AND ANSWER TO COMPLAINT. Now Comes William James Meacham, Respondent, and respectfully says to the COMMISSION ALLEGATIONS OF COUNT ONE

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Joan Newton
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1 BEFORE THE HEARING BOARD OF THE FILED ILLINOIS ATTORNEY REGISTRATION JUN AND DISCIPLINARY COMMISSION ATTY REG &DISC COMM CHICAGO In the Matter of: WILLIAM JAMES MEACHAM Attorney - Respondent. Commission No, No PROOO18 No ANSWER TO COMPLAINT Now Comes William James Meacham, Respondent, and respectfully says to the COMMISSION as follows: ALLEGATIONS OF COUNT ONE 1. Respondent admits to being sole owner ofan IOLTA Escrow account in the Bank of Edwardsville as stated in the Complaint. 2. Respondent admits to having bank accounts in the Bank of Edwardsville as listed in complaint. 3. Respondent agrees that Mark Breeden was injured in an auto collision as stated in the Complaint. 4. Respondent agrees he represented Mark Breeden in an auto crash matter as alleged. 5. Respondent filed a lawsuit for Mark Breeden as alleged in the Complaint. 6. Respondent admits Mark Breeden entered into a loan agreement with a loan company with regard to a loan against the proceeds ofthe lawsuit in which Respondent represented Mr. Breeden which Respondent represented Mark Breeden. The Initial loan was made by Cambridge

2 correct because it is not likely that Mary Breeden dreamed that she had an interview with Gallagher Basset. Respondent has no idea of how Ms. Breeden' s case could have been misplaced and neglected. Respondent advised Ms. Breeden to contact an attorney and have the attorney call me to discuss the reasonable value of the lost claim and we could arrive at figure to compensate her for her loss. Mary Breeden came to my office and showed me the Order which dismissed her case. I did not have a copy of it. Ms. Breeden failed to obtain Counsel to correct the matter. Respondent could not ethically deal with an unrepresented person in the matter. Ms. Breeden told the investigator that respondent told her Respondent had a head injury and Respondent's Daughter had a stroke. Neither allegation is true. Ms. Breeden also told the investigator that Respondent has no money with witch to pay her, and Respondent had not paid Mark Breeden's medical bills. The record clearly proves that Mark Breeden's medical bills were paid. Respondent believes that Mark Breeden is the source of the medical bill lies, along with the numerous lies he has told to the ARDC in an attempt to avoid paying his loans. In any event, Respondent is willing to recompense Mary Breeden for the loss she suffered. Respectfully Submitted tt~/111~ William J. Meacham Attorney at Law 521 St Louis Street Edwardsville IL (618) IL. Registration No

3 Management, a group ofcompanies which includes Law Cash. Mark Breeden refused to pay Cambridge Management and/or its sub company Law Cash. Cambridge Management exercised its option to proceed to Binding Arbitration in the matter. The Arbitrator awarded the sum ofmoney which was placed into Respondent's IOLTA account to Mark Breeden. The funds were paid to Mark Breedenover time by cash withdrawals paid to Mark Breeden at his request. Nearly three years later Law Cash, a Cambridge Management Company, filed suit against Mark Breeden and Respondent. The matter was dismissed. Respondent Denies that any funds were converted. 7. Respondent agrees Mark Breeden accepted $160,000 to settle the personal injury suit. 8. Respondent admits Farmers Insurance Paid Mark Breeden $160,000 settlement ofhis claim, 9. Respondent admits he deposited 105,256,63 ofthe settlement proceeds into his IOLTA account for Mark Breeden. 10. Respondent admits he disbursed funds to and for the use of Mark Breeden as stated in.paragraph Ten ofthe Complaint. 11. Respondent agreed to hold the remaining funds in his IOLTA ACCOUNT to pay any further expenses. 12. Respondent Denies that Respondent failed to notify Law Cash ofthe receipt ofthe settlement funds. 13. Respondent does have copies ofletters from Law Cash in easy Reach and cannot at present admit or deny whether Law Cash sent letters on July 13, 2009 and October Investigation continues. 14. Respondent received correspondence from Law Cash at some point in time. Respondent Denies that Respondent failed to advise Law Cash ofthe Receipt settlement funds. 15. Denied 16. Respondent has no way to know whether Law Cash learned ofa settlement offer from a third party. The allegation is Denied. 17. ResOndent Denies that any funds were disbursed to any party other than Mark Breeden or a legitimate creditor ofmark Breeden. Allegations ofwrongful conduct are Denied. 18. Respondent admits that the funds were paid out to Mark Breeden over a course oftime. Any accusation ofmisconduct concerning Mark Breeden's funds is Denied. Respondent specialy Denies that Respondent used any funds that belonged to Mark Breeden or any other party 19. Respondent Denies that any funds were converted for Respondents use or benefit: all funds were delivered to Mark Breeden. Law Cash a 20. Respondent agrees that neither Mark Breeden or Law Cash Authorized Respondent to use any portion ofthe settlement funds to Respondent for Respondents personal use. All claims of misuse ofmark Breeden's funds are Denied.

4 21. Respondent Denies that he used or converted any funds belonging to Mark Breeden or to Law Cash. Law Cash, a Cambridge Management Company, lost its claim on Breeden's funds in Binding Arbitration. 22. Respondent Deniesthat he used any funds or converted any funds from any party. Count II 23. The Administrator re-alleges paragraphs 3 through 21above. The Respondent Denies all accusations offormer Counts in Count One. 24. Respondent Admits that Law Cash filed a two count lawsuit against Breeden and Respondent which was later dismissed. 25. Administrator claims Respondent refused to produce records. Respondent would not agree to produce records pursuant to Attorney Client privilege unless the Court so ordered, the Court issued a Judicial Summons to obtain the records. Respondent would ofcourse provide all information for the Court ifthe Court so ruled. Respondent Denies the all allegations ofconversion offunds 26. Respondent admits that Paul Marks reported what he believed may be violations to the ARDC. Respondent Denies all allegations ofmisconduct with regard to the matter in question. 27. Respondent denies any wrong doing with regard to mark Breeden's funds. The funds which Paul Marks could not identify had been paid in cash to Mark Breeden at his request. All allegations ofattempting to deceive the ARDC or any other entity concerning the Receipts and or any attempt to hide Breeden's money are denied. All funds that were removed from the IOLTA account were paid in cash to Mark Breeden at his insistence. Respondent DENIES any attempt to deceive any person or entity regarding any allegation concerning the matter. Respondent Denies that the receipts which Mark Breeden signed were "false receipts". Respondent Denies that Respondent Denies the allegations ofall allegations regarding false receipts and "hiding money". All checks listed in the Complaint which are alleged to be false checks were paid out in cash to Mark Breeden over a period oftime. All receipts tendered by Respondent were true receipts which Mark Breeden signed and later denied. Allegations of Page 12 ofcomplaint regarding so called false checks and so called false receipts are Denied. Pg. 12 Line 46 of the Complaint alleges that Respondent told Breeden on August 27 that Respondent had removed and hidden the money for Breeden are Denied.

5 28. In reviewing the matter Respondent realized that an answergiven regarding the matter was incorrect. On page 14 ofthe Complaint Q. And today you've produced to me a number of receipts, and these were all signed by Mark Breeden A. Yes. (the receipts were signed by Mark Breeden) Q. On or about the dates indicated? A. Yes. Respondent either did not hear the question or failed to think about the answer. The receipts had been signed by Mark Breeden. Respondent had no reason to lie to the ARDC about checks. The Respondent just replied without thinking. In the usual course ofbusiness if a receipt is given it is on the spot. It would be normal to just answer the question one does not always think of such minor matters. Respondent Denies any attempt to deceive the ARDC or anyone else in regard to the matter. Respondent Denies the allegation that Respondent induced Breeden to sign false receipts. Respondent Denies each and every allegation ofwrong doing in regard to Count Three ofthe Complaint. Count Four Respondent has always maintained the bank statements for Respondents Trust Account. Respondent has always checked the balances due to Clients and other parties such as Health Care Providers, and others who may have charges for services rendered. In twenty-five years as a personal injury lawyer the Respondent has never until Breeden's case had a dispute over any claim. The Respondent has always paid the health care providers and loan companies. The Respondent has always given clients Disbursement sheets detailing fees and costs of litigation and the clients sign offon the documents. Respondent has always checked the monthly bank statements and has never had a problem with any matter involving any funds with regard to any Client or Health care provider or expert witness or any other party. As 95 per cent or more ofrespondents work is Personal injury or Workers Compensation Respondent settles cases or wins trials and receives funds from Insurance carriers and disburses the funds to the Clients and pays the health care providers and others within 2-3 days from the receipt ofthe award. The money comes in and goes out to the persons who are entitled to it. Respondent will be certain to strictly follow the rules in the future. As the Commission can see in the record all clients have been paid all funds due to them, Mark Breeden included. Respondent has studied the Rules and will be aware ofthe requirements of the book keeping from here on. Count Five

In Re Carolyn Cawvey: Respondent represented Ms. Cawvey in action against the Village of South Roxana in which Ms. Cawvey was injured in fall at the Municipal building.

6 In Re Carolyn Cawvey: Respondent represented Ms. Cawvey in action against the Village of South Roxana in which Ms. Cawvey was injured in fall at the Municipal building. Of course the Municipality raised the issue of whether the defendant had time to take notice and be aware of thealleged condition. The Respondent went to the site to obtain firsthand knowledge of the situation. The Respondent could not identify any defect in the sidewalk or stairs to the building. As the Respondent believed that the filing of an Amended Complaint would be frivolous Respondent did not take further action. Clearly the Respondent should have filed a Motion for Leave to withdraw and sent a copy to the client. For reasons which Respondent does not understand Respondent did not file such a Motion or contact the client. Attorney Larry Calvo contacted Respondent with regard to the matter. Mr. Calvo reported the matter as was his duty. Mr Calvo did not request Respondent to compensate Ms. Cauvey in any way for the loss of the claim. Respondent believes that Mr. Calvo recognized the claim was worth nothing and the Respondent could not file a frivolous claim. In spite of the fact that Respondent should have contacted the client, no harm was done to the client because the claim had no merit. Count Six Mary Breeden 1. On July 22, 2013 Marry Breeden fell on a sidewalk in Granite City Illinois. Pg. 19 Complaint Line The Respondent agreed to represent Ms. Breeden in an action against Granite City Illinois. Respondent admits he agreed to represent Ms. Breeden. Ms. Breeden told the Investigator that Ms. Breeden did not have a fee agreement with Respondent due to the fact that Respondent's copier was broken on the day that she came to Respondents office. Mary Breeden was confused. Respondent does not make Attorney Representation agreements on a copier, the form is on the computer and the names are typed. Mary Breeden is correct in the statement she made to the investigator when she said there was no fee agreement. Respondent had represented Mary Breeden in 1999 or 2000 in a personal injury matter. Ms. Breeden referred Mark to Respondent. There was no fee agreement. Respondent was going to take the matter pro bono as Mary Breeden is a nice person, she was a client years ago, she referred Mark Breeden to Respondent, and she had a hard life and was either divorced or in the process and Respondent thought she could use a break. Respondent Respondent cannot admit or deny whether Respondent and Ms. Breeden participated in a telephone interview with Gallagher Bassett. Respondent simply cannot be certain. It is probably

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