January 2026

DISBARMENT

Stephen John Armstrong

State Bar #208047, La Quinta (November 6, 2025)

Armstrong was disbarred by default.

State Bar investigators contacted Armstrong after he received the initial notice of disciplinary charges filed against him--and he indicated he intended to resign and did not intend to respond to the charges.

The State Bar Court determined that the motion for default against Armstrong was then properly filed--including a supporting declaration of reasonable diligence used to notify him of the proceedings before the default was entered --and verified that he did not move to have the order set aside or vacated.

As a result, the factual allegations in the charges were deemed admitted, and Armstrong was found culpable of all 34 counts of alleged misconduct.

His wrongdoing included: failing to respond to reasonable client inquiries, charging an illegal fee, and engaging in the unauthorized practice of law in another jurisdiction; two counts each of entering into an improper fee agreement and failing to pay client funds promptly; four counts of failing to promptly refund unearned advanced fees; five counts of failing to cooperate in the State Bar's investigation of the charges against him; six counts of failing to render accountings of client funds; and seven counts of failing to deposit client funds in a trust account.

An additional five counts of misappropriating client funds involved moral turpitude.

At the time Armstong was disbarred in the current case, there were four non-public disciplinary matters pending against him, which were abated.

SUSPENSION

Todd Michael Abbott

State Bar #227897, Chula Vista (November 6, 2025)

Abbott was suspended from the practice of law for 90 days and placed on probation for one year after he stipulated to committing 10 acts of professional misconduct.

His wrongdoing included: two counts of failing to maintain the required balance in his client trust account; three counts of failing to maintain required records for his client trust account; and four counts of commingling personal and client funds in trust. He was also culpable of one count of misconduct involving moral turpitude: allowing another to misappropriate funds from his client trust account.

Facts relevant to this matter: Abbott's father became trustee of a trust; the sole trust asset was a life insurance policy. Quarterly premiums were paid by the beneficial interest of the policy to an insurance broker, who them transferred them to the father to pay. The father, a licensed California attorney, informed Abbott that he intended to transfer to inactive status and asked Abbott to open a client trust account into which he could hold the premiums he was receiving. (In fact, the father had been transferred to an inactive status about three years earlier. He eventually admitted to misappropriating $515,900 and was convicted of wire fraud and disbarred in July of 2024.)

Abbott opened the account. For the next two years, unbeknownst to Abbott, his father used the account for various fraudulent purposes--effectively misappropriating the premium payments and denying the rightful beneficiary the benefit of the policy, which lapsed. On his own, Abbott failed to keep required trust account records and transferred funds from his personal account into the trust fund, also using it to pay personal and business expenses.

In aggravation, Abbott committed multiple acts of misconduct that significantly harmed another individual.

In mitigation, he entered into a prefiling stipulation, had practiced law discipline-free for approximately 14 years, and demonstrated remorse after learning of the misappropriation--offering to pay partial restitution. The offer was declined.

Joseph Richard Manning, Jr.

State Bar #223381, Foothill Ranch (November 6, 2025)

Manning  was suspended for one year and placed on probation for two years after he stipulated to committing three acts of professional misconduct: failing to ensure that his firm's employees conformed with ethical and professional obligations, seeking to mislead a judicial officer, and submitting false statements to the court--misconduct involving moral turpitude.

Manning is owner and managing partner of a law firm that focuses on personal injury and disability rights cases. He filed a request for statutory attorney's fees in a case he had worked on, which was misleading because it estimated time he and his associates had worked on the matter using standardized time increments, as opposed to records of actual time worked. The court compared the declaration Manning had filed in the case to declarations he had filed in other cases and found the billing statements to be identical, raising suspicions of fraud. Specifically, during one period, he filed identical declarations in 16 cases; 52 identical declarations during another time period; 26 during another period; and six identical declarations during a later time.

When the court issued an order to show cause why sanctions should not be imposed based on his firm's questionable billing practices, Manning responded that the declarations were "true and correct." Upon consideration, the court imposed sanctions of $2,500 for "a pattern of signing and filing documents in court whose factual contentions lack evidentiary support and abusing the judicial process" by filing a billing statement that was "a carbon copy" of those he had filed in previous cases.

In addition, the court sanctioned three of Manning's law firm associates who had also signed sworn declarations regarding the time spent on the case at issue.

In aggravation, Manning  committed multiple acts of wrongdoing that constituted a pattern of misconduct.

In mitigation, he entered into a pretrial stipulation, had practiced law for 16 1/2 years discipline-free before committing the instant misconduct, submitted evidence of engaging in extensive pro bono work and community services, and provided letters from 26 individuals taken from a range of the legal and general communities--all of whom vouched for his good character.

Henry Paul Noto

State Bar #101855, Bakersfield (November 6, 2025)

Noto was suspended from the practice of law for 18 months and placed on probation for three years after he successfully completed the State Bar Court's Alternative Discipline Program (ADP).

He had earlier been convicted of driving with a blood alcohol content of .08% or more causing injury (Cal. Veh. Code §23153(b)), with admitted allegations of inflicting great bodily injury while committing a felony (Cal. Penal Code §12022.7(a)), and causing bodily injury or death to more than one victim (Cal. Veh. Code §23558). Noto stipulated that the facts and circumstances surrounding the conviction involved moral turpitude warranting discipline.

The felony conviction case was consolidated with two others. In one, Noto stipulated to failing to comply with conditions attached to a prior discipline order--a public reproval. Specifically, he failed to timely submit the required written quarterly reports, reports on complying with criminal probation, and reports of abstinence-based self-help meeting verifications. He also failed to submit proof of attending the State Bar's Ethics School as required.

In the other case, he stipulated to failing to provide an accounting of advanced fees and failing to return a client file. In that matter, Noto was hired to represent a client in connection with a DMV hearing in which she sought to get her driver's license renewed. Advanced fees of $1,500 were paid in accord with a fee agreement characterizing the fee as "non-refundable," without specifying that it was a true retainer. A couple months later, Noto's representation was terminated; the amount of fees he had earned was disputed. Despite the client's multiple requests, Noto did not provide either her file or an accounting of funds held.

In aggravation, Noto had a prior record of discipline and committed multiple acts of wrongdoing.

In mitigation, he entered into a pretrial stipulation, suffered from emotional difficulties during the time of the misconduct, and provided evidence demonstrating his good character in the form of letters from six individuals taken from a range of the legal and general communities. He was also allotted mitigating credit for successfully completing the ADP in the instant case.

Tamara Noel Thomas-Mallery

State Bar #219389, Susanville (November 6, 2025)

Thomas-Mallery was suspended from practicing law for 30 days and placed on probation for one year after she stipulated to committing 20 counts of professional misconduct related to three separate client matters.

She was culpable of: failing to render an appropriate accounting for advanced fees paid; two counts each of failing to render appropriate accountings of fees clients had paid, failing to promptly refund unearned advanced fees, and failing to cooperate in the State Bar's investigation of the wrongdoing alleged; three counts each of failing to perform legal services with competence, failing to promptly release clients' papers and property after being requested to do so, and failing to act with reasonable diligence in representing a client; and four counts of failing to respond to reasonable client inquiries.

In one client case, Thomas-Mallery was retained to represent a client in a probate matter. She filed a petition for special letters of administration on behalf of the client, but failed to obtain the required signatures from the other heirs, or an inventory and appraisal of the estate property or to file a petition for administration. She then ignored numerous email queries from the client about the status of the case. The client filed a complaint with the State Bar two years after hiring Thomas-Mallery, and hired new counsel, who sought the client file and an accounting of fees paid; neither were delivered.

In another case, Thomas-Mallery was retained to represent a client seeking property left to him by trust; she accepted advanced fees of $3,000. She then failed to communicate with the client for nearly three years. The client hired an attorney "for purposes of establishing communication" with Thomas-Mallery, who did not respond to new counsel's requests, nor did she respond to several inquiries about the matter from State Bar investigators. She refunded the advanced fees paid after the State Bar began investigating, but did not return the client file.

And in the third client matter, Thomas-Mallery was retained to help a client seeking to dissolve a living trust. Five months after their initial meeting, Thomas-Mallery responded to the client's email request for an update on the case, assuring the client she would be "reaching out" to her after another unrelated trial matter concluded. After Thomas-Mallery ignored the client's requests for information for an additional three months, the client hired new counsel. Thomas-Mallery also subsequently failed to respond to several queries from State Bar investigators. She eventually returned the advanced fees paid, but not the entire client file, nor did she render an accounting as requested.

In aggravation, Thomas-Mallery committed multiple acts of misconduct.

In mitigation, she entered into a pretrial stipulation, had practiced law without a record of discipline for 18 years, provided letters from seven individuals attesting to her good character, suffered personal difficulties during the time of her misconduct, and presented evidence of performing pro bono and community service work.

--Barbara Kate Repa