James D Ryan Florida Bar Complaint

James D Ryan, Attorney in North Palm Beach, Florida. Complaint against James D Ryan for potentially violating Florida Rules of Professional Conduct. James D Ryan filed Chapter 7 Bankruptcy on or about May 9, 2012. Bankruptcy Trustee investigates James D Ryan for secreting assets.
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THE FLORIDA BAR Inquiry/Complaint Form James D. Ryan 636 US Highway One, Suite 110 North Palm Beach, Florida 33408 Tel: 561.881.4447 Thomas F. Ryan 370 Golfview Rd #101 North Palm Beach, Florida 33408 Tel: 561.626.3179 Michael J. Ryan 636 US Highway One, Suite 110 North Palm Beach, Florida 33408 Tel: 561.881.4447 Comes Now, Complainant, does hereby file his complaint against the above listed Attorneys, licensed in the State of Florida, and governed by the Florida Rules of Professional Conduct. Complainant has reason to believe that the above named persons have violated their oaths to uphold Rules of Professional Conduct by taking part in a scheme to defraud the Bankruptcy Estate of James D. Ryan and Court ordered marital support to Chery Ryan. Complainant has reason to believe that James D. Ryan willfully and knowingly committed a false and fraudulent statement with regards to his Bankruptcy Petition where he knowingly misrepresented his assets on two separate occasions when filing his schedule “B” (personal property) form. Complainant believes that James D. Ryan and brother’s Thomas F. Ryan and Michael Ryan conspired to conceal an asset with a value in excess of $500,000. Based on the events and facts as stated below, Complainant believes that Thomas F. Ryan, reasonably should have known, that brother James D. Ryan was fraudulently concealing significant assets from the Bankruptcy Trustee and from James Ryans’s wife, Cheryl Ryan. Based upon the facts as stated herein, Complainant believes that all three Attorneys are guilty of violating Rule 4-8.4 MISCONDUCT - Offenses involving dishonesty or breach of trust or serious interference with the administration of justice. Where James D. Ryan committed a pattern of repeated offenses by knowingly filing false schedules on his federal Bankruptcy petition and where Thomas F. Ryan knowingly or should have known that by being a party to a “straw entity” (the Trust), he was helping to conceal assets from a Bankruptcy Trustee and the wife, (Cheryl Ryan) of James D. Ryan. In support thereof, Complainant states the following: 1. On or about March 26, 2009, James D. Ryan filed a Petition for Dissolution of Marriage to Cheryl Ryan. See; Palm Beach Docket Case No. 502009DR003337; James Ryan V Cheryl Ryan. 2. On or about October 31, 2011, James D. Ryan, acting as Attorney, entered into an agreement with Diane G. Lettick which purportedly included legal services in exchange for 33% equity position in an “easement contract”. (Contingent Fee) See; Case No. 502011CA017517. Diane G. Littick vs. Empire Investment Group, LLC. (See Exhibit B) 3. On or about December 25, 2011, James D. Ryan created the Singer Island 100 Trust (The Trust). The Trust named Thomas F. Ryan (brother to James D. Ryan) as Trustee and Virginia Ryan (mother to James and Thomas) as Settlor. The Trust names James D. Ryan the Beneficiary. 4. On or about February 15, 2012, the aforementioned styled case no 502011CA017517 resulted in a final disposition and award to Diane G. Littick. (See Exhibit C) 5. On or about April 22, 2013, Diane G. Lettick, as to 66.67% interest and Singer Island 100 Trust, as to 33.33% interest, collectively “Landlord”, and Clear Channel Outdoor, a Delaware Corporation, Tenant, entered into a certain lease regarding the property described therein which has an address of 8380 Resource Drive, Riviera Beach, Florida. The term of the lease is 15 years, commencing on November 13, 2014. Graduated annual payments starting at $30,000 and ending at $40,000 are to be paid to “Landlord”. The “Lease” is signed by Diane Lettick as Landlord and Thomas F. Ryan as Landlord for the Singer Island 100 Trust. (See Exhibit D) 6. On or about May 9, 2013, James D. Ryan filed Chapter 7 Bankruptcy, United States Bankruptcy Court, Southern District of Florida, Case No. 13-20905-EPK. On Schedule B – Personal Property, Debtor, Ryan, listed himself as the Beneficiary of the Singer Island 100 Trust with a current value of only $100.00. (See Exhibit E) 7. On or about June 14, 2013, Debtor, James D. Ryan, by and through his Attorney, filed his amended schedules. Once again, Debtor, James D. Ryan, listed the Singer Island 100 Trust with a current value of only $100.00. (See Exhibit F) 8. On or about August 30, 2013, Debtor, James D. Ryan is granted a Discharge. (See Exhibit G) 9. On or about October 23, 2013, Bankruptcy Trustee, Deborah C. Menotte, filed her “Form 1” Property Record and Report. Case Status indicated that “Trustee was waiting for CBD to Expire. Investigating for Value in TWO LLC’s & Trust. (See Exhibit H) Ref #10: Beneficiary of Singer Island Trust (Investigating). 10. On or about, August 27, 2014, Thomas F. Ryan, as Trustee of the Singer Island 100 Trust, assigned all of the Assignors right, title and interest to “Assignee”, Deborah C. Menotte, in her capacity as Chapter 7 Bankruptcy Trustee for James D. Ryan. (See Exhibit I) 11. On or about September 2, 2014, Michael J. Ryan (brother of James and Thomas Ryan) made an appearance of record in the case of James D. Ryan vs. Cheryl Ryan, case no. 502009DR003337. 12. On or about September 19, 2014, Deborah C. Menotte (the Trustee), filed her Motion for Approval to Record Conveyance Documents Transferring Third Party Interests in Certain Real Property to the Bankruptcy Estate. The Background of the Motion indicated that “the Debtor, James D. Ryan), created the Singer Island 100 Trust (the “Trust”) as a “straw entity” designating his mother, Virginia F. Ryan, as the Settlor, and appointing his brother, Thomas F. Ryan, the Trustee. (See Exhibit J) 13. Specifically, Deborah C. Menotte, Trustee, stated “In an attempt to secrete 1/3 interest in the Asset, the Debtor created the Singer Island 100 Trust (the Trust) as a “straw entity”. 14. On or about January 15, 2015, public document entitled, “Assignment of Lease Agreement” was recorded in the County of Palm Beach, Florida. (See Exhibit K) CC: Pam Bondi Attorney General State of Florida The Capitol PL -01 Tallahassee, Florida 32399 Dave Aronberg State Attorney 401 North Dixie Highway West Palm Beach, Florida 33401 561.355.7100 Gregory Coleman President The Florida Bar Cypress Financial Center 5900 N. Andrews Ave, Suite 835 Ft. Lauderdale, Florida 33309 Catherine Wilson Daily Business Review 324 Datura Street, Suite 140 West Palm Beach, Florida 33401 James D. Ryan 636 US Highway One, Suite 110 North Palm Beach, Florida 33408 Cheryl Ryan 2725 PGA Blvd Palm Beach Gardens, Fl 33410 Thomas F. Ryan 370 Golfview Rd #101 North Palm Beach, Florida 33408 Michael Ryan 636 US Highway One, Suite 110 North Palm Beach, Florida 33408 Tel: 561.881.4447 Deborah C. Menotte Trustee PO Box 211087 W. Palm Beach, Florida 33421 [email protected] 561.795.9640 Under penalty of perjury, I declare the foregoing facts are true, correct and complete. ______________________________ ______________________________ RETURN TO THE FLORIDA BAR DEPARTMENT OF LAWYER REGULATION