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June 2025

| Jun. 2, 2025

Discipline Report

Jun. 2, 2025

June 2025

Recent attorney disbarments, suspensions, probations and public reprovals in California.

DISBARMENT

Victor Stephen Haltom

State Bar #155157, Sacramento (May 9, 2025)

Haltom was disbarred by default. He did not participate in the disciplinary proceeding in which he was charged with failing to comply with several terms imposed in an earlier probation order.

The State Bar Court confirmed that the petition for disbarment was timely filed and served, and that Haltom did not move to have it set aside or vacated.

The specific violations charged in the matter included: failing to schedule and participate in the required meeting with his assigned probation case specialist, failing to submit three written quarterly reports, failing to provide a declaration attesting to having read the Rules of Professional Conduct as well as specified sections of the California Business and Professions Code, failing to notify the clients of their right to request fee arbitration, and failing to file a declaration of compliance as ordered by the California Supreme Court pursuant to the applicable rule (Cal. Rules of Ct., Rule 9.20).

Haltom had been disciplined by the State Bar twice previously, and there were four other disciplinary matters "in various stages of investigation by the State Bar" at the time he was disbarred in the present case.

 

Nienke Schouten

State Bar #303146, San Jose (May 17, 2025)

Schouten was disbarred by default after she failed to participate, either in person or through counsel, in the disciplinary matter in which she was charged with 34 counts of professional misconduct.

The State Bar Court found that all procedural requirements--including proper service and adequate notice--had been met in the case, and that there was an adequate factual basis for imposing discipline. It also determined that Schouten did not move to set aside or vacate the default order imposed upon her.

As a result, Schouten was found culpable of all counts charged. Her wrongdoing, which related to five separate client matters, included: failing to inform a client of significant case developments, failing to obtain court permission to terminate employment, and failing to provide a proper accounting of client funds; two counts of failing to promptly release client files after being requested to do so; three counts of failing to respond to reasonable client inquiries; four counts each of failing to perform legal services with competence and failing to return unearned advanced fees; five counts of failing to act with reasonable diligence in representing clients; and six counts of improperly withdrawing from employment.

She was also culpable of failing to timely update her change of address in the State Bar's official records, as well as six counts of failing to cooperate in the State Bar's investigations of the misconduct alleged.

 

Michael Alan Voorhees

State Bar #88240, San Francisco (May 17, 2025)

Voorhees was summarily disbarred based on his conviction of six counts of grand theft (Cal. Penal Code § 487(a)).

The violations are felonies that the State Bar Court classified as involving moral turpitude.

 

SUSPENSION

Carrie Lynn Freestone

State Bar #130914, San Francisco (May 17, 2025

Freestone was suspended from practicing law for three years after an uncontested probation revocation proceeding.

The State Bar Court found, by a preponderance of the evidence, that she had violated several conditions imposed in an earlier discipline order. Specifically, she failed to schedule and participate in the required meeting with her probation case coordinator and failed to submit a quarterly written report and declaration attesting that she had read and complied with the Rules of Professional Conduct, as well as specified sections of the California Business and Professions Code. She also failed to complete the State Bar's e-learning course as directed.

Freestone did not participate in the current proceeding, and did not comply with the probation conditions imposed despite receiving a courtesy reminder letter as well as other notifications from the State Bar.

In aggravation, Freestone committed multiple acts of misconduct in the current case and had a prior record of discipline, which the court noted involved similar misconduct--indicating a lack of rehabilitation rendering the previous discipline more serious.

 

PROBATION

Dana M. Douglas

State Bar #220053, Granada Hills (May 9, 2025)

Douglas was placed on probation for one year after she stipulated to committing five acts of professional misconduct related to a single client case.

The counts charged and admitted included: failing to perform legal services with reasonable diligence, failing to keep clients reasonably informed of significant case developments, failing to refund unearned advanced fees, entering into an unlawful fee agreement, and failing to render an accounting of client funds.

In the underlying matter, Douglas represented two individuals defending against a civil default judgment. She accepted an advance fee of $3,500. The controlling agreement contained conflicting provisions--one specifying that it was a "non-refundable payment for services already performed and to ensure Attorney's availability to respond to these matters on Clients' behalf" and another specifying that the payment was a "retainer to commence this representation."

Douglas filed an answer and a fee waiver in the matter, both of which were rejected by the court--though she did not inform the clients of the rejection, nor did she file a perfected answer or fee waiver. The court entered a default against the clients; Douglas again failed to inform them of the judgment, and did not file a motion to vacate it. The clients eventually filed a motion to vacate in pro per, which was rejected by the court as deficient and untimely.

In aggravation, Douglas had a prior record of discipline and committed multiple acts of misconduct in the present case that significantly harmed her clients.

In mitigation, she entered into a prefiling stipulation and provided letters from seven individuals from a range in the legal and general communities--all of whom attested to her good character.

--Barbara Kate Repa

 

 

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