Jerome Larkin, Administrator of the Attorney Registration and Disciplinary Commission, by his attorney, Marcia Topper Wolf, pursuant to Supreme Court Rule 762(a), states that, on the date Michael Segal ("Movant") signed a motion requesting that his name be stricken from the Roll of Attorneys, a complaint was pending before the Commission regarding Movant’s actions which resulted in felony convictions for mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.C. § 1343), racketeering (18 U.S.C. § 1962(c)), embezzlement (18 U.S.C. § 1033(b)(1) and (2) and tax conspiracy (18 U.S.C. § 371). If the cause proceeded to hearing, the evidence set forth below would establish clearly and convincingly the misconduct described below.

Records of the United States District Court Northern District of Illinois in the matter of United States of America v. Michael Segal, 02 CR 112, would establish that:

1. On March 18, 2004, a federal grand jury, sitting in the United States District Court for the Northern District of Illinois, returned a 28-count fourth superseding indictment against Movant, Near North Insurance Brokerage, Inc. ("NNIB") and an employee of NNIB, in case number 02 CR 112.

2. The 28-count fourth superseding indictment charged Movant with criminal conduct related to his role as sole owner, director, chief executive officer and chief operating

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officer of Near North National Group and its wholly owned subsidiary, NNIB. Specifically, the indictment alleged that Movant, over the course of many years, devised and implemented a scheme to misappropriate over $20,000,000 from a premium fund trust account ("PFTA") for his own business and personal uses. As a result of such improper withdrawals, the PFTA ran deficits ranging from approximately $5,000,000 in 1990 to approximately $24,000,000 in 2001. In addition, the indictment charged that Movant concealed the illegal withdrawals from the PFTA by falsely representing to the Illinois Department of Insurance that the PFTA was being appropriately operated pursuant to the Illinois Administrative Code.

3. Counts One through Thirteen of the fourth superseding indictment charged Movant with mail fraud under 18 U.S.C. § 1341. Count Fourteen charged Movant with wire fraud under 18 U.S.C. § 1343. Count Fifteen charged Movant with racketeering under 18 U.S.C. § 1962(c). Counts Sixteen through Twenty-two charged Movant with making false statements to the Illinois Department of Insurance under 18 U.S.C. § 1031 (a)(1) and (2). Counts Twenty-three through Twenty-five charged Movant with embezzlement under 18 U.S.C. § 1033(b)(1) and (2). Count Twenty-six charged Movant with making a false statement to a federal agent under 18 U.S.C. § 1001. Count Twenty-seven was not directed to Movant. Count Twenty-eight charged Movant with tax conspiracy under 18 U.S.C. § 371.

4. On June 21, 2004, a jury verdict of guilty was entered as to Movant on Counts One through Twenty-Five and Count Twenty-Eight of the fourth superseding indictment.

5. On November 30, 2005, U.S. District Judge Ruben Castillo entered a judgment of conviction against Movant as to Counts One through Fifteen, Twenty-Three through Twenty-Five, and Twenty-Eight. Counts Sixteen through Twenty-Two were dismissed on the motion of the United States.

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6. On December 1, 2005, Movant was sentenced to 121 months in prison. Movant was also ordered to pay $1,900 in costs and $841,527.96 in restitution.

7. As a result of the order of conviction and the conduct described above, Movant has engaged in the following misconduct:

1. committing a criminal act that reflects adversely on the lawyer's honesty, trustworthiness or fitness as a lawyer in other respects in violation of Rule 8.4(a)(3) of the Illinois Rules of Professional Conduct;

2. conduct involving dishonesty, fraud, deceit or misrepresentation in violation of Rule 8.4(a)(4) of the Illinois Rules of Professional Conduct;

3. conduct which is prejudicial to the administration justice in violation of Rule 8.4(a)(5) of the Illinois Rules of Professional Conduct; and

4. conduct which tends to defeat the administration of justice or to bring the courts or the legal profession into disrepute in violation of Supreme Court Rule 770.