In the Matter of: KENNETH KARL DITKOWSKY, Attorney-Respondent, No. 642754.

Commission No. 2012PR00014 FILED - March 9, 2012 COMPLAINT Jerome Larkin, Administrator of the Attorney Registration and Disciplinary Commission, by his attorney, Lea S. Black, pursuant to Supreme Court Rule 753(b), complains of Respondent, Kenneth Ditkowsky, who was licensed to practice law in the State of Illinois on November 28, 1961, and alleges that Respondent has engaged in the following conduct which tends to defeat the administration of justice or to bring the courts or the legal profession into disrepute and which should subject him to discipline pursuant to Supreme Court Rule 770: ***Response*** Okay, typically you do not do a response to a preamble, BUT... “Defeating the administration of justice.” Perhaps KD is in the process of defeating the administration of lucrative evil payments to CT, but KD has never defeated the administration of pure justice. He is only interfering with the bizarre, twisted, evil form of “justice” that only involves lucrative benefits to the tortfeasors/miscreants as further detailed below. “Bring the courts or the legal profession into disrepute” is the furthest thing from the truth. KD is attacking an entire evil cabal that has ripped a 90 year old woman from her home, her family, her friends, then dumped her into 40 hour per week “adult day care” staring at walls and people who are low level functioning. If you think she is incompetent, then see the videos on YouTube, Facebook. Everyone else apparently has seen the videos, now they have seen several dozen detailed blog postings on the case, and over a hundred people are wondering–what is going on here? It is interesting that this complaint does not mention those videos (other than to say that Gloria should have produced them, which is preposterous, she has no duty to do that sua sponte), in which: 1) Mary is writing for help in her own hand, only asking for the spelling of a few

complicated words–how to get help, how to get home to her favored daughter Gloria, to have Gloria care for her as she did for 11 years; 2) telling the world how she wants her will and last disbursement of assets to her daughters clearly in equal proportions–a situation which Carolyn, attempted to defeat by having some bogus trust document prepared which purports to leave her home only to Carolyn or her daughter Kristen, if Carolyn predeceases Mary G; 3) Mary G at her 90th birthday party clearly and intelligently interacting with friends and family; 4) Mary bowling and interacting appropriately and intelligently with others at a bowling alley. Another thing CF did not mention in this complaint is how she was already once overturned on appeal for improperly declaring someone incompetent, when they were not. This “Complaint” is replete with half truths, outright lies, misinformation, hidden facts and misleading statements – clearly as if it were written by the GAL’s Cynthia Farenga (“CF”), Adam Stern (“AS”), together with input from CT’s attorneys Harvey Waller, Peter Schmeidel (“PS”)–(collectively hereinafter sometimes “miscreants”) and handed to Ms. Lea and she posted it up on the website like a good puppy waiting for a tasty Bacos treat. There is more to this story, and the reader has to pay close attention and read on.... (Okay, and also don’t laugh too loud). COUNT I (False statement to a third person in relation to Mary Sykes) 1. In or about 2000, Respondent prepared estate planning documents for Mary Sykes ("Sykes"). Respondent revised those estate planning documents for Sykes in 2002 and in 2003. Both wills devised Sykes’ personal effects and other items of household goods and furnishings to her daughters, Carolyn Toerpe ("Toerpe") and Gloria Sykes ("Gloria"). At all times alleged in this complaint, Respondent had not had contact with Sykes since 2004. ***Response*** Prior to 2004, Respondent had been the long time family counsel for Mary G. Sykes (Mary G) and her husband Charles, and Respondent was well acquainted with this couple, their legal needs and their finances and family history. If Atty Ditkowsky (“KD”) is talking about gold coins missing, there is no doubt in my mind he knows of what he speaks–without betraying prior atty client privileges. Moreover the gold coins, Mary G and Charles stuffing cash into mattresses, is well known legend in the family and both Charles and his nephew, Mr. Biddy, now deceased, collected gold coins for decades. Numerous family members have seen them an will attest to this. (And actually, if you know any older families in bungalows that drive a new car every year, you should be aware that for a long period of time, the ownership of gold coins was banned in the US. So what these old cagey men and women would do is drive to Canada, buy the gold coins, bring them home and then watch them appreciate–well beyond inflation. Check out the WSJ and other news sources for long term gold prices. They outstrip the stock market. Border patrols NEVER inspected cars and NEVER looked for gold coins in locked compartments. Check the internet for stories).

With respect to the wills, this is not entirely true. At some point, Carolyn got ahold of her mother and got her to sign a “trust agreement” wherein it is clear that when Mary dies, Carolyn will receive the home located at 6016 N. Avondale in Chicago. (Para VI(B)) It is ONLY if the house must be sold, that the daughters divide the proceeds 50/50. I will post the entire trust document soon as I can find a place to do so. If the GAL’s told the ARDC that Carolyn took her mother to an attorney to get a trust/estate document or whatever that the daughters would split the estate 50/50, that is an outright lie. Carolyn did what she did to get the entire house and cut Gloria out. The only problem is, when the house is sold Carolyn only gets 50%. I know for a fact that Carolyn does not believe this and she thinks that when the house is sold, it goes into the trust and she will get it all–because she does not understand how a trust works. In fact, the entire family has told me that they think Carolyn get it all only if the house is sold and that’s why she’s doing what she is doing. I believe what Carolyn is thinking is that when the funds are put into the trust and she is the trustee, then she can do what she wants with the funds or they might “disappear”, like the gold coins. But if you went to law school and paid attention to your Estate and Wills class, this is NOT true. No one in the family believes me. I have had long discussions with them about this, very long discussions, and to no avail.) CT is actually shooting herself in the foot by having the house sold. She thinks the money goes to a separate trust she gets to keep, but to the contrary, it goes in the remainder trust where it is distributed 50/50 upon the death of the trustor. Because I am also a close family friend, I am not much believed. They all remember me as the lady with 4 kids and who fosters cats and dogs–I’m not sure they think of me (including Gloria) as a real lawyer KD has also pointed out, and the Probate Court and CT hate this one, but the Mary G Trust violates the Statue of Uses wherein the trustor and beneficiary cannot be the same person. No one seems to get that either. But there are Illinois cases uploading those centuries old trust law concepts. Carolyn definitely does NOT know that if you hold a power of attorney or are the Trustee, you have to account for every dime and prepare an accounting and you are liable for any shortages.

2. On July 20, 2009, Toerpe filed a petition in the Circuit Court of Cook County to have Sykes adjudicated a disabled person due to concerns that Sykes’ suffered from dementia. Toerpe’s petition also sought Toerpe’s appointment as the guardian of Sykes’ estate and person. The Circuit Court Clerk docketed the matter as Estate of Mary Sykes, docket number 2009 P 4585. ***Response*** Carolyn Toerpe for years had been estranged to many family members and her relationship with her mother and her sister was tenuous at best. Gloria was invited by both her mother to move back to Chicago in 2000 (father Charles recently died) and that she would “buy her” a home on the back lot. Gloria put down a down payment, bought the house, put her mother’s name on the property as a testamentary convenience, and began to care for her mother while engaging in her profession of being a journalist. She wrote a book. It’s in fact a very good book, but has not sold well because, IMO, the internet is now packed with all sorts of good books, courtesy of

epublishing. Gloria did the brunt of the work in shopping, entertaining and caring for her mother, who was active, but getting on in years. Still, Mary knew what she wanted and when she wanted it and clearly expressed her love and personal favoritism for Gloria because **Gloria was there for her every day. Gloria took care of the bills, paid the mortgages, told her mom not to worry, took her mom 90% of where Gloria went and took her on great vacations, bought her beautiful designer clothes, took her to the beauty parlor several times per month–which she loved. Mary G and Gloria both eat vegetarian, and Gloria had special vegetarian foods prepared for herself and Mary G once per week and delivered to the home, made specially by Amibutol, a local gourmet vegetarian restaurant.** What did Carolyn do? Bitched and complained when she had to “take mom” for a weekend two or three times per year to give Gloria rest. While Mary wanted both daughters to lovingly care for her, what she wanted most was to live in her home until she passed and she wanted Gloria to take care of her, as she had done in the past. (Actually, with regard to paying the bills, Mary G would ask Gloria what bills had to be paid and Mary G would often insist on writing checks. In fact, Mary G was writing checks for bills right up until Carolyn ripped her out of her home and told her she could no longer do that. Gloria was fine with it because it made her mom happy. Because Carolyn had started sending Mary G’s bank statements to Carolyn’s home–a situation Mary did not like but she knew Carolyn insisted, Mary G would simply walk a short distance to the bank several times per week to check on her accounts. That is exactly how Mary G found out about the missing $4,000 and called up an atty (probably KD, tho it might have been the Center for Caring in Park Ridge) and was told to get a Protective Order against such nonsense. Carolyn became furious when she received a copy of the Petition, and she counter petitioned for Guardianship. 3. On or about July 24 2009, the court appointed Cynthia Farenga ("Farenga") as Sykes’ guardian ad litem. On August 26, 2009, because Farenga was unable to attend court, the court appointed Adam Stern ("Stern") special guardian ad litem, and both Farenga and Stern served as guardians ad litem for Sykes at all times alleged in this complaint. ***Response*** After Atty. Farenga (CF) returned from her vacation in August 2009, Atty Stern (AS) should have been dismissed. The appointment of 2 GAL’s is highly atypical and a strain on any estate and family. The question is, why were there 2 GAL’s. I believe at one point one of the GAL’s quipped to me “to protect the Estate from Gloria”, as some sort of obnoxious joke. And isn’t that a brilliant idea? Appoint someone as a guardian who is estranged from most of the family, estranged from all of Mary G’s family and friends, lives in a remote suburb with nothing but broad lawns and narrow minds? (Hemmingway said this about Oak Park, btw, not me). Yes, brilliant. 4. On November 3, 2009, Gloria filed a cross-petition in case number 2009 P 4585, nominating the Cook County Public Guardian to serve as Sykes’ guardian. Shortly thereafter, Gloria orally sought to be appointed the guardian of Sykes’ estate and person without amending her written

cross-petition. ***Response*** That is not entirely true. I went back to the office with Atty Jay Dolgin on the day of the hearing on Gloria’s health care plan and by the time court was back in order for more of the hearing on the health care plan, Atty Dolgin presented to the court a revised Petition for Guardianship where Gloria would become her mother’s Plenary Guardian. I know he filed it and presented it to the court. If it is missing from the file, I am not surprised. I have a copy of the document he filed and presented to the court. While it is not file stamped, I believe he handed it to the clerk and she stamped it and filed it. The judge obviously accepted it because the hearing proceeded. More important is prior to this, Mary G, who liked to frequent the neighborhood bank one block away, and who checked on her accounts there perhaps several times per week, discovered that $4,000 was missing in July, 2009. Mary G immediately went to court, and with the assistance of one of the paralegals (and not Gloria), swore out a complaint for a Protective Order–a Complaint that STILL has not been heard by the Probate Court. More importantly Illinois Law expressly prohibits the Respondent to a Petition for a Protective Order as serving as Guardian. Carolyn was not and still is not eligible to serve as Guardian of anyone. Carolyn’s excuse was she moved the money to set up a retirement account for her mother–a preposterous alibi because at age 90, Mary G is clearly unable to qualify for a retirement account. No investigation of where that money went has been done so far, despite repeated requests by KD, myself and family and friends of Mary G to have that money tracked. In fact at one point, I specifically requested this in an email to AS. Because the Probate court early on denied Atty Dolgin’s several requests for discovery prior to appointing CT, no bank records of these transactions have ever been produced–though they should have been. There is one court order on Dec 7, 2010 that says that Atty Dolgin’s subpoenas are dismissed by the court. 5. On December 10, 2009, the court adjudicated Sykes disabled based upon the report of Dr. Mark Amdur that Sykes was incompetent, and the court appointed Toerpe the plenary guardian of Sykes’ estate and person after a contested hearing on the care plans proposed by Toerpe and Gloria. On December 18, 2009, Gloria filed a motion to reconsider the December 10, 2009 order appointing Toerpe as Sykes’ plenary guardian. ***Response*** Another question to ask about is the report of Dr. Rabin, who signed off on a report on 6/30/09 but did not see Mary, instead only a PsychD saw her and then Rabin signed off on the report. This is contrary to 755 ILCS 5/11a-9 which requires a licensed physician participate in the evaluation and sign the report. A better question to ask is, how the heck did the court use the report of Dr. Amdur, when in fact Mary suffered from a number of easily rectifiable medical conditions that might have affected her testing. It should also be noted that reports were prepared on Mary G without analyzing her blood sugar

levels, a complete CBC and physical beforehand–including use of her hearing aids. Mary loved to fiddle with her hearing aids. I think it was a nervous habit. It drove Gloria nutz because she bought the fancy ones for her mother and her mom would lose them–at $1,000 a pop, but Gloria did this because she wanted the best for her mother. No where in Dr. Amdur’s report is there a CBC noting if she had any medical conditions that would temporarily impair mental functioning. Blood sugar levels are crucial. High blood pressure is also crucial and is linked to eating sugar and carbs. If you want to have someone declared incompetent, dump a load of sugar in them right before a test. Sugars immobilize activity in the brain for 15 to 45 hours minimum after ingestion. At times, Mary did have low blood sugar or hypoglycemia–another condition affecting mental abilities. Mary was also taking blood pressure medication. But with proper medication (only for Hptsn) diet, and nutrition (for the BSL), these temporary problems can be corrected. The GAL’s were advised of these health issues and deficiencies in any medical competency report filed in pleadings filed by Gloria and prepared by myself, but did nothing about it. No report, no investigation. They turned a blind eye to look at this. I was there during this hearing and it was clearly “wired”, “fixed”, “predetermined” or whatever you want to call it. Atty Jay Dolgin is a witness. Atty Dolgin told me the exact same thing on the way out of the courtroom. After the GAL’s disqualified my appearance–for notarizing a document and nothing further, the court then proceeded to trash Gloria’s “home care plan” whereas prior to this they helped Carolyn with her home care plan. Typically, prior to any trial or hearing, any party asking for discovery gets it. Atty Dolgrin, in open court asked Judge Connors for discovery and she responded with a snotty “why would you need that?” or something of the equivalent. In his great bravado, Atty Dolgrin responded, well I need to depose CT and ask her questions regarding a number of issues. The court immediately shut that down. What is even somewhat funny during Gloria’s testimony, the court shot her down because she did not recall the complex name and exact dosage for her mom’s only meds–a high blood pressure med, but Gloria, unlike Carolyn, could detail Mary G’s doctors, her medical history, etc. Here’s what’s funny. Eventually the court and Gloria got into a fight over her CBC and it was clear the judge did not know what that is or why it is important, but she used Gloria’s lack of knowledge of one med and one dose to disqualify her! A CBC is a basic medical test everyone should know about. It stands for “Complete Blood Count” (although what that is has changed over the years with more sophisticated testing equipment), and it measures blood chemistry as indicated below–from Wikipedia under CBC: A complete blood count (CBC), also known as full blood count (FBC) or full blood exam (FBE) or blood panel, is a test panel requested by a doctor or other medical professional that gives information about the cells in a patient's blood. A scientist or lab technician performs the requested testing and provides the requesting medical professional with the results of the CBC. Alexander Vastem is widely regarded as being the first person to use the complete blood count for clinical purposes.[citation needed] Reference ranges used today stem from his clinical trials in the early 1960s.

The cells that circulate in the bloodstream are generally divided into three types: white blood cells (leukocytes), red blood cells (erythrocytes), and platelets (thrombocytes). Abnormally high or low counts may indicate the presence of many forms of disease, and hence blood counts are amongst the most commonly performed blood tests in medicine, as they can provide an overview of a patient's general health status. A CBC is routinely performed during annual physical examinations in some jurisdictions. A CBC should have been done, including essential (and correctible) blood levels such as Vitmain D3 (a nutrient essential to every cell), Vitmain C (same), as well as the traditional iron, magnesium, chromium, etc. Her blood pressure should have been taken before and after the test, and the test should not have been administered if her blood pressure was over 140/85. Blood pressure is easily correctable. Her blood sugar level should have been in a relatively normal range of 80 to 120 and the test should have been administered after a healthy, low carb meal. In fact, dementia and autism have been reversed via diet and supplements and all of this should have been considered before declaring Mary incompetent. Salmon oil, krill oil, astaxanthin, Vitamins C and D3, MSM sulfur are all esstential to preventing and reversing dementia. In a survey of 500 older Americans ages 50 to 70, those with the highest levels of vitamin C, 98% were free of heart disease, dementia and cancer. (Some people can still make vitamin c, most cannont, read the book “the real story of vitamin c” by hinkley, available on Kindle for PD–free software–in seconds) None of this was done, but the GAL’s have been long advised that proper medical testing and normalization of CBC levels, BSL levels and blood pressure are crucial to any testing. Also diet. Everyone knows how people act badly–esp. children, after being loaded up with sugar or sugary or high carb foods.

6. Between December 2009 and April 2010, Respondent was contacted by Gloria and other friends and family of Sykes regarding Sykes’ estate and Gloria’s desire to be appointed Sykes’ guardian. Respondent agreed to represent Gloria and other friends and family of Sykes in matters relating to Sykes’ estate. ***Response*** Gloria, as far as I am aware, has never actively set out to be appointed Mary G’s guardian. She believes her mother knows where to live (her own home) and what she wants (for Gloria to live upstairs and care for her at home until she passes). The videos on FaceBook and Youtube speak volumes to this. Upon viewing all these videos, I believe the Guardianship, and for other reasons, primarily the lack of Soldini notices, should be dismissed entirely unless and until it appears that Mary does not know where she wants to live and that she no longer wants Gloria to care for her. Those are her directives at ANY point in time, and they appear to be entirely reasonable. It is entirely proper for her to direct anything else to a responsible, caring family member. Because she can no longer do these duties herself, as long as she dictates them properly to someone else, there is no need for a guardian. And there IS no litmus test for guardianship or

incomeptency. 7. On or about April 22, 2010, Respondent or someone at his direction sent a letter to Dr. Pramod Patel, Sykes’ treating physician. The letter, which sought information from Dr. Patel about his medical evaluation of Sykes, began by stating that Respondent represented "the interests of Mary Sykes." Respondent enclosed with the letter a document he created and signed that purported to be an appearance form relating to case number 2009 P 4585. The purported appearance form bore the caption "Estate of Mary Sykes" and the case number 2009 P 4585, and it stated: "The undersigned does hereby enter the additional appearance of Mary Sykes (sic) in the above-captioned and numbered case." Below the signature line, where Respondent listed his address and telephone number, Respondent identified himself as "Attorney for Mary G. Sykes." ***Response*** This form should be an Exhibit to the complaint. I’m not too sure how important this is regardless. An appearance form means nothing. Any competent doctor would know that he has to obtain written consent of the person themselves in order to disseminate any information to third parties. An appearance form and a naked request is not enough. Moreover, KD was likely responding to a request from Gloria to obtain the information, and most likely Gloria was listed on her mother’s forms as being a person to release medical information to. In addition, Gloria holds the last Medical Power of Attorney Form for her mother and KD knew that. Exhibit B, hereto. Regardless, KD was clearly trying to help Mary G, stop the isolation and the relentless persecution of Gloria by the GAL’s who had always favored Carolyn and treated Gloria with disdain. And in response to what KD did, is it better that the GAL’s present to the court a scathing competency review from Dr. Amdur–a doctor that had not seen Mary G at all, esp. in light of the videos posted on the internet showing Mary clearly knowing what she wants and where to live and whom to care for her? I think not. 8. At no time was Respondent representing Sykes, and at no time was he appointed to represent Sykes, and at no time had Respondent filed the purported appearance form in case number 2009 P 4585. ***Response*** It is my firm believe that had Mary G. known that KD was trying to help her, she would have readily agreed to his assistance. KD has not been able to have access to Mary G. at all. And with the current state of the Cook County Probate court, she will not be given that chance anytime soon–although she knows it and wants it. When I asked Gloria how she found KD, she told me the following story. During a visit some time ago, when Gloria had access to her mother, her mother said, you need to get me a lawyer–get me Ken Ditkowsky. It was said very fast because Carolyn was watching the two, and at first Gloria did not understand what the name was, but she searched and searched and phonetically figured out the name and realized who he was–their old family attorney. Then she thought, OMG, this guy must be so old or passed on, but she found

KD and told him the situation and KD has been working ever since to protect his old client. Obviously Mary G was a client that KD deeply cared about and had a great amount or respect for. His dedication to clients is nothing but outstanding and commendable. 9. Respondent also sent the letter and attachments described in paragraph seven, above, to Sykes, Stern, Farenga, Gloria, and Peter Schmiedel (the attorney for Toerpe) ("Schmiedel"). *** Response ***. See paragraph above. 10. Respondent’s statements in his letter to Dr. Patel that he represented Sykes, as described in paragraph seven, above, and his attachment of an unfiled appearance on Sykes’ behalf, were false and misleading, and Respondent knew that they were false and misleading because at no time before sending the letter and attachments described in paragraph seven above, did Respondent speak to Sykes about representing her in relation to case number 2009 P 4585, Sykes had not communicated with Respondent nor authorized him to send the letter to Dr. Patel, and at no time prior to sending the letter and attachments described in paragraph seven, above, did Respondent seek or obtain leave of the court to file an appearance on behalf of Sykes. ***Response*** See above. Gloria held the last Power of Attorney form for her mother, she likely was listed on her mother’s medical information form as being allowed to obtain information, and KD was at all times working with Gloria’s permission. At the time, KD was clearly seeking a method to help Mary G. And it is not entirely clear that Mary G had never hired KD. If what Gloria says is true–that Mary G told her to contact KD to represent her and get her home–then KD ***was*** in fact hired by Mary G and he was properly acting on her behalf. 11. Respondent’s letter to Dr. Patel and his attachment of a purported appearance on behalf of Sykes were intended to mislead Dr. Patel that Respondent represented Sykes, and were designed to get Dr. Patel to release information to Respondent regarding Sykes’ medical and mental health condition in order for Respondent to assist Gloria in her desire to be appointed plenary guardian over Sykes. ***Response*** Correction, by this time CT had already been appointed. The only thing KD was to try to represent Gloria and/or her mother to get Carolyn removed–and based upon his knowledge of the Protective Order Petition, the isolation of Mary and missing unaccounted for funds, it was well deserved. Since Gloria has never subsequently filed a Petition to become her mother’s guardian since Dec. of 2009, this paragraph is pure speculation. KD simply wanted a dangerous guardian removed. He knew his former client well, he knew that Gloria cared for Mary G for 11 years and helped support her, and he was well aware of the situation. It is interesting that the petition alleges that he was “hired” by the friends and family of Mary G to help her, but it neglects to realize if so many people requested this help, then it seems there was a whole lot of due

diligence–many stories and much information provided, before KD actually began to act. 12. By reason of the conduct described above, Respondent has engaged in the following misconduct: a. making a false statement of material fact of law to a third person, in violation of Rule 4.1(a) of the Illinois Rules of Professional Conduct; b. conduct involving dishonesty, fraud, deceit, or misrepresentation, in violation of Rule 8.4(c) of the Illinois Rules of Professional Conduct; c. conduct that is prejudicial to the administration of justice, in violation of Rule 8.4(d) of the Illinois Rules of Professional Conduct; and d. conduct which tends to defeat the administration of justice or to bring the courts or the legal profession into disrepute. ***Response*** Nothing could be further from the truth. KD was fulfilling his obligations as a lawyer and officer of the court to make the court aware of serious issues involved in the initial appointment and then subsequent continuing engagement of CT as Plenary Guardian–issues presented in great detail below.) The ARDC, CF, AS and PS should all be required to apologize to both KD and Mary G for each of their outrageous behaviors in this case. COUNT II (False Statements about judicial officials) 13. The Administrator realleges paragraphs one through 11 of count I, above. ***Response*** Does that really do any good? To repeat such one sided idiotic trash? Did CF and AS just hand this “complaint” to the ARDC and say “publish this–we have clout”? It sure looks like it. 14. In or about 2010, Gloria contacted Respondent regarding the court’s appointment of Toerpe as Sykes’ guardian. After being contacted by Gloria, Respondent began a campaign of sending emails to various family members and friends of Sykes, the guardians ad litem (Stern and Farenga) ("the GALs"), and various law enforcement agencies, in which Respondent made allegations that Sykes was the victim of elder abuse, and that the GALs and the court had acted inappropriately with respect to Sykes’ estate, that they had violated the law, and had physically or mentally harmed Sykes. Respondent sent emails on almost a daily basis from April 2010 through the date the Administrator referred an investigation of Respondent’s conduct to the Inquiry Board.

***Response*** Calls for an investigation are a constitutional right. An attorney does not leave his constitutional rights at the door step upon taking the oath of officer; rather, these constitutional rights become more important than ever after an attorney takes the oath of office and every attorney should take the type of proactive initiative that KD has taken in this case–all without interest and all without pay. He is to be commended and not scorned as certain miscreants would have this–and it is these miscreants who have benefitted, to the tune of thousands of dollars at minimum–to perhaps sharing in a cache of hidden gold coins and cash on the premises that CT secreted away, but the family knew about. At the very least their ability to churn legal bills they hope will be paid is sufficient motive to engage in scandalous and outrageous behavior. 15. The e-mails referred to in paragraph 14, above, include, but are not limited to: a. An October 10, 2010 e-mail to Gloria and other friends and family of Sykes, wherein Respondent accused the court of impropriety and accused the GALs of criminal conduct after the judge adjudicated Sykes incompetent based upon an evaluation by a doctor obtained by Gloria by stating: Your personal rights have been violated by the Court acting against its own rules and by the judge directing doctor shopping… ***Response*** Isn’t it true if you’re having a doctor make an evaluation, if the doctor is not independently selected, and moreover this doctor never even saw Mary G but wrote up a report, that is likely “doctor shopping?” And if the court banned Gloria and her attorneys from seeking discovery on Dr. Amdur, isn’t that likely because he is a hired gun and takes whatever position the person hiring him wants to find? Why haven’t the GAL’s investigated this and asked Dr Amdur why he never saw Mary, why Dr. Patel refused to say she was incompetent, and just how many times has he acted as a hired gun rather than a professional that produces opinions independent of the entity hiring him? No one has asked or answered those questions–yet. But CF and AS should have. It was pointed out to them in pleadings and in person.

**** End Response**** however, when a Judge knowing she has not (sic) jurisdiction issues orders that under color of statue deprive a citizen of his/her civil rights there are civil and criminal penalties… [the failure of the Court to investigate ‘doctor shopping (see August 31 transcript)

including Judge Connors counseling on the subject, the application for protective order etc is also not protected… This is also the reason that we contacted and will continue to contact Federal officials who have jurisdiction to address the criminal conduct that is polluting the Probate Division of the Circuit Court. In my opinion Stern and Feranga (sic) are at the very least accessories to criminal conduct. ***Response*** The GAL’s in probate are supposed to investigate allegations of fraud and crime. In this instance, they have turned a blind eye. While numerous family members repeatedly stated there were numerous gold coins and cash, the GAL’s have not investigated. They have not asked for discovery of CT’s finances, her bank records, investigated the remodeling of her home or purchases therein. KD is right to ask the GAL’s to simply do their job. The Probate Court summarily denied discovery on CT (Atty Dolgin is witness to this and there is a Dec 7, 2009 order striking Atty Dolgin’s subpoenas), and the GAL’s continue to ignore these issues. It is further important to note that there is no inventory or accounting to be found in the court’s files when I reviewed it back in January of 2012. Nothing, nada. Oh, there were orders to file an inventory, BUT nothing is actually in the file. Now, why is that? It is also interesting to note that many documents are missing from the Probate court file– Documents I filed, documents Gloria says she filed. While the Circuit Court of Cook County should have been on electronic filing years ago, attorneys and the public still play with the files. When you go to Probate court, the personnel hint there this is Gloria’s fault, but I point out to them that items such as Inventories, letters and petitions which help Gloria’s cause are the items that are missing. I have contacted the efiling division and begged them to expedite this case to electronic filing for the entire probate file due to the mess the file is in, the missing documents, but never heard further from them other than they would look into it. I already advised them that the situation was serious. ***End Response****

b. A February 11, 2011 e-mail to the GALs, Naperville Police, Illinois State Police, Schmiedel, and friends and family of Sykes, stating: Re: Mother isolated again After reading and doing my own investigation I’ve come to the understanding that the Mary Sykes case is a posterboard (sic) Elder Abuse and Financial Exploitation case in the worst traditions of the legal profession. Yesterday in an e-mail Mr. Stern admitted that even though the order appointing a plenary guardian referred to a hearing – THERE WAS NO

HEARING. What there was (sic) an agreement between the two GALs and the plenary guardian accepted by the Court that Mary Sykes was incompetent and that the very person who Mary filed a verified petition for an order of protection should be appointed plenary guardian. ***Response*** none required. No wrongful actions are alleged. c. An April 9, 2011 email through the contact page on the website for the National Committee for the Prevention of Elder Abuse, stating: This situation appears to be a scandal greater than Greylord! Yet because of politics et al – the financial exploitation is protected. It has been alleged that no (sic) only do the abusers profit, but so do the GALs but also the judges. ***Response*** none required. No wrongful actions are alleged. d. A May 11, 2011 email to the GALs and friends and family of Sykes, stating: Re: gloria (sic) on TV Time is short! It is getting shorter! Fish or cut bait. As gold is over $1500 an ounce, the gold coins are worth about $3000 each. That means there is almost a million in coins! That would make the theft a Class 1 felony! Aiding and Abetting is also a criminal act. A GAL is the eyes and ears of the Court – that fact creates a duty. ***Response**** See above. If anyone should know about these gold coins and cash, it is certainly KD. e. A June 7, 2011 email to the GALs and friends and family of Sykes, stating: Re: Significant fact that appears to have been suppressed As you are aware, the NASGA people, Gloria Sykes and the friends and family have been complaining bitterly that there is something inappropriate with the appointment of the very person who Mary Sykes filed a complaint for a protective order against as her plenary guardian. [T]he fact that this appointment was done by the Court entering an order upon the agreement of the proposed plenary guardian, and the two guardian (sic) ad litem suggest (sic) impropriety! The fact that even serious neglect admitted by the plenary guardian is defended by the GAL is highly suspicious. ***Response*** As far as I am aware, this is true. Dozens of friends and family members have complained about the behavior of Carolyn directly and indirectly to me. Over 100 people have signed my petition

to get Mary G home. Go and search on www.thepetitionsite.com for “Mary G Sykes”. Everyone thinks this is a true travesty and complete miscarriage of justice. The miscreants have no petition, they have no blog. They know what they are doing, and they only do something if it involves green as the ultimate reward. People who signed that petition, and now a new one for KD do it because they care and are altruistic–something the miscreants despise. However, it is energy they feed on–the goodness of others. f. A January 12, 2012 email to the GALs and friends and family of Sykes as a result of YouTube videos of Sykes posted by Gloria and never produced in court or to the GALs, stating: Re: Financial statement(s)/inventory due on the 10th of January 2012 With the videos now on the internet, they cannot be altered or surpressed (sic). They stand today as stark evidence that in August/Oct/Nov 2009 Mary Sykes was totally competent and the agreement referred to by Mr. Stern in his e-mail to you which was turned into a court order by the presiding Judge Connor was wrong and inappropriately and miscreantly (sic) took away your mother’s civil rights. ***Response*** The videos clearly show a competent person who knows what she wants and where she should live and who should take care of her. As long as Mary G’s requests in this regard are reasonable–and they clearly are–she should not be declared incompetent or isolated, kidnaped, secreted away from her friends, family, home and neighborhood that were her surroundings since the 1950's. And what’s with the allegation the videos were “never produced in court?” As soon as Gloria got a chance in the FED court, right away she popped open her laptop and ran them for Judge Garber and he was appalled–and at first he started helping and ruling for Gloria, until a few court hearings later when it became clear he was “not supposed” to do that, then all the help suddenly vanished. But Gloria got in a few good orders first. Did the GAL’s serve any discovery on Gloria for those videos? Did they ever ask to see them? No. Most of the time they treated Gloria with disdain and scorn and would not talk to her or go near her. During Gloria’s care plan hearing, all Judge Connors did was make faces while Gloria was testifying. Now granted, Gloria was furious at them for what they did, yet why do the GAL’s complain the videos were not produced in court when there was no obligation on Gloria’s part to do so? Gloria had long ago given up on the Probate court and her expertise is media–so she just put them up on the internet, where they now reside, at a plurality of websites, because apparently someone writes emails and flags them to get them down–despite the fact the comments on the blogs are people that like the videos and wonder about the sad state of the 18th floor of the Daley center. All good questions. In fact, several times when I and Gloria offered to show the court important evidence on a cell phone or laptop, the court said it had to be in writing or the Probate court would not consider it. Did you know that in the care plan that Carolyn prepared, Fred Toerpe was to take care of Mary

G during the day, and when he was not there, then granddaughter Kristin Toerpe was to care for Mary. That apparently did not go well. After a few months, Kristin moved out. Fred had no desire to care for mom-in-law, and then she got dumped into an adult day care facility in Naperville with other adults that were functioning on a very low level, and now she sits staring at the four walls or severely retarded adults during the day. Before this, she was able to speak on the phone to her sisters, her other relatives, her garden club friends and yak for an hour or two at a time! The worst part is this was done without any evaluation, without any court order (that I could find in the court’s file)–but worst of all, Gloria would have had her mom during the day and Gloria took her mom everywhere–even on lovely vacations! Mary has a home, she has Gloria to care for here. Why is she in Naperville, isolated, ripped from her familiar surroundings, and in an adult day care facility 40 hours a week. Who does this? Greed does. Evil and greed. g. A January 17, 2012 email to Sergeant Tom Krammer of the Naperville Police Department, stating: Re: How to pay off your congressman I suspect that the plenary guardian has dipped into Mary’s money and to keep the GALs happy has given them some cash. Of course the cash had to be shared with their clout. The clout is not going to return dime one, and thusly, doing the right thing would create a ‘cash flow problem.’ Someone is going to have to account and that means the million dollars in cash, Au coins, and jewelry will have be (sic) returned. The Tapes that you have been playing on your blog demonstrate that the determination that Mary was incompetent was pure fraud. Ergo, the Judge, the two guardian ad litem, and the plenary guardian committed old fashioned theft!... The guardians and their ‘clout’ had fool proof scam going with massive protection from the political elite. It was a perfect crime as every theft would be approved one way or another by a judge’s rubber stamp. I am not certain the Judges actually have (had) any idea of what they were ‘covering up!’ For instance, reading the transcripts and the statements made by Judge Connors, it is questionable if she knows any law whatsoever. ***Response*** I believe he is referring to the fact 1) the Probate court was reversed on the issue of sanctions; 2) the Probate court dispensed with procedure and denied Gloria discovery after repeated requests from her Atty Dolgin–even going so far as striking all of his subpoenas to bring witnesses to court for the hearing on the merits (how corrupt is that?); 3) the Probate court helped Carolyn with her care program and trashed Gloria’s on trivial grounds (read the transcript, I have it and will publish it on the internet); 4) the court was informed by PS that the sisters never received Soldini notices and the court said it was enough they were in court–despite the fact those notices contain important legal information and warnings and despite there is no case law that says that; 5) the court knows that Carolyn shut off Gloria’s gas for months and this is a violation of the CRLTO amounting to thousands of dollars in liability against the Estate of Mary G (“Estate”) and did not immediately remove her; 6) the court has stated that it does not need to comply with § 1401 regarding a judgment entered in another court–the Probate court said it could attack any

judgement at any time–which is not the law or the caselaw in Illinois; 7) the court was told but ignored the fact that CT was the Respondent in a Petition for a Protective Order and no hearing was ever noticed or set; 8) Gloria had filed numerous motions in Probate and was told after I was disqualified that her pro se motions could not be heard because “she had no attorney”–how bad is that?; 9) the Probate court now knows that the § 1401 two year limitations period has well passed to attack the Lumberman’s funds frozen in Indiana, but refuses to dissolve that injunction because it believes it “can attack any judgment at any time”, 10) the GAL’s and PS know better they must file a § 1401 motion to attack a judgment, and they let the two years pass creating a liability of $200,000 to the Estate based upon malpractice and CT should be removed for that reason alone and PS should be barred from representing any Estate in Illinois; 11) the Probate court took my laptop during one status call and refused to let me take notes–creating a § 1983 violation and abuse of process, –and so on and so on. *** End Response**** h. A February 16, 2012 email to the GALs, Schmiedel, the Cook County Sheriff’s Office, and the Illinois State Police, accusing a judge of violating another court’s automatic stay order, even though he knew that the automatic stay had been lifted, by stating: Re: Dissipation of the Mary Sykes Estate You reported to me that Judge Stuart appeared to just give lip service to Schmiedel's protestations and really did nothing negative. That has been the pattern. I was surprised that she violated the automatic stay - you (sic) home is part of the Bankruptcy proceeding and Mr. Schmiedel in seeking to partition it without a specific modification of the stay is contempt of Court. The contempt of court provides for the assessment of attorney fees. That might help you get an attorney. In my opinion Mr. Schmiedel took a very risky course of action! I do not know why he would do such a thing. ***Response**** KD is right again here. The BK code provides for an automatic stay in bankruptcy for all collection matters, and Gloria had no professionally prepared brief filed to prevent it. Apparently the attorney she had at the time, was just a hack, and never got a brief done other than a short numbered list of “denied, denied, denied”–which was clearly an insufficient pleading to counteract the request of PS to lift the stay in bankruptcy. That does not make it right or fair. Since that time, Gloria has been working Pro Se–and is constantly getting out lawyered–another situation that is patently unfair, and CF and AS have stood idly by watching Carolyn get ahold of mom, isolate her, evict Gloria, sell her home and of course the first step is adult day care, the next will be a nursing home where she will die. Wait and see. Even Atty Dolgin said that is where the case would be heading way back in Dec of 2009. He quit on Gloria, but made it clear to me he was disgusted with the entire situation in Probate, that no justice would be done, and he was too old to get involved or stay involved in such utter nonsense. The average elder put in a nursing home dies in 3 years. The average elder left in their own home with a caretaker or relatives lives 2.5 times that!

i. A February 16, 2012 email to the GALs and friends and family of Sykes, suggesting that he was going to pursue criminal action against Schmiedel by stating: Re: Sykes Gloria, check with the postal inspector – I understand that Schmiedel produced an envelope that missed a key element. If in fact he mailed it, he also intercepted it. The interception of mail is a federal crime. ***Response*** Interception of mail IS a federal crime and if PS did it, Gloria should report it. The better question is why are AS and CF willing to protect a criminal, and why is the ARDC their vehicle? This is not even to mention the fact that KD is NOT a prosecutor, so just how is he going to file a criminal complaint and “pursue criminal action”? All KD can do is advise the victim of a crime to promptly report it, and then if no action is taken, then to keep on reporting and make a stink until someone does their job. j. A February 17, 2012 email to Stern and Schmiedel, threatening criminal action and sanctions alleging that two of Sykes’ sisters did not have notice of a the petitions for guardianship filed by Toerpe and Gloria when they were present in court, by stating: Re: Safe harbor note No matter how this matter is sliced and diced it is clear that without the Sodini notices having been appropriately served, there is no jurisdiction for the probate court to do anything, and when this matter is examined by law enforcement it will be examined by the clear light of hindsight. The partition action against scheduled property is clearly improper and violates the automatic stay. All that said, the Federal Courts historically have not been very tolerant of 'gotta' type enforcement. Therefore, even though I am not representing Ms. Sykes I am suggesting to you (and Mr. Schmiedel) that if you do not unwind whatever action you have taken in connection with the illegal partition lawsuit by the close of business on Tuesday next, Ms. Sykes will seek a Court order from the United States Bankruptcy Court seeking to hold you in contempt and damages. (Monday is a holiday)… ****Response*** Since when has it been an ethical violation to inform a client or even a member of the public what elements constitute a crime and they should contact the authorities promptly? This is what attorneys are supposed to do! And it is improper to seek partition against property scheduled in a bankruptcy proceeding. It is quite risky business. Gloria was out lawyered, but it does not make it right or fair or ethical.

Also, the “safe harbor” language came from an email used in settlement of the differences between the parties. This is supposed to be kept confidential so parties may fully explore settlement (and heaven know that settlement of this case would benefit the time talents and abilities of at least 2 probate court judges, and about a dozen lawyers and dozens of interested family memnts). So why is this “safe harbor” language ending up in a complaint when CF and AS know they’re never, never, never supposed to do this. It’s just plain slimy and sleazy. ***End Response*** k. A February 17, 2012 email to Farenga, stating: Re: safe harbor I did not include you in the safe harbor letter that I sent to Stern and Schmiedel as I was informed that you were not in Court on Thursday and therefore was (sic) not part of the partition fiasco. If you were indeed part, I am certain that Stern will share my e mail with you. It should be taken seriously. The policy that has been demonstrated in the Sykes case has been naked intimidation. Gloria is the first target, and everyone else who was upset by the perfidy exhibited a secondary target. Even I was not immune. It has been part of the makeup of my generation of lawyers not to ambush adversaries, but, to give them every opportunity to do the right thing. It has been my experience that a better result is obtained if you give the miscreants an opportunity to back off! Thus, the safe harbor letter. ***Response*** No response is necessary. No improper actions have been alleged. l. A February 18, 2012 email to Farenga, the Cook County Sheriff, and the Illinois State Police, threatening criminal action against the GALs by stating: Re: safe harbor I sent you the safe harbor letter as a courtesy - you have every right to ignor (sic) it, and you have every right to have to deal with the consequences… The safe harbor letter gave you and your friends an opportunity to mitigate the damages that you caused and are causing. The letter and your responses are strong evidence that the miscreant actions were and are intentional. The abuse and financial exploitation of Mary Sykes is now of record as an intentional act on the part of court appointed individuals! The law enforcement people now have no excuse for not prosecuting the villians (sic) to the full extent of the law! ***Response****

That is a good question, why do law enforcement personnel turn a blind eye and give lip service to protecting the elderly, and in particular, Mary G? m. A February 18, 2012 email to Gloria, Farenga, Cook County Sheriff, Illinois State Police, and Naperville Police, threatening criminal action against the GALs by stating: Re: safe harbor 42 USC sec 1983 Spoilation (sic) of evidence is a cause of action - you should add it to your adversary complaints. ***Response*** This in particular is a good one, I never knew spoliation of evidence is a separate cause of action. I thought it was the subject matter for a Motion to Compel that the recipient of discovery did not turn over the document or thing but instead destroyed it. Again, providing a legal opinion from a lawyer is now somehow violates the rules for attorneys? I think not.

However, the ARDC alleges this is threatening criminal action, when in fact KD is talking about bringing a civil count for spoliation of evidence in an Adversary Proceeding–in bankruptcy. It is in bankruptcy court that Adversary Complaints are brought. Another duh. That’s what you get when you hire trained puppies and give them Beggin Strips for treats. ***End Response*** Mr. Schmiedel's statement to the Court that the Estate of Mary Sykes was down to fourthousand (sic) dollars is most disturbing. That means that about a million dollars in assets have been dissipated or have been divided. That explains why both GALs refuse to perform the simple tasks that were assigned to them… Generally, the appointment of a person as a guardian is not the granting of a license to steal! The commission of a felony is not part of the job description of a guardian. Buck vs Bell is not authority to perform 'retro active abortion' on a senior citizen. We will have to read the Obama care legislation, but I have doubts if congress authorized funds for the procedure. Gloria - I copied the Naperville Police Department on this and several other e-mails. I desire that they do some wellness checks to assure us that Mary Sykes has not been retroactively aborted! ***Response*** Okay, that was funny BUT see my comment elsewhere. The murder of a victim of financial exploitation is common where funds are finally depleted by the abuser.

***End Response** n. A February 21, 2012 email to friends and family of Sykes, stating: RE: Today’s hearing and yesterday’s visit They are no (sic) aware that the tide has turned and 1) they are going to be paying a humongous sum in income taxes and penalties, 2) they are going to face a bunch of lawsuits that their insurance does not cover, and 3) every dime that the (sic) stole must be returned. As they paid a referral fee to their clout they are going to have to make this up out of their own pockets. The question has to be asked: Why do they not just start persecuting Gloria and Mary? They are of the generation that does not make an analysis of a problem before addressing it. Farenga's impulse is to try to intimidate, PS to lie is (sic) way out, and Stern to slime his way out. This has worked for them in the past. The problem that they have is that Gloria is not going to let them out! She is going to make each of them famous. She will quote from the treasure trove of transcripts and e-mails that has garnered, and with a few pictures and a compelling narative (sic) every one of Farenga's words is going to echo in each of their ears for years after each goes to his/her final reward. In the Mary Sykes case the miscreants picked on the wrong people! Gloria's previous documentaries were very effective and well thought of. Her documentary on the Mary Sykes case will have special meaning and be very effective. It is very foolish not to take her seriously. Gloria's work product will be written and viewed through the filter of hindsight. I predict that ****** ***Response*** No allegation of improper behavior was made in this paragraph. I can only assume it was included for its entertainment value. o. A February 21, 2012 email to friends and family of Sykes, stating: Re: Today’s hearing and yesterday’s visit If the guardians/Judge/clout et al have skin in the game as we suspect that they do, they have a great deal to lose. Gloria's demeanor protects her! Judge Stuart will go to her grave regretting the day she put Gloria in 'chains!' We are far from done with that outrageous act. ***Response*** No allegation of improper behavior was made in this paragraph. I assume it was included for entertainment value. 16. Respondent’s emails, as set forth in paragraph 15, above, that there was impropriety going on in relation to the Sykes case; that the GALs, the judges, and/or law enforcement were engaging in

financial exploitation or had financially profited in some way in relation to Sykes’ guardianship case; that the judge had inappropriately taken away Sykes’ rights; and that Stern, Farenga, and the judge had committed theft were false. ***Response*** The statements are not false. The case was likely wired. Whether cash changed hands or not, no one will ever know. However, the result is the same. A railroaded Guardianship with no discovery and no Soldini notices. CT helped with her care plan while Gloria’s was dismissed for ridiculous petty reasons. A Dr. Amdur who filed a report in June 2009 but had not seen or met Mary G before that and there was no medical report before hand. A Dr. Patel who was Mary’s primary case physician for years and would not sign a letter of incompetency. A Dr. Rabin who saw Mary G on Halloween, when she was likely full of sugar and suffering from hypertension and dementia–again, no medical exam beforehand. A raft of close family friends and family (sisters) who would testify they knew of hundreds of gold coins, thousands of dollars hidden in the home–all gone. Two GAL’s–to protect one another’s backsides. CF and AS who have not obtained the bank records regarding the missing $4,000. A Petition for a Protective Order filed by Mary G that was never heard nor considered. The GAL’s filing a complaint now saying that Soldini notices were not required because the sisters were in court on the date of the hearing. What? Now Illinois law or some new case says these maybe waived? I think not. Don’t the sisters have the right to 14 days advance notice of the hearing? No Illinois case has ever declared that Soldini notices are not required. In fact, it is the opposite. A Soldini notice informs the recipient of important legal rights and how to terminate a guardianship, object to a guardianship, object to the appointment of a particular person–all important statutory rights other family members have. But these are statutory rights the Miscreants do not want the family members to know. For CF, AS, the court and even the ARDC to say that these notices can be waived by simply appearing in court on the day of the proceeding to appoint a guardian is completely disingenuous. See an actual Soldini notice in Exhibit C, hereto. Videos that slowly disappear off of Youtube without explanation and emails to youtube go unanswered. (The videos are now safely up on Facebook under MaryGSykes and are the subject of numerous cross posts on the internet and I have discovered another popular website that does not allow the removal of videos by just flagging them or sending out a dumb email). Gloria’s $200,000 in assets were frozen in a preliminary injunction motion but no hearing has ever been set for those. My disqualification for notarizing one document–preposterous–the GAL’s wanted me gone because they knew about the family and what was going on. They did not want a competent, knowledgable attorney in there. Last year, Carolyn T. had Gloria’s gas turned off at her residence, a violation of the Chicago Residential Landlord Tenant Ordinance (“CRLTO”) for approximately 5 months, rendering the unit uninhabitable, and Gloria had to rent elsewhere. This violation is or will be part of the adversarial proceedings in bankruptcy for Gloria. AS and CF knew about Carolyn T’s gross violation of these ordinances in managing property for her mother, yet AS and CF had no calls to remove her for violating the CRLTO and bringing liability of $200 to $500 per day plus reasonable attorneys fees upon Mary T’s estate.

And let’s talk about the court system. The judges are buddies with the GAL’s and vice versa because the judges appoint them so they can make money from a well funded estate. Many a GAL has done nothing but stir up controversy in a family to churn a bill. The judges tolerate it because the GAL’s support them and make campaign contributions. The nursing homes and elder care facilities donate to the campaign funds of probate court judges. The judges have an interest in cozying up to those that are linked into the nursing home and elder care business and finding incompetency where there might not be anything at all because once declared incompetent the person can be put in a facility without any fuss or say in this whatsoever. Any senior that complains or kicks up a fuss is drugged or sedated there. The judges have an interest in accepting testimony from “doctors” that always find incompetency–even where the doctor never even saw the patient. The courts have good reason to deny all discovery against the doctor, how he was chosen, in how many cases he found incomptency and which side he was on. Ever go to a nursing home and take a survey? 90% of the patients want to go home. They don’t understand why they are there when they say they have money and had a good home or apartment. No one ever investigates. No one cares. If anyone, anywhere, protect the rights of these most vulnerable persons in our society, the nursing homes would be much emptier–and so would the pockets of a lot of attorneys, court systems and elder care facilities. That does not make the system right–it makes it pitiful. We treat animals in shelters better than our elderly in nursing homes–at least a cat or dog can hope for a fur-ever home. It is not true that Mary G didn’t want to come to court. The one time she was there, she tried to talk but the judge would not permit it. Mary G wants to go home. She wants to live in her own home and have Gloria care for her–as Gloria did for 11 years. But what is happening right now? CT has evicted her own sister. She is in the process of selling the home and putting it into a trust fund–a trust fund that CT will benefit from (or at least she thinks she will, see above). This was the goal of CT all along. The entire case and procedure is nothing but the unmitigated evil of CT. A bigger conflict of interest could not exist. PS apparently went to the mortgage holder, Chase, on Gloria’s home and told them that the home was abandoned and they had to secure it. One day Gloria came home and found all her furnishings from the home thrown into the snow, interior walls of the home destroyed by smashing the walls open, and a lock box put on the house. Chase admitted liability. Further CT lied to Chase, told them she was on Gloria’s safe deposit box, when she was not, and had the box drilled open. What is most curious about this action is the destruction of the property from the inside (did PS hire the goons to do this–it is clear someone wanted Gloria evicted from her mother’s home and her home made uninhabitable–I have seen the destruction first hand) And, even more curious was the security cameras (4 of them) were disabled and the recorder tampered with. If the exercise was just to secure an abandoned property, why were Gloria’s furnishings thrown into the snow? (I have photos). Why were the security cameras disabled and fooled with? (My son, an engineering major at SIU set up the cameras again and got them running and recording properly and more important–he put a password on the system). Seems to me it was PS and his goons and CT. Why are the GAL’s standing idly by? If CT and PS are involved in this, why aren’t the GAL’s investigating? Neither has come out to see the destruction. Neither has spoken with the service that did this. No report. No one knows why they came there, why

they disabled a 4 camera security system well hidden in the garage, why they smashed numerous interior walls, why they threw a ton of interior valuable furnishings into the snow. CT and PS have postulated that Mary G is half owner of the home and its contents therein and made this subject to a partition proceeding. If this is true, then why are none of this miscreants–PS, CT, AS and CF shouting at the top of their lungs “MARY G’S HOME WAS DESTROYED, HER VALUABLE FURNITURE DESTROYED” and hailing an investigation—pictures, reports, circles and arrows, just like in Alice’s Restaurant! Or just maybe they were all part of it. I guess no one has read the splitting up the baby story of King Solomon. Except this is kind of in reverse. The miscreants want Gloria gone, they trash her house, her furnishings, try to get her to move out, but they never realize that in doing so if no one is outraged and files a report with the Probate Court and investigates, this very lack of investigation, reports, circles and arrows, clearly implicates them in their evil deeds. Further, the GAL’s knew that they wanted to attack Gloria’s August 2008 settlement agreement and final order on her Lumberman’s case. Atty Brodsky in August 2010 told the court and the GAL’s if they wanted to attack a judgment, they had to file a 1401 petition in 2 years. (The deadline was nearly up at that point). Judge Connors said she could alter that judgment at any time–which is contrary to Illinois law on the subject. The GAL’s never filed any motions to attack that judgment and the funds that are frozen should now be released to Gloria. The GAL’s should do it and the court sua sponte. Why doesn’t the ARDC investigate that and charge the GAL’s with improperly managing those funds, thereby throwing Gloria into poverty. Currently KD has determined that Illinois nursing homes are LLC’s that under the law may not charge for administrative services to the corp. However, these entities have traditionally charged the state millions in administrative fees over many long years amounting to a possible lawsuit by Lisa Madigan (assuming she is willing to take these hoodlums on) - the tune of billions of dollars in refunds due the taxpayers of the state of Illinois–do you really think there is no conflict? Do you really think there is a reason to “get rid” of KD. It would be very convenient for a lot of clout happy people right now. Moreover, the Petition does not mention that CF and AS had KD sanctioned for $5,000 and that sanction was overturned on appeal. Where is the complaint against them for hailing KD into a court where he had never appeared before as a means to intimidate him? They filed under § 137 and this requires a filing or pleading in that court. KD never filed any documents in the Probate proceeding, but he was hailed in there by CF and AS and chewed out by the court and sanctioned–a sanction that was ultimately reversed on appeal. My question is, is this Complaint the legal backwash for embarrassing the highly sensitive and overly emotional egos of the miscreants–this is what they wired too? That is nothing but utterly disgusting behavior on their part. 17. Respondent either knew that his statements as described in paragraph 15, above, were false or he made the statements with reckless disregard as to their truth or falsity. KD has done nothing but state the truth and ask the questions that no one wants to hear. Why did

Judge Connors deny Atty Dolgrin his repeated requests for discovery prior to a hearing to appoint Carolyn? Why was the medical report of a doctor that never even saw Mary G used to declare her incompetent? Why were the sisters never given their Soldini notices and why now are the GAL’s and even the ARDC saying that notices were not required when in fact there were and they contain important disclosures regarding the legal rights pertaining to those two sisters. Why was this repeated ad infinitum with no inquiry and response by either Judge Connors or Judge Stuart? Why did Judge Connors say in August of 2010 that she did not have to follow Illinois State law § 1401 and she could declare any judgment from any Illinois court at anytime invalid? When PS and the GAL’s failed to file a Petition against Gloria and serve her with a motion to reopen that judgement pursuant to § 1401, why is it the judge did not remove all of them for gross malpractice? Why was not CT removed for shutting off Gloria’s gas when she knew Gloria was living there and that was a breach of the CRLTO entitling Gloria in an adverse proceeding against the Estate of Mary G a fine of $200 to $500 per day, which amounted to thousands of dollars in fines? KD has not said that the Judges were thieves or that AS, CF and PS are thieves. It is clear from his writing he is making a statement that these miscreants have obvious motives to form a conspiracy and exploit Mary G and her millions in gold coins. He has repeatedly asked the Naperville police to investigate and they ignore him. He has the right to do this and request wellness checks because Mary G’s life IS clearly in danger. Case studies of elders that are financially abused show that once the money is depleted, the victim is then murdered. Why is no one concerned? The Naperville police very well should be. They should be out there every day–checking on Mary G. A woman deposited with a daughter that prior to a Petition for a Protective Order rarely saw or visited with the daughter. A daughter of ill repute and who was not respected in Mary G’s circle of family and friends. When they were told money was missing, why did not a detective perform a simple asset search? Why is there no warrant for the home to check on expensive repairs and upgrades? There’s a lot of lip service here about protecting the elderly, but not much action. And when one calls for action, they are promptly declared a chicken little at best or a miscreant at worst for questioning anything–let alone the dozens of questions in this Response. Perfectly good questions, if you ask me. I have what, about 40 questions or so in this response. Will the ARDC now postulate that there an ethics rule that prevents me from asking questions? 18. By reason of the conduct described above, Respondent has engaged in the following misconduct: making an extrajudicial statement that the lawyer knows or reasonably should know will be disseminated by means of public communication and would pose a serious and imminent threat to the fairness of an adjudicative proceeding, in violation of rule 3.6(a) of the Illinois Rules of Professional Conduct; ***Response*** What harm? What upcoming judicial proceeding. Gloria had has it with that Probate court. Do

you blame her? She was treated miserably and unfairly from the get to. CT has already been long appointed. All of the above emails were written after that appointment of CT occurred in Dec of 2009. Blogs on the internet are now “serious and imminent threat[s]?” This is no jury case of major importance. It has been repeated in no media outlets. Gloria has not filed a Petition to Remove CT (though it is well deserved). There are no upcoming proceedings. This is all clearly after the fact. There is no judge to influence regarding appointment of a Guardian, CT has already been appointed and then these emails were written. And no, neither KD nor myself image with a glass of wine late at night that we’re defending Blagogevich. We know this is small potatoes, a group of blogs on the internet type of stuff. ***End Response**** making a statement that the lawyer knows to be false or with reckless disregard as to its truth or falsity concerning the qualifications or integrity of a judge, adjudicatory officer or public legal officer, in violation of Rule 8.2 of the Illinois Rules of Professional Conduct; conduct involving dishonesty, fraud, deceit, or misrepresentation, in violation of Rule 8.4(c) of the Illinois Rules of Professional Conduct; conduct that is prejudicial to the administration of justice, in violation of Rule 8.4(d) of the Illinois Rules of Professional Conduct; presenting, participating in presenting, or threatening to present criminal charges to obtain an advantage in a civil matter, in violation of Rule 8.4(g) of the Illinois Rules of Professional Conduct; and ***Response*** KD has NEVER threatened to present criminal charges. He has merely analyzed the situation at hand, and based upon his decades of experience in law, he has provided his legal opinion based up the facts presented to those that are or maybe harmed by criminal actions. He has only called upon the Naperville police to further investigate and he has that right. In fact, it is a duty under Himmel. Every attorney has a proactive obligation to report serious crimes–even when it violates the attorney client privilege– to authorities. Every attorney has the obligation to report serious violations of other attorneys to the authorities AND ARDC. The Himmel case requires attorneys to report other attorneys engaging in criminal activities. Further, there is no explanation of how reporting serious crimes and possible or probable crimes has gained Ken Ditkowsky any “civil advantage”. He has not filed a single pleading in any Sykes case – other than those which dispensed with the bogus sanctions filed by the miscreants. So where is the “civil advantage’ spoken of. It is my understanding that Rule 8.4(g) is supposed to apply in settlement discussions involving a

civil case where one attorney threatens or agrees not to press criminal charges or criminal charges are dropped in exchange for a more favorable settlement. So why is the ARDC charging KD with this? He has engaged in no settlement discussions on any case he filed or he represented any client on. Gloria has been pro se in just about every proceeding she has filed, except for brief stints with fleeting attorneys. Where does this come from? The ARDC has failed to identify any alleged “civil proceeding” and the alleged “benefit” that KD is partaking of in order to state a proper claim for relief and as such, this allegation must be dismissed. ***end response*** conduct which tends to defeat the administration of justice or to bring the courts or the legal profession into disrepute. WHEREFORE, the Administrator requests that this matter be assigned to a panel of the Hearing Board, that a hearing be held, and that the panel make findings of fact, conclusions of fact and law, and a recommendation for such discipline as is warranted. ***Response*** Many people have already written the ARDC that it is CF, AS and PS that should be investigated and not KD or myself. KD has no financial motive in any of this and has never present Gloria with any bill. I have not worked for Gloria except to answer limited questions since January of 2010 when CF and AS wrongfully and with ill intent, disqualified me. (CF stated in the hallway outside the court that she did not want me on the case because I would “paper her to death.” Well, I was diqualified, so now I get to blog and video her to death. Did she really think I would walk away from a grave injustice?) After that, Gloria never trusted me again and doesn’t fully understand what happened. All the caselaw, in Illinois and throughout the nation, is clear that you can’t disqualify an attorney based upon a simple notarization of a document. The only persons saying that KD and myself need investigation is only CF and AS. A petition on the internet has already collected over 100 signatures attesting to the fact that CT should be removed as guardian. KD is only repeating what has already been well ascertained and documented in this family and in the court proceedings. The videos are on the internet showing Mary is competent, capable and thinks logically about herself, her situation and her family. From those videos, it is clear that CF lied to the court when she said that Mary dictated letters to the court for help because the videos clearly show Mary writing more letters for help and Gloria only helping with spelling. This is a half hour of video! Mary G Sykes wants to go home and live in her own home. Gloria has pledged to support her and care for her–something she had done quite capably for 11 years prior to this proceeding. It is time to get rid of all of CT, PS, AS and CF and make them the subject of a thorough investigation. Okay, I could not help myself, and Wordperfect makes this waaaay tooo easy, but I counted over 50 questions–questions the GAL’s and law enforcement and the court should be answering. I have more, but those will have to wait for another day.

CONCLUSION: KD is one of the hardest working attorneys I know. He has stayed up late nights, got up early in the morning, worked and worried (like myself) endless hours trying to help Mary and Gloria. He has written countless letters, given free legal advice in countless emails, has nagged, cajoled, grandstanded, dramatically enhanced his communications–and sometimes it appears he is overly zealous regarding protecting Mary G–yet to call him into scorn and disrepute for his help, assistance, kindness and caring is one of the worst forms of evil possible. This complaint should and must be dismissed against KD and the instigators there of (including the ARDC) should be required to provide a public apology to him. This public apology should remain permanently on the ARDC website.