FILED IN THE CIRCUIT COURT OF COOK COUNTY STATE OF ILLINOIS JAN 19 2017 JEROME LARKIN, not individually but as Administrator of theattorney Registration and Disciplinary Commission, ATTY REG & DISCCOMM CHICAGO Petitioner, GRACE OLUWATOYIN AKINLEMIBOLA, Respondent. Case No. Commission No. 201 7PR00Q03 PETITION FOR ADJUDICATION OF MINOR INDIRECT CRIMINAL CONTEMPT AND FOR OTHER RELIEF NOW COMES Jerome Larkin, not individually but as Administrator of the Attorney Registration and Disciplinary Commission (hereinafter "Petitioner"), by his attorney, Scott A. Kozlov, pursuant to the Illinois Attorney Act, 705 ILCS 205/1 et seq., and pursuant to Supreme Court Rule 779(b), and petitions this honorable court to hold Respondent Grace Oluwatoyin Akinlemibola (hereinafter "Respondent") in minor indirect criminal contempt of court, and to order such other and further relief as this court deems proper. In support whereof, Petitioner states as follows: relevant part: NATURE OF THIS ACTION, JURISDICTION, AND VENUE 1. This is an action brought pursuant to Supreme Court Rule 779, which provides, in Unauthorized practice of law proceedings authorized by the Inquiry Board against a person that is not licensed to practice law in any other U.S. jurisdiction...may be brought by the Administrator as civil and/or contempt actions pursuant to the rules of this court, its inherent authority over the practice oflaw, or other laws ofthe State related to the unauthorized practice of law. Proceedings shall be commenced in the
circuit court for the circuit in which venue would be proper under the Code of Civil Procedure (735 ILCS 5/2-101 et seq.)... The circuit court is authorized to enter a final judgment disposing of the case. Appeals from that judgment are governed by Rule 301 ofthis court. 2. On January 18, 2017, the Inquiry Board of the Commission authorized proceedings to be brought against Respondent pursuant to Supreme Court Rule 779. 3. Venue for this action properly lies in the Circuit Court of Cook County, Illinois, pursuant to 735 ILCS 5/2-101, because Respondent resides in Cook County, and Respondent's conduct as referenced herein occurred in Cook County. PARTIES 4. Petitioner, Jerome Larkin, is the Administrator ofthe Attorney Registration and Disciplinary Commission, which is empowered by Supreme Court Rule 779 to bring civil and/or criminal contempt actions against, inter alia, aperson that is not licensed to practice law in any other U.S. jurisdiction. 5. Respondent is a resident of Cook County, who at no time has been licensed to practice law in Illinois or anyother U.S. jurisdiction. UNAUTHORIZED PRACTICE OF LAW IN VIOLATION OF THE ATTORNEY ACT AND THE COMMON LAW 6. In May 2005, Respondent graduated from the Illinois Institute of Technology's Chicago-Kent College of Law with a juris doctorate degree. She has failed the Illinois bar examination on three occasions. 7. On February 2016, Respondent incorporated a business, The Grace Akinlemibola Corporation, with the Illinois Secretary of State's Office. Respondent is the sole officer and director ofthat company.
8. Since approximately May 2015, Respondent has maintained a website for The Grace Akinlemibola Corporation at www, fjachijsiness.com. 9. On the website homepage for www.gacbusiness.mm, Respondent states: The Grace Akinlemibola Corporation was formally created in February of 2016 as a conglomerate corporation consisting of vanous related service and product companies. From subsidiaries ranging from film production to financial and legal services, the corporation now has companies that offer many related services to be a "one-stop shop" for any company orindividual, (emphasis added) 10. On the website www.gacbusiness.com, Respondent also has atab labeled, "Lines of Business." When the tab is activated, adrop down menu lets the user select from the options of, "Finance, Legal, Film, Literary, Political or Property." (emphasis added) If the user selects the Legal option, apage displays, which is titled, "Legal Services." On that page, the following language appears: LEGAL SERVICES Grakin Corporation, the consulting subsidiary, has completed and maintained a variety ofcontracts, also providing services related to contractual development, negotiation, drafting and review among other items. Current projects include, but are not limited to the following: creating a patent for a financial business method, creating areorganized business structure for an existing company, and negotiating and developing contracts for a film project. 11. In connection with each of the matters referenced in paragraphs eight through 10, above, Respondent falsely indicated to purported clients that she had authorization to provide legal services.
12. On October 25, 2016, the Administrator of the Attorney Registration and Disciplinary Commission had Respondent personally served with a subpoena requiring her appearance and production documents related to clients ofthe Grace Akinlemibola Corporation. 13. On November 15, 2016, Respondent appeared at the Attorney Registration and Disciplinary Commission, but she refused to produce any documentation in response to the Administrator's subpoena. "legal services" from her website. At that time, Respondent also refused to remove the reference to 14. Respondent knew that her actions in holding herself out as authorized to provide legal services constituted the unauthorized practice of law, yet she willfully and knowingly engaged in those actions and continues to engage in such conduct. 15. Respondent has engaged in the unauthorized practice oflaw through a course of conduct in violation of the Illinois common law, including by falsely representing directly and by implication to the public on the website, www.gacbusiness.com. as referenced in paragraphs nine and 10, above, that she was authorized to provide legal services in the State of Illinois. People v. Goodman, 366 111. 346, 8N.E.2d 941 (1937). 16. Section 1ofthe Attorney Act, 705 ILCS 205/1, provides, in relevant part: no person shall be permitted to practice as an attorney or counselor at law within this State without having previously obtained a license for that purpose from the Supreme Court of this State. no person shall receive any compensation directly or indirectly for any legal services other than a regularly licensed attorney, nor may an unlicensed person advertise or hold himself or herself out to provide legal services. any person practicing, charging or receiving fees for legal services or advertising or holding himself or herself out to provide legal services within this State, either directly or indirectly, without See
being licensed to practice as herein required, is guilty of contempt of court and shall be punished accordingly, upon complaint being filed in any Circuit Court of this State. The remedies available include, but are not limited to: (i) appropriate equitable relief; (ii) a civil penalty not to exceed $5,000, which shall be paid to the Illinois Equal Justice Foundation; and (iii) actual damages. 17. Respondent has engaged in the unauthorized practice of law through a course of conduct in violation of the Illinois Attorney Act, 705 ILCS 205/1, including by falsely representing directly and by implication to the public on the website, www.gacbusiness.com. as referenced in paragraphs nine and 10, above, that she was authorized to provide legal services in the State ofillinois. WHEREFORE, the Administrator prays that this honorable Court enter judgment: A. Finding Respondent guilty of minor indirect criminal contempt of court pursuant to the Court's inherent authority as recognized in Supreme Court Rule 779, and Chicago Bar Association v. Goodman, 366 111. 346,8N.E.2d941(1937); B. Imposing punitive sanctions and/or fines against the Respondent/Contemnor for his minor indirect criminal contempt of court, including a fine of no more than $2,500, and a period of incarceration ofless than one (1) year; C. Declaring that Respondent has engaged in the unauthorized practice of law in violation ofthe Illinois Attorney Act, 705 ILCS 205/1; D. Imposing a civil penalty against Respondent in an amount not to exceed $5,000, payable to the Illinois Equal Justice Foundation, for each violation of the Illinois Attorney Act, 705 ILCS 5/201 etseq.; E. Temporarily and permanently enjoining Respondent from engaging in the business of providing legal services in the State of Illinois; and Providing for such other and further relief as justice and equity may require.
F. Providing for such other and further relief as justice and equity may require. Respectfully submitted, Scott A. Kozlov Counsel for the Administrator One Prudential Plaza 130 East Randolph Drive, Suite 1500 Chicago, Illinois 60601 Telephone: (312) 565-2600 Attorney Number 91502 Jerome Larkin, Administrator Attorney Registration and Disciplinary Commission By: 0. Scott A. Kozlov MAINLIB #850562 vl
Summons-Individual/Corporation (Replaces CCMC 0232) CCCR N232-10M-06/09/04 ( IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS JEROME LARKIN, not individually but as Administrator of the Attorney Registration anddisciplinary Commission, No. GRACEOLUWATOYIN AKINLEMIBOLA. Commission No. SUMMONS THE PEOPLE OF THE STATE OF ILLINOIS TO ALL PEACE OFFICERS IN THE STATE - GREETING: WE COMMAND THAT YOU SUMMON Grace Oluwatoyin Akinlemibola 203 N. LaSalle Street, Suite 2100 Chicago, IL 60601, an individual/a corporation if he shall be found in the State of Illinois to be and appear before The Circuit Court of Cook County, at 555 W. Harrison St., Branch 46 Courtroom, Chicago, IL 60607, at 9:00am sharp, on, 2017, to answer unto the People of the State of Illinois for and concerning the charge of Unauthorized Practice of Law - Indirect Criminal Contempt filed in said Court, and have you then and there this writ with the endorsement thereon, in what manner you shall have executed the same. Cook County Arty No. 91502 Issued in Cook County, Name: Scott A. Kozlov Attorney for: The ARDC Administrator Address: 130 E. Randolph Dr., Suite 1500 City/State/Zip: Chicago, IL 60601 Telephone: (312) 565-2600 Judge Judge's No. WITNESS: DOROTHY BROWN, CLERK OFTHE COURT and the Seal thereof, at Chicago Clerk I executed this writ by servingthe within named on MAINLIB #850579 vl