November 1, 2012
The Illinois Administrator has filed a complaint alleging misconduct based on the following factual averments:
During all of 2011 and continuing through the early months of 2012, Respondent lived in Mannheim, Germany, where he worked as in-house assistant general counsel for a multinational corporation that has its corporate headquarters in Illinois. Respondent's responsibilities included advising the corporation on export control matters. Respondent did not maintain a private practice apart from the legal work he did for the corporation.
During that same period, Respondent had a personal relationship with a woman who was a citizen of Turkey, and who required a visa in order to travel from that country to visit Respondent in Germany. Respondent knew that a business visa would allow the woman to stay in Germany for a longer period than would a personal visa. Respondent also knew that the woman did not meet the qualifications necessary to receive a business visa.
On September 8, 2011 and January 25, 2012, Respondent prepared two separate letters addressed to the consular visa section of the German embassy in Turkey. Both letters were printed on letterhead stationery that identified Respondent as an attorney licensed to practice law in Illinois, and which listed Respondent's home address as the location of a law firm.
In the letters...Respondent stated that he was a member of a law firm that specialized in export control law, that he advised international clients in export compliance and proceedings, and that the firm requested that the woman...be granted a business visa to attend a series of meetings related to Turkey and its purported "particular role as an emerging market for our clients." Respondent forwarded both letters to the woman...with the expectation that she would deliver them to the German embassy in support of an application for a business visa for which she was not otherwise qualified.
Respondent's statements in the two letters...were false, and Respondent knew that they were false, because he was not then a member of a law firm specializing in export control law, he was not engaged in advising international clients in export compliance and proceedings, and there was no series of meetings scheduled with the woman to discuss exports to Turkey or any other business purpose.
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