to ARDC Rule 231(b) Respondent DISCLOSURE PURSUANT TO
ARDC RULE 231
Now comes Respondent, Htin Myat Win, by Carl R. Draper, his attorney, and
pursuant to ARDC Rule 231(a) he states that he has not been admitted to practice law
before any other state court other than the State of Illinois. He has been authorized
to practice law before the federal courts in Illinois, particularly, in the central district
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and southern district of Illinois, and as an Assistant Attorney General, he was
authorized to practice before any state administrative agency of the State of Illinois.
Pursuant to ARDC Rule 231(b) DISCLOSURE PURSUANT TO ARDC RULE
231
Now comes Respondent, Htin Myat Win, by Carl R. Draper, his attorney, and
pursuant to ARDC Rule 231(a) he states that he has not been admitted to practice law
before any other state court other than the State of Illinois. He has been authorized
to practice law before the federal courts in Illinois, particularly, in the central district
and southern district of Illinois, and as an Assistant Attorney General, he was
authorized to practice before any state administrative agency of the State of Illinois.
Pursuant to ARDC Rule 231(b) Respondent also obtained the Illinois Producer
License in 2007 issued by the Illinois Department of Insurance. Respondent's name
appeared as Htin Myat Win on the license. Respondent no longer has custody of the
license and is unable to recall any registration number assigned. Respondent has not
used the license since 2007 and has not renewed the license.
Respectfully Submitted,Htin Myat Win, Respondent
}arl R. Draper
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