September 2025

DISBARMENT

Drexel Andrew Bradshaw

State Bar #209584, San Francisco (August 2, 2025)

Bradshaw was disbarred after multiple appeals culminating in a unanimous opinion by the California Supreme Court (In re Bradshaw, 17 Cal. 5th 1095 (2025)).

The State Bar Court's Hearing Department had initially recommended disbarment in the disciplinary case, but the Review Department instead recommended a six-month actual suspension and two years of probation. The Office of the Chief Trial Counsel petitioned to review that recommendation.

The California Supreme Court found Bradshaw culpable of breaching his fiduciary duties, making material misrepresentations to deceive the court, and engaging in a scheme to defraud the trust he administered--misconduct involving moral turpitude.

Bradshaw initially represented a client in a landlord-tenant dispute. She then requested that his firm prepare a will and trust as her estate plan. The documents specified that the trustee should "expend as much of the trust estate as necessary" to avoid placing her in assisted living or other alternative living arrangements. When the client was 85 years old, she fell in her home and was diagnosed with dementia. Bradshaw was appointed as the client's conservator--though the appointing petition falsely claimed that the client had been removed from her home by Adult Protective Services. The probate court denied Bradshaw's initial requests to waive court accounting and terminate its supervision of the trust.

Around the time Bradshaw became conservator, he hired an individual to make repairs to the conservatee's residence and rental property. The  handyman was not a licensed contractor, but Bradshaw paid $1,000 for him to attend a licensing course, then formed a "construction company" naming himself as sole signatory and agent. After the handyman's first and second license applications were denied, Bradshaw was advised to hire a "Responsible Managing Officer" (RMO) for the company, and did so, though the individual did not meet the statutory requirements of being permanently employed by and actively engaged in the business. After the RMO was paid $6,000, the company obtained a contractor's license with the former repairman listed as president, secretary, treasurer, and owner; Bradshaw bankrolled the business checking account and remained sole authorized signatory. Two credit card accounts were opened for the business, issued to Bradshaw, his wife, son, and a receptionist at Bradshaw's law firm.

Bradshaw then sought and was granted first and second mortgages on the conservatee's home--though the probate court conditioned the second mortgage on limiting $250,000 to be paid for the conservatee's care and living expenses, with any other expenditures requiring court approval. After the conservatee died at age 86, Bradshaw was removed as trustee--finding that he had "committed significant breaches" in his duties.

A total of $70,793 was paid to the construction company from trust assets.

In aggravation, Bradshaw had a prior record of discipline, committed multiple acts of misconduct in the instant matter that substantially harmed a client who was highly vulnerable due to her age, and demonstrated indifference to atoning for or acknowledging his wrongdoing.

In mitigation, the supreme court reviewed the character evidence and cooperation exhibited by stipulating to some facts and exhibits--both of which had been accepted by the Hearing Department and Review Department--and found they merited "little weight."

Jacqueline Elizabeth Devlin

State Bar #241764, Oroville (August 29, 2025)

Devlin was disbarred by default after she failed to participate in her disciplinary proceeding, either in person or through counsel, despite receiving adequate notice and having the opportunity to do so. She had earlier entered a plea of no contest to one count of committing vandalism causing more than $400 in damages (Cal. Penal Code § 594(a)(1)).

In the underlying matter, Devlin saw her brother-in-law's car parked outside a market, and when he came out of the store, asked him for a ride to her home. After he refused, she became agitated, took a set of keys out of her purse, and ran them across the side of the car--causing a long scratch. Devlin then told police officers investigating at the scene that she did not possess any keys--though a subsequent search of her purse revealed three keys and three metal bottle openers.

Duane R. Folke

State Bar #137341, Los Angeles (August 29, 2025)

Folke was disbarred after being found culpable on appeal of four of the six counts of professional misconduct with which he was originally charged--all of them related to a single client matter.

His wrongdoing included: failing to represent a client with diligence, failing to promptly account for client funds, improperly withdrawing from representation, and failing to refund unearned advanced fees.

In the underlying matter, Folke was associated as co-counsel in the trial of a wrongful termination case--paid $11,700 in advanced fees.

He met with co-counsel, who stressed the urgency of the matter, accepted a copy of the complaint and client case files and materials, and initially, communicated through several email messages. However, Folke abruptly abandoned his representation, without performing any meaningful work on the case, and without providing notice to either the co-counsel or client.

After the client terminated Folke's services and demanded a refund of the advanced fees, he claimed their fee agreement had been orally modified--a claim the State Bar Court found lacked credibility. The client ultimately sought a return of the fees paid by initiating a fee arbitration. The arbitrator ordered a return of the fees plus arbitration filing costs. While that decision was reversed on appeal, the matter was remanded with instructions to determine whether equitable considerations might excuse Folke's failure to timely serve his petition.

In recommending disbarment, the State Bar Court underscored Folke's lack of credibility at trial, noting: "His statements were often vague and imprecise, and his responses frequently prefaced with phrases such as 'I believe' or 'I think,' which undermine their credibility. Further, his testimony was self-serving and uncorroborated by credible evidence."

In aggravation, Folke had two prior instances of professional discipline, committed multiple acts of wrongdoing in the instance case that significantly harmed his client, demonstrated indifference to the misconduct involved by refusing to  recognize the seriousness of the charges and by shifting blame to others, and continuingly failed to make restitution to his client.

In mitigation, he was allotted limited weight for evidence of performing some community service that lacked specific details.

Erin Sabrina Sullivan Guzman

State Bar #230936, Oceanside (August 22, 2025)

Guzman was disbarred by default.

Though she appeared at an early status conference in the case, she did not participate further in the disciplinary proceedings brought against her.

State Bar representatives, notifying Guzman of the consequences of failing to respond to the notice of disciplinary charges and default order filed against her, reached her by telephone. Guzman informed them of her new email address at that time, and a courtesy copy of the charges were sent to it. She did not move to have the default entered against her set aside or vacated, and the State Bar Court found that the factual allegations made support the conclusion that she was culpable of all five counts charged.

Her wrongdoing, which related to a single client case, included: failing to act with reasonable diligence in representing her client, failing to respond to reasonable client inquiries, failing to return the client's papers and property after being requested to do so, failing to refund unearned advanced fees, and failing to cooperate in the State Bar's investigation of the misconduct alleged.

There was one additional investigative matter pending against Guzman at the time she was disbarred in the instant case.

SUSPENSION

William Taylor Carss

State Bar #218460, Irvine (August 8, 2025)

Carss was suspended from practicing law for six months and placed on probation for one year. In his disciplinary proceeding, he had stipulated to two acts of professional misconduct related to a single matter: allowing a nonlawyer to act as an officer of a law firm and failing to deposit client funds in a trust account.

When the COVID-19 pandemic impacted his law practice, Carss sought and secured additional employment with a Pennsylvania law firm focused on debt resolution that was purportedly seeking a "managing attorney" for a California-based office. The person who hired Carss was a disbarred attorney formerly licensed to practice in California and Nevada who held himself out as a vendor consultant/business advisor for the Pennsylvania firm.

During Carss' tenure in the position, clients paid fees through monthly automatic bank debits--the sums intended to pay for debt resolutions services.

Unbeknownst to Carss, articles of incorporation were filed in California for a for-profit firm--listing Carss as the CEO, CFO, director, secretary, and agent. Also, without Carss' knowledge, the disbarred attorney transferred 20,000 open files and 200 California clients to a firm that he controlled, forging Carss' signature on letters to the clients informing them their cases were going to be taken over. Carss later discovered the new firm was created to facilitate transferring clients in the face of pending litigation and to siphon off the automatic payment funds.

A total of $2.5 million in unearned fees were drawn from the client accounts, but that amount was later seized by the trustee after the firm filed for Chapter 11 bankruptcy. Carss fully cooperated with the trustee in protecting the clients and recovering their files.

In mitigation, Carss entered into a prefiling stipulation, had practiced law discipline-free for approximately 21 years, fully cooperated with the bankruptcy trustee to protect client interests, submitted evidence of performing community service, and provided letters from 15 individuals taken from the legal and general communities--all of whom vouched for his good character.

Amber Hope Gordon

State Bar #276908, Los Angeles (August 22, 2025)

Gordon was suspended for 30 days and placed on probation for two years after she stipulated to committing nine counts of professional misconduct related to two matters.

She was culpable of: failing to keep a client reasonably informed of significant case developments, engaging in conduct prejudicial to the administration of justice, disobeying a court order, and two counts each of failing to act with reasonable diligence in representing a client, failing to perform legal services with competence, and failing to maintain the respect due the court.

In one matter, Gordon was appointed as Indigent Defendant Counsel for two incarcerated individuals--both of whom were likely eligible to have their sentences reduced due to a new law mandating resentencing. However, Gordon took no steps to petition the court for sentence reductions and for parole in light of the new laws, nor did she attempt to explain why either client might not be eligible for parole. Instead, she sought multiple continuances--causing both cases to be delayed for approximately one year. A new Indigent Defendant Counsel was eventually appointed, who sought re-sentencing hearings; both clients were released from prison soon after that.

In another case, Gordon substituted in as appointed counsel in a criminal appellate case--again seeking multiple extensions over requesting more time to file an opening brief over a period of 11 months. The court eventually sent a letter directing Gordon to either file an opening brief or request an additional extension of time to do so. She failed to file or submit a request for more time, and failed to inform her client of the court's order. The client terminated Gordon's services, and new counsel was appointed to handle the case.

In aggravation, Gordon committed multiple acts of wrongdoing that significantly harmed clients who were vulnerable due to their incarcerated states.

In mitigation, she entered into a prefiling stipulation, had practiced law discipline-free for nearly 12 years, provided letters from nine individuals from varying backgrounds--all of whom attested to her good character, and suffered from physical pain during the time of the misconduct due to two head injuries.

Petro Richard Kostiv

State Bar #285859, Los Angeles (August 29, 2025)

Kostiv was suspended from the practice of law for 60 days and placed on probation for one year.

He was originally charged with eight counts of professional misconduct related to several cases involving Immigration Court proceedings. A hearing judge found him culpable of five of the counts charged, and recommended six months of actual suspension.

In this appeal, the panel found that the Office of Chief Trial Counsel failed to prove culpability  of the counts, and agreed with Kostiv's argument that his act of misrepresentation was "grossly negligent" as opposed to intentional. It recommended imposing lesser discipline: 60 days of actual suspension.

Kostiv was found culpable of three counts of failing to perform legal services with competence, and misrepresentation--misconduct involving moral turpitude.

In one of the cases at issue, he represented a client with several applications related to immigration matters; an attorney experienced in immigration who shared office space with Kostiv for a time was affiliated in the case--securing a new notice of hearing date, though Kostiv remained the attorney of record. Both attorneys claimed they did not receive subsequent communications from the Immigration Court. No response was filed, nor did either lawyer appear at the hearing in the case--which was rescheduled to an earlier date; a judge found the application had been abandoned and entered an order of removal against the client. Kostiv's later attempts to reopen the case and appeal the order were unsuccessful. The panel on appeal underscored that Kostiv, who was aware of irregularities in receiving communications from the Immigration Court in the case, had a "duty to at least investigate the court record" for the relevant status and hearing dates.

In another matter, an immigration judge ordered Kostiv's client to be removed after a receptionist at his firm misinformed them both that her hearing had been rescheduled. Kostiv failed to file to correct the facts setting out the reasons they failed to appear. The Board of Immigration Appeals later granted a remand of the case under a new attorney, finding Kostiv's representation had been "deficient."

In mitigation, Kostiv was allotted moderate weight for cooperating with the State Bar in its investigation and for submitting evidence of his good character, as well as substantial weight for performing community service.

In aggravation, he received moderate weight for committing multiple acts of misconduct and for causing significant harm to one of his clients.

Timothy Alan Provis

State Bar #104800, Port Washington, Wisconsin (August 6, 2025)

Provis was suspended from practicing law for 60 days and placed on probation for one year after he stipulated to committing four acts of professional misconduct--all of them related to a single client case brought in another jurisdiction.

He was culpable of: failing to pursue only legal and just actions, failing to comply with a court order, and two counts of failing to report judicial sanctions imposed to the State Bar as required.

In the underlying matter, Provis filed a complaint in Wisconsin, alleging several people formed a "racketeering enterprise" to prevent his client from using an easement that would allow him to access a lake. The complaint asserted several facts that proved to be false--including that the client had a valid deed to the related property. And it asserted several legal theories that were later found to be frivolous and unreasonable. In addition, the client had previously litigated the issue of using the easement; three courts had denied the use sought. 

A Wisconsin court found that Provis had violated a Federal Rule of Civil Procedure (rule 11(b)(3)) by failing to reasonably certify that the factual contentions in the complaint he filed were supported by evidence.

During the course of the litigation. Provis and his client were ordered jointly and severally liable for sanctions of $53,483 imposed by a district court; a circuit court imposed an additional sanction of $25,512 against Provis alone. Provis has not paid either sanction amount, and failed to report the sanctions imposed until after the State Bar began its investigation into the matter.

In aggravation, Provis committed multiple acts of wrongdoing that significantly harmed the administration of justice by wasting court time and resources.

In mitigation, he entered into a profiling stipulation and had practiced law approximately 38 years without a record of discipline.

Renee Estelle Sanders

State Bar #226258, Pasadena (August 6, 2025)

Sanders was suspended for 60 days and placed on probation for one year after she stipulated to committing six acts of professional misconduct related to two client matters.

Her wrongdoing included: depositing funds received without the required prior court authorization, failing to report to the State Bar that she had terminated the employment of a disbarred attorney, failing to maintain a client trust fund account journal and two counts of failing to maintain client funds in a trust account, as well as one count involving moral turpitude: making a material misrepresentation to a court.

In one matter, Sanders was retained to draft and file probate papers in an intestate estate. The surviving heirs were two sisters--one of whom resided in a mental health institution. However, Sanders finalized a petition for letters of administration naming one sister as the sole heir, failing to investigate that there was an additional heir living in an institution; she relied on the information in an intake form prepared by a disbarred attorney she had hired as a paralegal. The estate property was sold to a strawman who was a friend of the sister named in the petition; he wrote a check to Sanders for $4,000, which she deposited without first securing court authorization as required.

In the other matter, Sanders made several deposits of client funds into her personal account rather than a client trust account as required.

In aggravation, Sanders committed multiple acts of wrongdoing that involved an individual who was vulnerable due to mental health disabilities, and lacked candor during the State Bar's investigation of the misconduct alleged.

In mitigation, she entered into a pretrial stipulation, had no record of discipline in nearly 15 years of practicing law, provided letters from 12 individuals from a variety of communities vouching for her good character, and submitted evidence of providing pro bono and low-cost legal services to community members.

Peter Kristofer Strojnik

State Bar #242728, Phoenix, Arizona (August 6, 2025)

Strojnik was suspended from the practice of law for 30 days and placed on probation for one year after he successfully completed the conditions imposed for participating in the State Bar Court's Alternative Discipline Program (ADP).

While the underlying disciplinary proceeding was in abatement, Strojnik sought the services of the Lawyer Assistance Program (LAP). When the abatement was terminated, he submitted evidence demonstrating a causal connection between his alcohol abuse and the charges pending against him.

Strojnik received the discipline recommendation in the instant case after successfully participating in both the LAP AND ADP.

He had filed stipulations in two underlying cases. In one, he admitted to failing to comply with several conditions imposed in an earlier public reproval order, including--failing to timely file four quarterly reports, failing to file proof of passing the final State bar Ethics School test or completing six hours of Minimum Continuing Legal Education, and failing to provide proof of passing the Multistate Professional Responsibility Exam.

In the other, he stipulated to failing to serve disability access complaints as statutorily required and failing to comply with mandated notification requirements.

In aggravation, Strojnik had a prior record of discipline, engaged in multiple acts of wrongdoing in the instant matter, and demonstrated indifference about the reality and consequences of his misconduct.

In mitigation, he entered into a pretrial stipulation, cooperated in the investigation of his wrongdoing, and took remedial steps to comply with the statutory provisions he had violated. His successful completion of the ADP was also deemed a mitigating circumstance.

Jennifer Lynn Wilson-Tancreto, Westwood

State Bar #275084 (August 29, 2025)

Wilson-Tancreto was suspended from practicing law for six months and placed on probation for two years. She had filed a stipulation admitting to being culpable of 34 acts of professional misconduct related to seven separate clients.

Her wrongdoing included: failing to release a client's papers and property after being requested to do so, as well as six counts each of failing to respond to reasonable client inquiries and failing to render appropriate accountings of client advanced fees, and seven counts each of failing to deposit client funds in a trust account, failing to promptly refund unearned advanced fees, and failing to cooperate in the State Bar's investigation of the misconduct alleged.

The fact patterns in all seven client cases were substantially similar: Wilson-Tancreto accepted advanced fees from clients in various types of cases--including real property rights, dissolution of marriage, and child support. She did not maintain an active client trust account, but deposited the funds received into her personal bank account. Thereafter, she failed to answer many client requests for information about their cases, and failed to respond to State Bar investigators' queries about the wrongdoing alleged.

In aggravation, Wilson-Tancreto committed multiple acts of wrongdoing.

In mitigation, she entered into a pretrial stipulation, had practiced law discipline-free for approximately 11 years, demonstrated candor and cooperation in an additional non-public pending investigation, and suffered from extreme physical and mental health issues during the time of the misconduct due to a brain tumor and alcohol dependency.

PROBATION

Noreen Anne Krall

State Bar #202373, Morgan Hill (August 29, 2025)

Krall was placed on probation for one year after she stipulated to entering a plea of no contest to driving with a blood alcohol content level of .08 percent or more (Cal. Veh. Code § 23152(b)), driving with a blood alcohol content level of .15 percent or more (Cal. Veh. Code § 23578), willful refusal to submit to chemical tests (Cal. Veh. Code §§ 23612 and 23157) with a prior DUI conviction (Cal. Veh. Code § 23152(b)), and contempt of court for willfully disobeying a court order (Cal. Penal Code § 166(a)(4).

It was Krall's fourth conviction for driving under the influence of alcohol--two previous in California, one in New York.

In the present matter, Krall drove a car on a suspended license while she was under the influence of alcohol. She had consumed alcoholic beverages at a party, then collided with an object near the road and stopped her car--blocking traffic behind her. She failed to complete field sobriety tests and refused to provide a breath sample to investigating officers at the scene. She also refused to provide a blood sample; a sample taken after a warrant was obtained revealed a blood alcohol concentration of .229 percent.

The State Bar Court determined that the facts and circumstances surrounding the present incident did not involve moral turpitude.

In aggravation, Krall committed multiple acts of wrongdoing.

In mitigation, she entered into a pretrial stipulation and had practiced law discipline-free for approximately 13 years prior to her first DUI conviction.

Rodney Alan Malpert

State Bar #133812, Texas (August 8, 2925)

Malpert was placed on probation for one year after he stipulated to earlier pleading no contest to one count each of assault (Cal. Penal Code § 240) and disturbing the peace (Cal. Penal Code § 415).

Both offenses are misdemeanors, and the State Bar Court determined that the facts and circumstances surrounding the offenses in the case did not involve moral turpitude.

Relevant underlying facts: Malpert and his wife engaged in arguing--both at a restaurant while out to dinner and later at home, where he then pushed and choked her. Their young child witnessed the assault. Malpert's wife then secured an emergency protective restraining order against him, and he then checked himself into the psychiatric ward at a hospital.

In mitigation, Malpert entered into a pretrial stipulation in the case, had practiced law for approximately 29 years without a record of discipline, and was given limited weight for character references letters from six individuals--known of whom demonstrated that they knew the full extent of his misconduct, nor did they address any disciplinary concerns.

--Barbara Kate Repa