State Bar Court of California

Hearing Department

STIPULATION RE FACTS, CONCLUSIONS OF LAW

DISPOSITION AND ORDER APPROVING DISBARMENT; ORDER OF INVOLUNTARY INACTIVE ENROLLMENT

Case Number(s): 12-N-16993-PEM

In the Matter of: David Lin, Bar # 174022, A Member of the State Bar of California, (Respondent).

Counsel For The State Bar: Heather E. Abelson, Deputy Trial Counsel

180 Howard Street

San Francisco, CA 94105-1639

Phone: (415) 538-2357

Bar # 243691,

Counsel for Respondent: in Pro Per Respondent

David Lin

1036 Jena Terrace

Sunnyvale, CA 94089

Bar # 174022

Submitted to: State Bar Court Clerk’s Office San Francisco.

Filed: January 14, 2013.

  <<not>> checked. PREVIOUS STIPULATION REJECTED

Note:  All information required by this form and any additional information which cannot be provided in the space provided, must be set forth in an attachment to this stipulation under specific headings, e.g., "Facts," "Dismissals," "Conclusions of Law," "Supporting Authority," etc.

A. Parties' Acknowledgments:

1.    Respondent is a member of the State Bar of California, admitted December 7, 1994.

2.    The parties agree to be bound by the factual stipulations contained herein even if conclusions of law or disposition are rejected or changed by the Supreme Court.

3.    All investigations or proceedings listed by case number in the caption of this stipulation are entirely resolved by this stipulation and are deemed consolidated. Dismissed charge(s)/count(s) are listed under "Dismissals."  The stipulation consists of 9 pages, not including the order.

4.    A statement of acts or omissions acknowledged by Respondent as cause or causes for discipline is included under "Facts."

5.    Conclusions of law, drawn from and specifically referring to the facts are also included under "Conclusions of Law".

6.    The parties must include supporting authority for the recommended level of discipline under the heading "Supporting Authority."

7.    No more than 30 days prior to the filing of this stipulation, Respondent has been advised in writing of any pending investigation/proceeding not resolved by this stipulation, except for criminal investigations.

8.    Payment of Disciplinary Costs-Respondent acknowledges the provisions of Bus. & Prof. Code §§6086.10 & 6140.7. (Check one option only):

checked. Costs are awarded to the State Bar.
<<not>> checked. Costs are waived in part as set forth in a separate attachment entitled "Partial Waiver of Costs".
<<not>> checked. Costs are entirely waived.

9.    ORDER OF INACTIVE ENROLLMENT:
The parties are aware that if this stipulation is approved, the judge will issue an order of inactive enrollment under Business and Professions Code section 6007, subdivision (c)(4), and Rules of Procedure of the State Bar, rule 5.111(D)(1).

B. Aggravating Circumstances [for definition, see Standards for Attorney Sanctions for Professional Misconduct, standard 1.2(b)]. Facts supporting aggravating circumstances are required.

<<not>> checked. (1)   Prior record of discipline [see standard 1.2(f)].

<<not>> checked. (a)    State Bar Court case # of prior case .
<<not>> checked. (b)    Date prior discipline effective .
<<not>> checked. (c)    Rules of Professional Conduct/ State Bar Act violations:  
<<not>> checked. (d)    Degree of prior discipline  
<<not>> checked. (e)    If Respondent has two or more incidents of prior discipline, use space provided below. .

<<not>> checked. (2)   Dishonesty:  Respondent's misconduct was surrounded by or followed by bad faith, dishonesty, concealment, overreaching or other violations of the State Bar Act or Rules of Professional Conduct.

<<not>> checked. (3)   Trust Violation:  Trust funds or property were involved and Respondent refused or was unable to account to the client or person who was the object of the misconduct for improper conduct toward said funds or property.

<<not>> checked. (4)   Harm:  Respondent's misconduct harmed significantly a client, the public or the administration of justice.

<<not>> checked. (5)   Indifference:  Respondent demonstrated indifference toward rectification of or atonement for the consequences of his or her misconduct.

<<not>> checked. (6)   Lack of Cooperation:  Respondent displayed a lack of candor and cooperation to victims of his/her misconduct or to the State Bar during disciplinary investigation or proceedings.

<<not>> checked. (7)   Multiple/Pattern of Misconduct:  Respondent's current misconduct evidences multiple acts of wrongdoing or demonstrates a pattern of misconduct.

checked. (8)             No aggravating circumstances are involved.
Additional aggravating circumstances: .

C. Mitigating Circumstances [see standard 1.2(e)]. Facts supporting mitigating circumstances are required.

<<not>> checked. (1)       No Prior Discipline:  Respondent has no prior record of discipline over many years of practice coupled with present misconduct which is not deemed serious.

<<not>> checked. (2)   No Harm:  Respondent did not harm the client or person who was the object of the misconduct.

<<not>> checked. (3)   Candor/Cooperation:  Respondent displayed spontaneous candor and cooperation with the victims of his/her misconduct and to the State Bar during disciplinary investigation and proceedings.

<<not>> checked. (4)   Remorse:  Respondent promptly took objective steps spontaneously demonstrating remorse and recognition of the wrongdoing, which steps were designed to timely atone for any consequences of his/her misconduct.

<<not>> checked. (5)   Restitution:  Respondent paid $   on   in restitution to without the threat or force of disciplinary, civil or criminal proceedings.

<<not>> checked. (6)   Delay:  These disciplinary proceedings were excessively delayed.  The delay is not attributable to Respondent and the delay prejudiced him/her.

<<not>> checked. (7)   Good Faith:  Respondent acted in good faith.

<<not>> checked. (8)   Emotional/Physical Difficulties:  At the time of the stipulated act or acts of professional misconduct Respondent suffered extreme emotional difficulties or physical disabilities which expert testimony would establish was directly responsible for the misconduct.  The difficulties or disabilities were not the product of any illegal conduct by the member, such as illegal drug or substance abuse, and Respondent no longer suffers from such difficulties or disabilities.

<<not>> checked. (9)   Severe Financial Stress:  At the time of the misconduct, Respondent suffered from severe financial stress which resulted from circumstances not reasonably foreseeable or which were beyond his/her control and which were directly responsible for the misconduct.

<<not>> checked. (10) Family Problems:  At the time of the misconduct, Respondent suffered extreme difficulties in his/her personal life which were other than emotional or physical in nature.

<<not>> checked. (11) Good Character:  Respondent's good character is attested to by a wide range of references in the legal and general communities who are aware of the full extent of his/her misconduct.

<<not>> checked. (12) Rehabilitation:  Considerable time has passed since the acts of professional misconduct occurred followed by convincing proof of subsequent rehabilitation.

checked. (13)                No mitigating circumstances are involved.

Additional mitigating circumstances:  

D. Discipline: Disbarment.

E. Additional Requirements:

(1) Rule 9.20, California Rules of Court:  Respondent must comply with the requirements of rule 9.20, California Rules of Court, and perform the acts specified in subdivisions (a) and (c) of that rule within 30 and 40 calendar days, respectively, after the effective date of the Supreme Court's Order in this matter.

<<not>> checked. (2)   Restitution:  Respondent must make restitution to  in the amount of $  plus 10 percent interest per year from  .  If the Client Security Fund has reimbursed  for all or any portion of the principal amount, respondent must pay restitution to CSF of the amount paid plus applicable interest and costs in accordance with Business and Professions Code section 6140.5.  Respondent must pay the above restitution and furnish satisfactory proof of payment to the State Bar's Office of Probation in Los Angeles no later than  days from the effective date of the Supreme Court order in this case..

checked. (3)             Other: Respondent shall comply with any restitution order in the underlying criminal action (Case No. 3:11-cr-00393).

Attachment language (if any):.

ATTACHMENT TO

STIPULATION RE FACTS, CONCLUSIONS OF LAW AND DISPOSITION

 

IN THE MATTER OF: David Lin, State Bar No. 174022

STATE BAR COURT CASE NUMBER: 12-N-16993-PEM

 

FACTS AND CONCLUSIONS OF LAW.

 

Respondent admits that the following facts are true and that he is culpable of violations of the specified statutes and/or Rules of Professional Conduct.

 

Case No. 12-N-16993-PEM (Rule 9.20 Proceeding)

 

FACTS:

 

1. On May 15, 2012, Respondent was convicted of violating 18 U.S.C. sections 1349 (conspiracy to commit mail and wire fraud), 1341 (mail fraud), and 1343 (wire fraud) in the United States District Court, Northern District of California, San Francisco Division, Case No. 3:11-cr-00393. Respondent appealed his conviction, and his appeal is pending.

 

2. On June 29, 2012, the Review Department of the State Bar Court, In Bank, issued an Interim. Suspension After Conviction Order in Case No. 12-C-13717 (hereinafter "9.20 Order"). The 9.20 Order included a requirement that Respondent comply with Rule 9.20, California Rules of Court, by performing the acts specified in subdivisions (a) and (c) within 30 and 40 days, respectively, after the effective date of the 9.20 Order.

 

3. On June 29, 2012, a Case Administrator of the State Bar Court properly served upon Respondent a copy of the 9.20 Order. Respondent received the 9.20 Order.

 

4. The Review Department Order became effective on July 22, 2012. Thus, Respondent was ordered to comply with subdivision (a) of Rule 9.20 of the California Rules of Court no later than on or about August 26, 2012, and was ordered to comply with subdivision (c) of Rule 9.20 no later than on or about September 5, 2012.

 

5. To date, Respondent has not filed with the clerk of the State Bar Court a declaration of compliance with Rule 9.20(a), California Rules of Court, as required by Rule 9.20(e).

 

CONCLUSIONS OF LAW:

 

6. By not filing a declaration of compliance with Rule 9.20, Respondent has failed to comply with the Review Department’s 9.20 Order requiring Respondent to do acts connected with or in the course of his professions which he ought in good faith to do, in wilful violation of Business and Professions Code section 6103.

 

AUTHORITIES SUPPORTING DISCIPLINE.

 

The Standards for Attorney Sanctions for Professional Misconduct provide a "process of fixing discipline" pursuant to a set of written principles to "better discharge the purposes of attorney discipline as announced by the Supreme Court." (Rules Proc. of State Bar, tit. IV, Stds. for Atty. Sanctions for Prof. Misconduct, Introduction (all further references to standards are to this source).) The primary purposes of disciplinary proceedings and of the sanctions imposed are "the protection of the public, the courts and the legal profession; the maintenance of high professional standards by attorneys and the preservation of public confidence in the legal profession." (In re Morse (1995) 11 Cal.4th 184, 205; std 1.3 .)

 

Although not binding, the standards are entitled to "great weight" and should be followed "whenever possible" in determining level of discipline. (In re Silverton (2005) 36 Cal.4th 81, 92, quoting In re Brown (1995) 12 Cal.4th 205,220 and In re Young (1989) 49 Cal.3d 257, 267, fn. 11.) Adherence to the standards in the great majority of cases serves the valuable purpose of eliminating disparity and assuring consistency, that is, the imposition of similar attorney discipline for instances of similar attorney misconduct. (In re Nancy 0990) 51 Cal.3d 186, 190.) Any discipline recommendation different from that set forth in the applicable standards should clearly explain the reasons for the deviation. (Blair v. State Bar (1989) 49 Cal.3d 762, 776, fn. 5.)

 

Here, Respondent violated Business and Professions Code section 6103 by willfully failing to comply with the Review Department’s Rule 9.20 Order. The applicable standard is Standard 2.6(b) which provides that a violation of section 6103 shall result in disbarment or suspension "depending on the gravity of the offense or the harm, if any, to the victim[.]" The expect level of discipline set forth in the plain language of California Rules of Court, rule 9.20, as well as related case law supports a level of discipline in this matter at the highest level of standard 2.6(b).

 

Rule 9.20 states in pertinent part "A suspended member’s willful failure to comply with the provisions of this role constitutes a cause for disbarment .... "

 

Disbarment is also supported by caselaw. In Matter of Esau (2007) 5 Cal. State Bar Rptr. 131, the Review Department disbarred respondent for failing to comply with rule 9.20. The Court stated "Indeed, the finding that respondent willfully violated a court order requiring his compliance with rule 9.20 is sufficient grounds for disbarment when, as here, the evidence in mitigation is not compelling." ld. at 133. The Court noted that "the decisional law has been weighted towards disbarment for violations of rule 9.20. Id. at 138. The Court further noted that recent cases that "resulted in discipline of less than disbarment involved significant evidence in mitigation and/or substantial compliance with rule 9.20[.]" ld. Here, disbarment is appropriate because, as in Esau, there is not compelling evidence in mitigation, nor is there substantial compliance with rule 9.20.

 

PENDING PROCEEDINGS.

 

The disclosure date referred to, on page 2, paragraph A(7), was December 19, 2012.

 

COSTS OF DISCIPLINARY PROCEEDINGS.

 

Respondent acknowledges that the Office of the Chief Trial Counsel has informed respondent that as of December 20, 2012, the prosecution costs in this matter are $2,382.00. Respondent further acknowledges that should this stipulation be rejected or should relief from the stipulation be granted, the costs in this mater may increase due to the cost of further proceedings.

SIGNATURE OF THE PARTIES

Case Number(s): 12-N-16993-PEM

In the Matter of: David Lin, State Bar No.: 174022

 

By their signatures below, the parties and their counsel, as applicable, signify their agreement with each of the recitation and each of the terms and conditions of this Stipulation Re Facts, Conclusions of Law and Disposition.

 

Signed by:

 

Respondent: David Lin

Date: December 21, 2012

 

Respondent’s Counsel:

Date:

 

Deputy Trial Counsel: Heather E. Abelson

Date: December 26, 2012

DISBARMENT ORDER

Case Number(s): 12-N-16993-PEM

In the Matter of: David Lin, State Bar No.: 174022

 

Finding the stipulation to be fair to the parties and that it adequately protects the public, IT IS ORDERED that the requested dismissal of counts/charges, if any is GRANTED without prejudice, and:

 

checked. The stipulated facts and disposition are APPROVED and the DISCIPLINE RECOMMENDED to the Supreme Court.

<<not>> checked. The stipulated facts and disposition are APPROVED AS MODIFIED as set forth below, and the DISCIPLINE IS RECOMMENDED to the Supreme Court.

<<not>> checked. All Hearing dates are vacated.

 

The parties are bound by the stipulation as approved unless: 1) a motion to withdraw or modify the stipulation, filed within 15 days after service of this order, is granted; or 2) this court modifies or further modifies the approved stipulation. (See rule 5.58 (E) & (F), Rules of Procedure.) The effective date of this disposition is the effective date of the Supreme Court order herein, normally 30 days after the file date. (See rule 9.18(a), California Rules of Court.)

Respondent David Lin is ordered transferred to involuntary inactive status pursuant to Business and Professions Code section 6007, subdivision (c)(4). Respondent’s inactive enrollment will be effective three (3) calendar days after this order is served by mail and will terminate upon the effective date of the Supreme Court’s order imposing discipline herein, or as provided for by rule 5.111(D)(2) or the Rules of Procedure of the State Bar of California, or as otherwise ordered by the Supreme Court pursuant to its plenary jurisdiction.

 

Signed by:

Judge of the State Bar Court: Pat E McElroy

Date: January 14, 2013

CERTIFICATE OF SERVICE

[Rules Proc. of State Bar; Rule 5.27(B); Code Civ. Proc., § 1013a(4)]

 

I am a Case Administrator of the State Bar Court of California. I am over the age of eighteen and not a party to the within proceeding. Pursuant to standard court practice, in the City and County of San Francisco, on January 14, 2013, I deposited a true copy of the following document(s):

 

STIPULATION RE FACTS, CONCLUSIONS OF LAW AND DISPOSITION AND ORDER APPROVING

 

in a sealed envelope for collection and mailing on that date as follows:

 

checked. by first-class mail, with postage thereon fully prepaid, through the United States Postal Service at San Francisco, California, addressed as follows:

 

DAVID LIN

1036 JENA TER

SUNNYVALE, CA 94089

 

checked. by interoffice mail through a facility regularly maintained by the State Bar of California addressed as follows:

 

Heather E. Abelson, Enforcement, San Francisco

 

I hereby certify that the foregoing is true and correct. Executed in San Francisco, California, on January 14, 2013.

 

Signed by:

George Hue

Case Administrator

State Bar Court