DISBARMENT (BY CONSENT)
Ryan S. Bourjaily, P79575, Bloomfield Hill. Disbarment, Effective March 15, 2026.
Respondent and the Grievance Administrator filed a Stipulation for Consent Order of Discipline, in accordance with MCR 9.115(F)(5), which was approved by the Attorney Grievance Commission and accepted by Tri-County Hearing Panel #58. The stipulation contains respondent’s admissions to the factual allegations and allegations of professional misconduct as set forth in the formal complaint in its entirety. Based on respondent’s admission and the stipulation of the parties, the hearing panel found that, between September 25, 2024 and October 17, 2024, respondent commingled over $100,000 for his personal use, including personal gambling transactions, while acting as a conservator in a probate matter in the Oakland County Probate Court, and that respondent misappropriated funds. As of November 7, 2024, respondent had repaid the funds in full that he misappropriated, back to the estate.
Specifically, the panel found that respondent: failed to promptly pay or deliver funds that a client is entitled to receive, in violation of MRPC 1.15(b)(3); knowingly disobeyed an obligation under the rules of a tribunal except for an open refusal based on an assertion that no valid obligation exists, in violation of MRPC 3.4(c); engaged in conduct that violates the standards or rules of professional conduct, in violation of MRPC 8.4(a) and MCR 9.104(4); engaged in conduct involving dishonesty, fraud, deceit, misrepresentation, or violation of the criminal law, where such conduct reflects adversely on the lawyer’s honesty, trustworthiness, or fitness as a lawyer, in violation of MRPC 8.4(b); engaged in conduct that is prejudicial to the administration of justice, in violation of MRPC 8.4(c) and MCR 9.104(1); engaged in conduct that exposes the legal profession or the courts to obloquy, contempt, censure, or reproach, in violation of MCR 9.104(2); and, engaged in conduct that is contrary to justice, ethics, honesty, or good morals, in violation of MCR 9.104(3).
The panel ordered that respondent be disbarred, effective March 15, 2026. Costs were assessed in the amount of $1,129.00
INTERIM SUSPENSION PURSUANT TO MCR 9.115(H)(2) [FAILURE TO APPEAR DUE TO PHYSICAL OR MENTAL INCAPACITY]
Robert A. Pasionek, P33173, Mesa, Arizona. Interim Suspension — Effective March 12, 2026.
On March 12, 2026, Ingham County Hearing Panel #3 entered an order suspending respondent’s license to practice law in Michigan on an interim basis, effective immediately, pursuant to MCR 9.115(H)(2), after respondent failed to personally appear at a hearing scheduled on the same date claiming a physical incapacity as the reason for his non-appearance.
AUTOMATIC INTERIM SUSPENSION
Michael E. Siwek, P 64198, Byron Center. Effective February 24, 2026.
On February 24, 2026, respondent was convicted by guilty plea of sexual exploitation of a minor, in violation of 18 U.S.C. 2251(a), and possession of child pornography, in violation of 18 U.S.C. 2252(A)(5)(B); in United States of America v Michael E. Siwek, United States District Court for the Western District of Michigan, Case No. 1:25-cr-5. Upon respondent’s conviction and in accordance with MCR 9.120(B)(1), respondent’s license to practice law in Michigan was automatically suspended.
Upon the filing of a judgment of conviction, this matter will be assigned to a hearing panel for further proceedings. The interim suspension will remain in effect until the effective date of an order filed by a hearing panel under MCR 9.115(J).
REPRIMAND WITH CONDITION (BY CONSENT)
Kourtney L. Stone, P 85504, Grand Rapids. Reprimand, Effective March 19, 2026.
Respondent and the Grievance Administrator filed an Amended Stipulation for Consent Order of Reprimand in accordance with MCR 9.115(F)(5), which was approved by the Attorney Grievance Commission and accepted by Kent County Hearing Panel #4. The stipulation contained respondent’s admissions to the factual allegations and allegations that she committed professional misconduct while serving as an assistant prosecuting attorney assigned to the Kent County Treatment and Support Court (TASC), a diversion program for defendants with mental health or substance abuse issues. The complaint alleged that respondent developed and maintained an inappropriate personal relationship with a TASC participant whom she was professionally involved with, communicating extensively with him outside official channels, offering gifts and financial assistance, and making statements implying influence over prosecutorial decisions without the knowledge of his attorney. It was further alleged that respondent disclosed confidential information about other TASC participants and improperly accessed the detainee’s recorded jail phone calls using her professional credentials, conduct that ultimately led to an investigation, suspension of her access, and the termination of her employment with the Kent County Prosecutor’s Office.
Based upon respondent’s admissions and the stipulation of the parties, the hearing panel found that respondent represented a client (the State of Michigan) when the representation of that client may have been materially limited by the lawyer’s own interests, in violation of MRPC 1.7(b); communicated about the subject of the representation with a person whom the lawyer knew to be represented in the matter by another lawyer without the consent of the other lawyer, in violation of MRPC 4.2(a); failed to treat with courtesy and respect all persons involved in the legal process, in violation of MRPC 6.5(a); engaged in conduct prejudicial to the administration of justice, in violation of MRPC 8.4(c) and MCR 9.104(1); engaged in conduct that exposes the legal profession or the courts to obloquy, contempt, censure, or reproach, in violation of MCR 9.104(2); engaged in conduct that is contrary to justice, ethics, honesty, or good morals, in violation of MCR 9.104(3); and, engaged in conduct that violates the standards or rules of professional conduct adopted by the Supreme Court, in violation of MPRC 8.4(a) and MCR 9.104(4).
In accordance with the stipulation of the parties, the panel ordered that respondent be reprimanded and subject to a condition relevant to the established misconduct. Costs were assessed in the amount of $1,143.92.
ORDER OF REINSTATEMENT
On January 13, 2026, Tri-County Hearing Panel #4 entered an Order of Suspension (By Consent) in this matter suspending respondent from the practice of law in Michigan for 45 days, effective February 4, 2026. On March 17, 2026, respondent filed an affidavit pursuant to MCR 9.123(A), attesting that he has fully complied with all requirements of the panel’s order and will continue to comply with the order until and unless reinstated. Counsel for the Grievance Administrator informed the Board’s staff that the Administrator has no objection to respondent’s reinstatement; and the Board being otherwise advised;
NOW THEREFORE,
IT IS ORDERED that respondent, Jalal J. Dallo, P72879, is REINSTATED to the practice of law in Michigan, effective March 23, 2026.
ORDER OF REINSTATEMENT PURSUANT TO MCR 9.123(A)
On December 17, 2025, Washtenaw County Hearing Panel #3 entered an Amended Order of Suspension With Conditions (By Consent) in this matter suspending respondent from the practice of law in Michigan for 30 days, effective January 8, 2026. On March 2, 2026, respondent filed an affidavit pursuant to MCR 9.123(A), attesting that he has fully complied with all requirements of the panel’s order and will continue to comply with the order until reinstated. The Grievance Administrator did not file an objection to respondent’s affidavit pursuant to MCR 9.123(A); and the Board being otherwise advised;
NOW THEREFORE,
IT IS ORDERED that respondent, Erik C. Rakoczy, P86620, is REINSTATED to the practice of law in Michigan, effective March 9, 2026.