News & Notices

Orders of Discipline & Disability July August 2026

 

Michigan Bar Journal

Order of Discipline & Disability

AMENDED1 SUSPENSION (BY CONSENT)

John E. Berry, P 34268, Lake Linden. Suspension - 30 Days, Effective July 1, 2026.2

Respondent and the Grievance Administrator filed a Stipulation for Consent Order of Discipline, which was approved by the Attorney Grievance Commission and accepted by Grand Traverse Hearing Panel #1. The stipulation contained respondent’s admissions to the factual allegations in the formal complaint, and respondent’s admissions to allegations of professional misconduct set forth in subparagraphs 41(c), (d), (e), (f), (h), and (j) of the formal complaint. Specifically, it was alleged alleging that over the course of a six-year representation of a client in an adoption matter, respondent failed to provide competent representation, neglected the matter, failed to act with reasonable diligence, failed to adequately communicate with his client, and made false statements of material fact to his client when he represented that adoption paperwork had been filed with the Court when he knew such statements to be false. The stipulation further contained the parties’ agreement that subparagraphs 41(a), (b), (g), (i), (k), and (l) of the formal complaint were to be dismissed.

Based on respondent’s admissions and no contest pleas, the panel found that respondent: neglected a legal matter entrusted to the lawyer, in violation of MRPC 1.1(c); failed to act with reasonable diligence and promptness in representing a client, in violation of MRPC 1.3; failed to keep a client reasonably informed about the status of a matter and comply promptly with reasonable requests for information, in violation of MRPC 1.4(a); failed to make reasonable efforts to expedite litigation consistent with the needs of the client, in violation of MRPC 3.2; engaged in conduct that violates the standards or rules of professional conduct, in violation of MRPC 8.4(a) and MCR 9.104(4); and engaged in conduct that is prejudicial to the administration of justice, in violation of MRPC 8.4(c) and MCR 9.104(1).

In accordance with the stipulation of the parties, the panel ordered that respondent’s license to practice law be suspended for 30 days, effective July 1, 2026. Costs were assessed in the amount of $772.31.

1 Amended to correct inaccurate pronouns in the first paragraph.
2 The panel found that the parties’ had set forth good cause for modification of the effective date to July 1, 2026.

SUSPENSION (BY CONSENT)

Victor L. Bland, P 38278, Kalamazoo. Suspension - 45 Days, Effective May 26, 2026.

Respondent and the Grievance Administrator filed an Amended Stipulation for Consent Order of Discipline pursuant to MCR 9.115(F)(5), which was approved by the Attorney Grievance Commission and accepted by Kalamazoo County Hearing Panel #3. The amended stipulation contained respondent’s admissions to paragraphs 5 through 22 of the formal complaint, and respondent’s no-contest plea to the allegations of professional misconduct in subparagraphs 23 (a)-(e). Specifically, that respondent engaged in a conflict of interest by entering into a romantic and sexual relationship with his client during the course of representing her in a divorce matter.

Based upon respondent’s admissions as set forth in the parties’ amended stipulation, the panel finds that respondent: represented a client where the representation of that client was materially limited by the lawyer’s own interests, in violation of MRPC 1.7(b); 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 court 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, in violation of MRPC 8.4(a) and MCR 9.104(4).

In accordance with the amended stipulation of the parties, the hearing panel ordered that respondent’s license to practice law in Michigan be suspended for 45 days, effective May 26, 2026. Total costs were assessed in the amount of $931.87.

DISBARMENT AND RESTITUTION

Michelle L. Elowski, P 74608, Alpena. Disbarment, Effective January 30, 2026.1

The Grievance Administrator filed a formal complaint against respondent. Based on respondent’s default, witness testimony, documentary evidence supporting the allegations in the formal complaint, and respondent’s no contest plea to the criminal charges in People of the State of Michigan v Michelle Lynn Elowski, Oscoda County, 23rd Circuit Court, Case Nos. 24-1953-FH and 24-1954-FH), the panel found that respondent misappropriated funds from several clients in matters for which respondent had been retained, and in doing so, engaged in illegal conduct that resulted in her criminal conviction.

The panel found, by virtue of respondent’s default and the evidence presented by the Grievance Administrator, that respondent: failed to act with reasonable diligence and promptness in representing a client, in violation of MRPC 1.3; failed to keep her clients informed as to the status of their cases, in violation MRPC 1.4(a); failed to explain a matter to the extent reasonably necessary to permit the client to make informed decisions regarding the representation, in violation of MRPC 1.4(b); failed to pay or deliver funds or other property that a client or third person was entitled to receive, in violation of MRPC 1.5(b)(3); failed to hold the property of the client or third person in connection with representation separate from the lawyer’s own property by depositing funds into her personal account, in violation of MRPC 1.15(d); knowingly made a false statement of material fact in connection with a disciplinary matter, in violation of MRPC 8.1.(a); engaged in conduct involving dishonesty, fraud, deceit or misrepresentation and that the conduct reflected adversely on the attorney’s honesty, trustworthiness or fitness to practice as an attorney, in violation of MRPC 8.4(b); engaged in conduct that exposed the legal profession to obloquy, contempt, censure or reproach in violation of MCR 9.104(2); engaged in conduct contrary to justice, ethics, honesty or good morals in violation of MCR 9.104(3); engaged in conduct violating the standards or rules of professional conduct, in violation of MRPC 8.4(a) and MCR 9.104(4); engaged in conduct that violated the criminal laws of the State of Michigan and the United States, an ordinance, or tribal law pursuant to MCR 2.615, in violation of MCR 9.104(5); and, knowingly made a misrepresentation of any facts or circumstances surrounding a request for investigation or complaint, in violation of MCR 9.104(6).

The panel ordered that respondent be disbarred, effective January 30, 2026, and that she pay restitution totaling $266,091.90. Costs were assessed in the amount of $3,933.69.

On January 29, 2026, respondent timely filed a petition for review pursuant to MCR 9.118. After proceedings held in accordance with MCR 9.118, the Board affirmed the panel’s order of disbarment, but reduced the restitution ordered by the panel to $201,591.90. No further costs were assessed.

1 Respondent’s license to practice law in Michigan has been continuously suspended since January 16, 2025. See Notice of Automatic Interim Suspension, issued on February 27, 2025, in Grievance Administrator v Michelle L. Elowski, 25-15-AI.

DISBARMENT

Fredric R. Gumbinner, P 40279, Washington, District of Columbia. Disbarment, Effective May 20, 2026.1

The Grievance Administrator filed a Notice of Filing of Reciprocal Discipline that attached a certified copy of an order from the District of Columbia Court of Appeals in a matter titled In Re Fredric Gumbinner, Case No. 25-BG-0469, disbarring respondent from the practice of law in the District of Columbia, effective June 12, 2024. Respondent’s disbarment in the District of Columbia was a result of his conviction, by guilty plea, of the criminal offense of Bribery Concerning Programs Receiving Federal Funds, in violation of 18 U.S.C. § 666(a)(2), a felony.

An order regarding imposition of reciprocal discipline was issued by the Board on February 9, 2026, ordering the parties to, within 21 days from service of the order, inform the Board in writing

(i) of any objection to the imposition of comparable discipline in Michigan based on the grounds set forth in MCR 9.120(C)(1) and (ii) whether a hearing was requested. The 21- day time period expired without objection or a request for a hearing by either party. As a result, respondent was deemed to be in default with the same effect as a default in a civil action, pursuant to MCR 9.120(C)(6).

On April 21, 2026, the Attorney Discipline Board ordered that respondent be disbarred from the practice of law in Michigan, effective May 20, 2026. Costs were assessed in the amount of $1,538.60.

1 Respondent has been continuously suspended from the practice of law in Michigan since November 20, 2023, the date of his felony conviction. Please see Notice of Automatic Interim Suspension issued July 25, 2024.

DISBARMENT AND RESTITUTION WITH CONDITION (BY CONSENT)

Suzanna Kostovski, P 39535, Washington. Disbarment, Effective May 12, 2026.1

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 #102. The stipulation contained 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 admissions and the stipulation of the parties, the hearing panel found that respondent committed professional misconduct in two client matters and failed to cooperate with the disciplinary investigation.

Specifically, the panel found that respondent: failed to act with reasonable diligence and promptness in representing a client, in violation of MRPC 1.3 (Count One); failed to keep a client reasonably informed about the status of a matter, in violation of MRPC 1.4(a) (Count One); failed to explain a matter to the extent reasonably necessary to permit the client to make informed decisions regarding the representation, in violation of MRPC 1.4(b) (Count Two); upon termination of representation, failed to protect a client’s interests, such as surrendering papers and property to which a client is entitled, and refunding any advance payment of fee that has not been earned, in violation of MRPC 1.16(d) (Count One); knowingly failed to respond to a lawful demand for information from a disciplinary authority, in violation of MRPC 8.1(a)(2) (Count Three); violated or attempted to violate the Rules of Professional Conduct, in violation in MRPC 8.4(a) (Counts One and Two); 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) (Counts One and Two); engaged in conduct prejudicial to the administration of justice, in violation of MCR 9.104(1) and MRPC 8.4(c) (Counts One, Two, and Three); engaged in conduct that exposes the legal profession or the courts to obloquy, contempt, censure, or reproach, in violation of MCR 9.104(2) (Counts One, Two, and Three); engaged in conduct contrary to justice, ethics, honesty, or good morals, in violation of MCR 9.104(3) (Counts One, Two, and Three); failed to provide an answer to a request for investigation that fully and fairly disclosed all the facts and circumstances pertaining to the alleged misconduct, in violation of MCR 9.113(A) and MCR 9.104(7) (Count Three); and violated an order of discipline, in violation of MCR 9.104(9) (Counts One and Two); failed to provide the required notification to active clients of her order of suspension, in violation of MCR 9.119(A) (Counts One and Two); practiced law while her license was suspended, in violation of MCR 9.119(E)(1) (Counts One and Two); communicated with clients while her license was suspended, in violation of MCR 9.119(E)(2) (Counts One and Two); and held herself out as an attorney while her license was suspended, in violation of MCR 9.119(E)(4) (Counts One and Two).

In accordance with the stipulation of the parties, the hearing panel ordered that respondent be disbarred from the practice of law in Michigan, effective May 12, 2026, that he pay restitution in the total amount of $7,000.00, and that he be subject to a condition relevant to the established misconduct. Costs were assessed in the amount of $774.02.

1 Respondent’s license to practice law has been continuously suspended since December 14, 2023. See Notice of Suspension With Conditions (By Consent), Grievance Administrator v Suzanna Kostovski, 22-10-GA.

REPRIMAND

Thomas M. Lenney, P 53720, Chatham, New Jersey. Reprimand, Effective May 20, 2026.

The Grievance Administrator filed a Notice of Filing of Reciprocal Discipline pursuant to MCR 9.120(C), that attached an order reprimanding respondent issued by the Supreme Court of New Jersey on January 2, 2024. Respondent was reprimanded for engaging in negligent misappropriation of client funds and commingling, failing to comply with record-keeping requirements, and practicing law while administratively ineligible, in violation of New Jersey Rules of Professional Conduct 1.15(a) and (d), 5.5(a), and R 1:21-6.

An order regarding imposition of reciprocal discipline was issued by the Board on February 18, 2026, ordering the parties to inform the Board in writing, within 21 days from service of the order, (i) of any objection to the imposition of comparable discipline in Michigan based on the grounds set forth in MCR 9.120(C)(1), and (ii) whether a hearing was requested. The 21-day period set forth in the Board’s order expired without objection or request for hearing by either party.

On April 21, 2026, the Attorney Discipline Board ordered that respondent be reprimanded, effective May 20, 2026. Costs were assessed in the amount of $1,524.84.

REPRIMAND

Samuel P. Nedeau, P72604, Muskegon. Reprimand, Effective May 20, 2026.

The Grievance Administrator filed a Notice of Filing of Reciprocal Discipline pursuant to MCR 9.120(C), that attached a certified copy of an order from United States Bankruptcy Court, Western District of Michigan, issued on December 3, 2025, reprimanding respondent, effective December 3, 2025, in the matter titled In Re Annette Mary Bohach, Case No. 25-03097-swd.

An order regarding imposition of reciprocal discipline was issued by the Board on March 5, 2026, ordering the parties to, within 21 days from service of the order, inform the Board in writing (i) of any objection to the imposition of comparable discipline in Michigan based on the grounds set forth in MCR 9.120(C)(1) and (ii) whether a hearing was requested. The 21- day time period expired without objection or a request for a hearing by either party. As a result, respondent was deemed to be in default with the same effect as a default in a civil action, pursuant to MCR 9.120(C)(6).

On April 21, 2026, the Attorney Discipline Board ordered that respondent be reprimanded, effective May 20, 2026. Costs were assessed in the amount of $1583.22.