Jerome Larkin, Administrator of the Attorney Registration and Disciplinary Commission, by his attorney, Wendy J. Muchman, pursuant to Supreme Court Rule 762(a), states that on the date Dean J. Roupas (hereinafter "Movant") filed a motion requesting that his name be stricken from the Roll of Attorneys, a one-count complaint was pending before the Hearing Board charging Movant with conduct relating to his criminal conviction for corruptly offering and giving cash intending to influence and reward others in violation of the federal statute that criminalizes theft or bribery in connection with programs receiving federal funds, Title 18 U.S.C. §666(a)(2) . Had Movant’s conduct been the subject of a hearing, the Administrator would have introduced the evidence described below, and that evidence would have clearly and convincingly established the following conclusions of misconduct:

Movant’s admissions, certified copies of Rules of the Illinois Department of Revenue, and various court and bank records and client files would have established the following facts:

1. At all times relevant to Movant’s conviction, he was an attorney in Illinois who represented individuals and entities in defending matters brought against them by the Illinois Department of Revenue (hereinafter "Department").

2. Between July 2002 and June 2003, the Department’s rules prohibited Department employees from referring taxpayers to an attorney or law firm in connection with any official business involving the Department. The Department’s rules also required employees to report to

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the Department any offer of a bribe or any unethical practice by tax practitioners.

3. Between November 2000 and October 2003, Movant paid cash bribes totaling approximately $40,000 to three auditors at the Department in exchange for their referrals to Movant of taxpayers’ legal work involving transactions of $5,000 or more.

4. Movant made the payments in cash to conceal the fact that he was making such payments.

5. Between November 2000 and October 2003, when Movant made the cash payments, he knew it was illegal for him to do so, and he did so anticipating favorable treatment by the auditors on behalf of his clients. As a result of the cash payments to the auditors, Movant received client referrals that resulted in approximately $148,000 in legal fees and also received favorable treatment from the auditors on his client’s cases including: lowering the final tax liability for certain clients; providing confidential internal Department documents to Movant relating to clients Movant was representing; and providing advice to help Movant represent his clients in connection with their cases.

6. On January 8, 2008, in connection with the activities described in paragraphs 1-6 above, Movant was charged with corruptly offering and giving cash intending to influence and reward the actions of others in violation of Title 18 U.S.C. §666(a)(2). (United States of America v. Dean Roupas, et al) 08 CR 7, in the United States District Court for the Northern District of Illinois.

7. On February 26, 2008, Movant pled guilty to the indictment, and a plea agreement was filed.

8. On July 25, 2008, Movant was sentenced to fifteen months in a Bureau of Prisons facility and two years supervised release plus $148,800 in restitution to be paid jointly and severally by Movant and the co-defendants in the criminal case.

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9. By the reason of 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 by violating Title 18 U.S.C. §666(a)(2), 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 that is prejudicial to the administration of 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 bring the courts or the legal profession into disrepute, in violation of Supreme Court Rule 770.