Transcript
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