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ATTORNEY REGISTRATION AND DISCIPLINARY COMMISSION

IN THE SUPREME COURT OF ILLINOIS


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)
In the Matter of: )
)
) Supreme Court No:
)
)
)
Andrew Hays ) No 2014IN3330
Antona Hays ) No 2014IN3331
Sarah !u"# ) No 2014IN3332
$espondents )
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TO:
Andrew Hays
Antona Hays
Sarah !u"#%
Hays Firm LLC,
55 W. Wacker Drive,
14
th
Floor,
Chicago, Illinois 60601
NOTICE OF FILING A RESPONSE
PLEASE TAKE NOTICE that on the _________ day of Septe!e" ##$ #%&'% I
f&ed wth the C&er# of the A$'C the atta"hed Attorney 's"p&nary $ep&y to
Sarah !u"# No 2014IN3332


Chrstopher Sto&&er
(04) *+ ,rand Apt 414
Ch"a-o% I&&nos (0(3.
312-/34 .010
1
ATTORNEY REGISTRATION AND DISCIPLINARY COMMISSION
IN THE SUPREME COURT OF ILLINOIS
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)
In the Matter of: )
)
) Supreme Court No:
)
)
)
Andrew Hays ) No 2014IN3330
Antona Hays ) No 2014IN3331
Sarah !u"# ) No 2014IN3332
$espondents )
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REPLY TO ATTORNEY SARAH (UCK
&
RESPONSE
#

1 Ms. Buck is a graduate of Valparaiso University (1999) and Chicago-ent College of !a" (#$$9). %hile in la"
school& Ms. Buck "as a 'e'(er of the Moot Court )onor *ociety and the "inner of the +ational )ealth !a" 'oot
court co'petition. Upon graduation& Ms. Buck clerked for the )onora(le !ee ,reston "hile he served in (oth the
!a" -ivision and Chancery -ivision of the Circuit Court of Cook County. Ms. Buck is also an ad.unct-professor at
Chicago-ent College of !a"& teaching /llinois Civil ,rocedure. /n this course& she teaches second and third year
la" students the court rules and court procedures necessary to litigate clai's in /llinois state courts.
21he Attorney $e-straton and 's"p&nary Commsson was esta2&shed 2y the
I&&nos Supreme Court to dea& wth ssues of professona& ms"ondu"t of attorneys+
1he serous a&&e-atons of professona& ms"ondu"t that the Comp&anant has rased
re-ardn- the $espondents are ssues that are not 2efore the I&&nos Court n No.
2014 CH06759 + 1he ssues of professona& ms"ondu"t rased 2y ths Attorney
2
0he 1espondent& *arah Buck& provides irrefuta(le evidence that she
violated 21-C 1ules 1.# (d) 2 la"yer shall not counsel a client to engage& or assist a
client& in conduct that the la"yer kno"s is cri'inal or fraudulent&Cri'inal& 3raudulent and
,rohi(ited 0ransactions. %ith kno"ingly and "illfully assisting their client Mark *toller to
co''it a cri'e
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or fraud in Cook County Civil Case No. 2014 CH06759 (Exhibit 1
to complaint.)
The Repon!ent" *arah Buck& p#o$i!e i##e%&table e$i!ence that
he $iolate! 'R(C R&le1.7) C*N+,-CT *+ -NTERE.T) R/,E 0.7(a))
,'12ER '. 1-TNE... 1U!5 6.17 01U0)3U!+5** /+ *0205M5+0*
08 80)51* /n the course of representing a their client Mark *toller& the
*arah Block kno"ingly7 (a) 'ake false state'ent(s) of 'aterial fact or la"
to a third person.
1he $espondents% Sarah !u"#% pro3des rrefuta2&e e3den"e that she
3o&ated A$'C $u&es 1U!5 9.67 M/*C8+-UC0(a)&(()&(c)& (d) violating or
atte'pt to violate the 1ules of ,rofessional Conduct& kno"ingly assist or
's"p&nary "omp&ant are ssues that the Commsson s so&e&y empowered to a"t
upon under the I&&nos $u&es of 4rofessona& Ms"ondu"t and N51 any State Court
6ud-e+
3:9; ,aragraph (d) prohi(its a la"yer fro' kno"ingly counseling or assisting a client to co''it a
cri'e or fraud.
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induce another to do so& or do so through the acts of another. *arah Buck
provided evidence against her of creating a false affidavit of Mark *toller
'arked as Exhibit (
(ACKGROUND FACTS
$espondents Andrew Hays% Antona Hays and
Sarah !u"#% represent % Mar# Sto&&er% 43 the son of Chrstopher Sto&&er% () the
"omp&anant n Coo# County Case No. 2014 CH06759 where Mar# Sto&&er s
"har-ed wth defraudn- hs father out of 7(0%000% aded and a2etted 2y the sad
respondents who are named defendants+ 8See 9:h2t 1 to "omp&ant) 1he response
of Sarah !u"# "&ear&y esta2&shes e3den"e of her professona& ms"ondu"t and
"&ear 3o&atons of the I&&nos 4rofessona& $u&es of 4rofessona& Condu"t+
SARAH (UCK ENGAGED IN A CO)ERUP AND THREATENED
OPPOSING COUNSEL$ FORMER COOK COUNTY *UDGE +AYNE
RHINE$ +ITH A RULE &,- MOTION UNLESS SARA (UCK +AS
IMMEDIATELY DISCHARGED AS DEFENDANT FROM CASE No. 2014
CH06759 (.ee Exhibit lette# %#om Repon!ent 3&c4 to 'tto#ne5 1a5ne
Rhine" 6hich !#o$e %o#me# 7&!8e Rhine o&t o% Cae No. 2014 Ch06759
attache! to 'n!#e6 Ha5 #epone)
4
2fter *ara Buck received service of su''ons na'ing her as a
defendant in case +o. #$16 C)$<=>9& she "rote a letter
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to counsel for
the ,laintiff?Co'plainant& %ayne 1hine threaten hi' "ith a frivolous 1ule
14= sanction 'otion unless *ara Buck "as "ithdra"n fro' case +o #$16
C)$<=>9& as a defendant in order to cover up her professional 'isconduct
and cri'inal conduct.(2ssisting Mark *toller& under the color of la" to
defraud his father the co'plainant out of @<=&$$$& "hen her la" fir' )ays
3ir' !!C is not even registered "ith the /llinois *upre'e Court& licensed to
practice "ithin the state of /llinois.)
4 1he &etter s atta"hed to Andrew Hays $esponse+
)
1espondent Buck "ho pro'otes herself as an ad.unct professor at
ent *chool of !a". %here -ean *tephen *o"le 5sA and -ean )arold B.
rent kne" or should have kno"n that 2d.unct ,rofessor *arah Buck "ho
represented to the Chicago ent *chool of !a" that she "as a ClicensedD
practicing attorney& "hen 2d.unct ,rofessor *arah BuckEs la" fir' that she
ackno"ledged in her response !etter at F 1 C/ take 'y role as an attorney
and as an e'ployee of the )ays 3ir' very seriously
>
.D )o"ever& -ean
*tephen *o"le 5sA and -ean )arold B. rent kne" or should have kno"n
that the fir'& )ays !a" 3ir' !!C& that *arah Buck ackno"ledges (eing an
e'ployee& is not registered nor licensed "ith the /llinois *upre'e Court a
#e9&i#e! b5 R&le 721(c). 1ecently the conseAuences of a la" fir'Es failure
to o(tain a 1ule =#1(c) certificate of registration "ere addressed in Ford
Motor Credit Company v. Sperry, 2ppellate Court of /llinois& *econd -istrict&
+o. #-$#-$6<#& -ecided7 +ove'(er 4& #$$4. /n /llinois& it is "ell
esta(lished that only persons duly ad'itted to practice la" in this state 'ay
appear on (ehalf of other persons. 0he nor'al effect of a personEs
unauthoriGed practice on (ehalf of a party is to reAuire the dis'issal of the
) !u"# 3o&ated A$'C $u&e 4+1 1ruthfu&ness n Statements to 5thers+
(
cause or to treat the particular actions taken (y the representative as a
nullity.D Patt-Holdampf, 449. app. 4- at 1$94& /ll. -ec. =$9& =99 +.5.ed.
Ford Motor Credit Company v. Thomas B. Sperry +o. #-$#-$6<# -ecided
+ove'(er 4& #$$4& 2ppellate Court of /llinois& *econd -istrict. 0o enforce
court orders entered (y unlicensed and therefore unregulated la" fir's
"ould a(rogate the state purpose of the 1ule =#1(c) certificate of
registration
<
. 0he 1espondent violated 21-C 1ule >.> UnauthoriGed
,ractice of !a".
*ara Buck as an e'ployee of the unlicensed la" fir' of )ays 3ir'
!!C has no right to represent& Mark *toller in case +8. +o. #$16
C)$<=>9.
-ean *tephen *o"le& 5sA.& and -ean )arold B. rent 5sA.& kne" or
should have kno"n that the )ays !a" 3ir' !!C& that *arah Buck 'ade a
'isrepresentation to her students at Chicago ent *chool of !a" that she
( 0he /llinois *upre'e Court has pro'ulgated certain rules on the discipline of
attorneys and their ad'ission to the state (ar. 0hese rules provide the reAuire'ents
for those "anting to attain a license to practice la" in the state. *ee 199 /ll. #- 1.
=$1. 0he rules also provide for additional reAuire'ents for those seeking to practice
la" through a professional corporation. *ee 1<< /ll. #d. 1.=#1. 3or instance& rule
=#1(a) reAuires that the corporation do nothing that "ould violate the standards of
professional conduct applica(le to attorneys. *ee 1<< /ll. #d. 1. =#1((). 1ule =#1(c)
reAuires each corporation that seeks to practice la" to register "ith the /llinois
*upre'e Court. *ee 1<< /ll. #- 1. =#1(c) C+o corporation or association or li'ited
lia(ility co'pany shall engage in the practice of la" in /llinois or open or 'aintain an
esta(lish'ent for that purpose in /llinois& "ithout a certificate of registration issued (y
this courtD 1<< /ll #d. 1. =#1(c) as "ell kno"n to -ean *o"le 5sA and -ean
)arold B. rent. 0he Co'plainant "as har'ed (y the )ays 3ir' for their
failure to register.
0
is e'ployee of the )ays !a" 3ir' !!C& and licensed to practice la" "ithin
the *tate of /llinois& "hen the )ays !a" 3ir' !!C is not licensed "ithin the
*tate of /llinois as "ell kno"n to -ean rent and -ean *o"le.
0he 21-C should reAuire that the 1espondent )ays !a" 3ir' !!C.&
send a letter to all of their clients and infor' the' that they are not licensed
to practice la" "ithin the *tate of /llinois and to void all orders that have
(een entered (y the 1espondent )ays !a" 3ir' !!C.
0he 21-C should reAuire that the )ays !a" 3ir' disgorge itself of all
of the attorney fees that have (een paid to the unregistered )ays la" 3ir'.
/ncluding all attorney fees paid to )ays (y Mark *toller.
0he )ays !a" fir' respondents "ere served "ith 2d'issions in Buly
of #$16 in "hich they failed to respond dee'ing all ad'issions as
ad'itted& including the 'ost da'ning ad'ission 1=& C2d'it that Mark
*toller (64) has conspired "ith his attorney(s) Buck to defraud his father out
of @<=&$$$D *ee Exhibit C.
*arah Buck ad'its drafting Mark *tollerEs (per.ured) affidavit "hich is
'ade in (ad faith 'arked as Exhibit (. *ee Christopher *tollerEs attached
conflicting affidavit Exhibit E& "hich contradicts the Mark *tollerEs affidavit&
"hich has no" for the 21-C created a CAuestion of factD that can and 'ust
(e decided at a evidentiary hearing conducted (y the /nAuiry Board. 0he
/
Christopher *toller& <> affidavit should (e given significant "eight.
/t is clear that *arah Buck has failed to de'onstrate the full
acceptance and recognition of the seriousness of her professional
'isconduct.

1HERE+*RE" Co'plainant prays that the /nAuiry Board i''ediately
assign this 'atter to a hearing& panel& that a date for hearing (e
i''ediately set& that the hearing (e conducted and that the panel 'ake
findings of fact& conclusions of la" and a reco''endation for such
discipline as is "arranted (y its findings.
+
Chrstopher Sto&&er
(04) *+ ,rand Apt 414
Ch"a-o% I&&nos (0(3.
312-/34 .010
)ERIFICATION
I% the unders-ned% state that I ha3e made reasona2&e n3est-aton n the fa"ts "ontaned
heren and "ertfy ths p&eadn- pursuant to se"ton 1-10. of the I&&nos Code of C3& 4ro"edure+
;
C."/0top.e" Sto11e"
.
Ce"t/f/2ate of Ma/1/34
I here2y "ertfy that ths moton s 2en- deposted wth the <+S+ 4osta& Ser3"e as
frst C&ass ma& n an en3e&ope addressed to:
6erome =ar#n 're"tor Attorney Admssons
I&&nos Attorney $e-straton 9astern 'str"t
and 's"p&nary Commsson 21. S+ 'ear2orn St
130 N+ $ando&ph Street% Sute 1)00 Ch"a-o% I&&nos (0(04
Ch"a-o% I&&nos (0(01
6ames Comey
're"tor of >!I Ch"a-o
2111 *+ $oose3e&t $d+
Ch"a-o% I& (0(0(
312-/2.-)032
Ch"a-o?e+f2+-o3
@a"hary 1+ >ardon
<ntes States Attorney 5ff"e
Northern 'str"t of I&&nos% 9astern '3son
21. S+ 'ear2orn St% )
th
>&oor
Ch"a-o% I&+ (0(04
312-3)3-)300
=sa Mad-an
I&&nos Attorney ,enera&
100 *+ $ando&ph St+
Ch"a-o% I&&nos (0(01
Ma/1 F"a5d D/6/0/o3
:*.T',-N.:ECT-*N.ER;-CE
4001.H'RR-.*N"R00<50190
CH-C'=* -, 60669>2201

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Chrstopher Sto&&er 'ate:
9AHI!I1 A
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9AHI!I1 !
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9AHI!I1 C
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9AHI!I1 '
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9AHI!I1 9
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