In the Matter of:

BEFORE THE HEARING BOARD

OF THE

ILLINOIS ATTORNEY REGISTRATION

AND

DISCIPLINARY COMMISSION

FILED

OCT 31 2016

ATTY REG & DISC COMMCHICAGO

CYNTHIA JEAN KOROLL,

Attorney-Respondent

No. 6275102.

Commission No. 2016PR00079

ATTORNEY-RESPONDENT'S ANSWER TO COMPLAINT

NOW COMES the Attorney-Respondent, CYNTHIA JEAN KOROLL, pro se

and for her Answer to Complaint, states as follows:

COUNT I

(Engaging in harassing conduct in billing dispute with Roca)

1. On May 12, 2015, Respondent and Roca Labs Inc. ("Roca"), by its agent, Don

Juravin, agreed that Respondent would represent Roca in providing general business

advice and representation in litigation, mediation, and other matters regarding Roca's sale

of weight-loss supplements. Respondent and Roca agreed that Respondent would work as

part of Roca's legal team, which included Florida attorneys April S. Goodwin, Paul

Berger, and Rachel Hyman. Respondent and Roca entered into a written agreement that

Respondent would work as an independent contractor for a 90-day trial period

commencing May 12, 2015, and that Respondent was expected to work 20-25 hours per

week and charge Roca a rate of $50 per hour. The agreement further provided that

Respondent was to record her time spent on Roca matters and expenses she incurredin

Roca matters, in Roca's time tracking software ("HubStaff).

ANSWER: Admit that Respondent entered into an agreement to perform legal

services for Roca and that an agreement was signed with Don Juravin agreeing to

$50.00 per hour on a temporary basis and that certain hours would be recorded in

"Hubstaff" and other hours and expenses would be recorded and submitted by

email on a monthly basis. Deny that Respondent's written agreement required her

to work as part of a "legal team". Admit that independent contractors April S.

Goodwin, Paul Berger and Rachel Hyman also provided legal and other services to

Roca at the time of Respondent's contractual obligation. As to other facts, deny and

demand strict proof thereof.

2. Between May 12, 2015 and July 11, 2015, Respondent and Goodwin discussed

Goodwin'sconcernthat Respondent had not used the HubStaffsystemto record her time

as well as what Roca had determined to be a lack of specificity in Respondent's time

entries. On July 11, 2015, Roca informed Respondent that it would not renew

Respondent's independent contractor agreement after the 90-day trial, based on her

failure to resolve its concerns with her billing. Roca further withheld payment of

Respondent's last invoice until its concerns could be addressed.

ANSWER: Admit that on occasion Goodwin discussed the process of using Hubstaff

and explicitly instructed Respondent not to use Hubstaff during travel and during

depositions. Deny that Roca informed Respondent it would not renew the

independent contractor agreement and further state that Respondent terminated

the agreement due to Roca's failure to perform on the contract. Further, answering,

Respondent states that Roca, in its; answer to a civil complaint filed against it by

Respondent in Florida, admitted that Respondent, and not Roca, terminated the

independent contractor agreement.

3. On or about July 17, 2015, Roca filed a complaint alleging that Respondent

engaged in malpractice with respect to her representation of Roca. The complaint was

docketed as Roca Labs Inc., v. CynthiaKoroll, case number 15-CA-006540 in the Circuit

Court of the 13th Judicial District in Hillsborough County, Florida.

ANSWER: Admit that Roca filed said complaint and subsequently filed amended

pleadings and further avers the complaint has no legal merit whatsoever.

4. On or about July 22, 2015, Respondent filed a breach of contract complaint

against Roca Labs in which she alleged that Roca had not paid her certain sums for her

services. The complaint was docketed as Cynthia Koroll v. Roca Labs, et al., case number

15-CC-024279, in the Circuit Court of the 13th Judicial District in Hillsborough County,

Florida.

ANSWER: Admit said complaint was filed seeking unpaid fees and unreimbursed

expenses and dismissed with the Court's instruction to file a counterclaim, if

desired, in 15-CA-006540.

5. Between July 11, 2015 and July 27, 2015, Respondent sent to Goodwin, Juravin

and Hyman hundreds of texts, emails, tweets and Skype instant messages containing

racial slurs, anti-Semitic comments and threats of litigation, including the following:

"You are a witness. You better be damn straight that everyword can be backed up because I will never let this go. Iwill litigate this until you and your slimey Israeli punkclient wish he had never thought of hiring a white, brilliantGentile." Email to Hyman dated July 20, 2015, 12:16 p.m.

"...so suck some more on that Israeli slong [sic] girl. I hopeyou choke as I will take you apart bit by bit in every legalway possible from now until the end of your career." Emailto Goodwin dated July 20, 2015, 9:35 a.m."You WILL regret ever meeting me. I will turn over everyrock you and your fucking towel head Arab crawled outfrom under from now to eternity." Email to Goodwin datedJuly 20, 2015, 9:35 a.m.

"Tell your Israeli terrorist that this is American [sic] and hecan go fuck himself and the camel he rode in on. Take thatpussy little Monk loving faggot [sic] and his retarded kidwith him." Email to Goodwin dated July 20, 2015, 9:35a.m.

"Just talked to a Jewish friend, he says that this is typical ofan Israeli Jew. And he suggests a fraud count and trebledamages." Text message to Hyman dated July 16, 2015,9:58 p.m.

"Lose some weight, get a facial and deal with the speechimpediment. Jackass." Email to Goodwin dated July 20,2015,9:35 a.m.

"It will be a public proceeding and everyone that sees andhears you will think: He must be a poor man. He must be athief. And in the process you will look like a low lifescummy thief. Because making me foot the bill for yourlitigation is STEALING. I do not know what God or idolyou worship but my God says that stealing is breaking acommandment. Do you look in a mirror Don? What doyour kids think about their Father when the policemancomes to the house AGAIN to serve him papers? Little kidsare scared of cops. Maybe they think that the policemanmight take Daddy away?" Email to Juravin dated July 20,2015 at 2:37 a.m.

"So get the Israeli to pay me in full. Drop the ducking suitand apologize....Eat that shit. All of you. " Skype messageto Goodwin dated July 20, 2015, 10:33 a.m.

"Today I might tweet and Facebook all your personalcomments about your coworkers from our Skypeconversations...After I call Paul's [Berger] wife today."Email to Goodwin dated July 20, 2015, 6:41 a.m.

"You are just a piece of shit." Email fo Goodwin dated July20,2015,9:35 a.m.

"Rachel Hyman is Orthodox Jew. Berger is Jewish. Butthey bash Juravin for cheap practices and Jewing down allfor discount." July 21, 2015 11:02 a.m. Tweet.

"cheap Jew bastard" Email to Goodwin dated July 21,2015,2:24 p.m.

"So get your Team and the Israeli together. Work up asweat on his swarthy oily brow and put together a proposedorder." Email to Goodwin dated July 23, 2015, 8:57 p.m.

"you are simply morally bankrupt and sociopathic or soterrified of having to get another job that you have takenleave of your senses " Email to Berger, Goodwin andHyman dated July 24, 2015 at 4:40 a.m.

"You do not have the right to call yourself a lawyer.Because there is another name for a woman who will do

anything for pay. It is not "counsel." Email to Berger,Goodwin and Hyman dated July 24, 2015, 4:40 a.m.

"Though Israeli slong [sic] might have been a bit over thetop Twitter LOVES it." Email to Goodwin dated July 25,2015 at 1:25 a.m.

ANSWER: Admit that communications were exchanged sent in the timeframe specified and that the majority of communication with Roca and otherindependent contractors was by text, email and Skype, Respondent lacksknowledge of the number of communications. Admit that Respondent statedshe would file litigation for unpaid attorney fees and travel expenses. Admitthat the excerpts included in Paragraph 5, though out of context as presentedabove, were regretably sent or tweeted by Respondent.

6. Respondent intended her statements as described in paragraph five, above, to

embarrass, delay, or burden Goodman, Hyman, Juravin, Berger and other Roca

employees so that Roca would pay her the amount Respondent alleged she was due in

fees.

ANSWER: Deny.

7. By reason of the conduct described above, Respondent has engaged in the

following misconduct:

a. In representing herself in a dispute with Roca,taking action through texts, emails and tweets toGoodman, Juravin, Hyman and Berger, that had nosubstantial purpose other than to embarrass, delayor burden Roca's attorneys and employees inviolation of Rule 4.4(a) of the Illinois Rules ofProfessional Conduct.

ANSWER: Deny.

COUNT II

(Engaging in harassing and burdensome conduct in litigation with Roca)

8. The Administrator realleges paragraphs one through four, above.

ANSWER: Respondent reaffirms her answer to 1-4, above.

9. Between July 11, 2015 and July 27, 2015, Respondent sent to Goodman, Juravin

and Hyman hundreds of texts, emails, tweets and Skype instant messages in some of

which she threatened to reveal confidential information she had learned during the

attorney-client relationship, including the following:

"I also have texts- from your team- about your team. Aboutyou. So, when the Court has to hear about the 17 hours,then that is exactly what they will hear. When the Courtpermits me to testify about the conversations in that 17hours based on phone records? This is what they willhear..."Email to Juravin dated July 20, 2015 at 2:37 a.m.

ANSWER: Admit that an unknown number of texts, emails and Skype messages

were sent and Tweets were posted during the period described including the email

excerpt cited. Deny that Respondent threatened to reveal any confidential material

she had learned during the litigation. Admit that Respondent stated she would

testify in Court if permitted. As to the remaining allegations, deny and demand

strict proof thereof.

10. Between July 11, 2015 and July 27, 2015, Respondent sent to Goodman, Juravin

and Hyman hundreds of texts, emails, tweets and Skype instant messages in come of

which she threatened to require Roca to present for deposition Roca employees and

independent contractors (including one working and residing in Pakistan), spouses and

children of Roca attorneys, although they had no knowledge of Respondent's billing and

minimal interaction with Respondent, including the following:

"I want to litigate this matter to uncover every little detail.You can expect to come here for my deposition. I want todepose every one of you and all office staff that I interactedwith, including Jack." Email to Goodwin dated of July 21,2015,2:24 p.m."I want preserved all accounts, all electron Devices, allphones, all computers used at any time to communicatewith me or about me, including but not limited to:

Paul BergerRachel HymanApril GoodwinDon Juravin

Legalteai-n@rocalabs.com"Jack"

"Shannon or Sharon"

This is also my request to take these depositions. I willhave all depositions videotaped. I will Skype them and Iwill have attendees at the depositions." Email to Doowinand Berger dated July 21, 2015, 2:51 p.m.

"We are issuing notices for your depositions. Will youaccept service for Shannon, Selena, Jack, Roca'saccountant, the employees who I discussed the call fromMarc with, Don and Don's wife or should I issue subpoenas

for their depositions and have the Sheriff serve them?I will also need to take the deposition of Mr. Hyman oncertain questions posed to him by Rachel on my behalf.Also he is a witness to conversations about my legal abilityand Rachel's upset with Don for a variety of things. WillRachel accept service or should I serve Brett?" Email toGoodwin and Berger dated July 21, 2015 at 5:53 p.m.

"There are no threats against family members. There areonly promises. Paul's kids were parties to conversations.They heard him speak to me. Once again, he elected to putthem in a position to testify and you filed the garbage."Email to Goodwin dated July 24, 2015 at 4:40 a.m.

ANSWER:. Admit that a number of communications as described were sent

including, but not limited to, the cited excerpts. Denied that Respondent had anyimproper intent or purpose in making any of the communications referred to inparagraph 10. Deny all remaining allegations of paragraph 10.

11. Respondent intended her statements as described in paragraph nine and ten above,

to embarrass, delay, or burden Goodman, Hyman, Juravin, Berger and other Roca

employees so that Roca would pay her the amount Respondent alleged she was due in

fees.

ANSWER: Denied.

12. By reason of the conduct described above, Respondent has engaged in the

following misconduct:

a. in representing herself in a dispute with Roca,taking action through texts, emails and tweets toGoodman, Juravin Hyman and Berger, that had nosubstantial purpose other than to embarrass, delayor burden Roca's attorneys and employees inviolation of Rule 4.4(a) of the Illinois Rules ofProfessional Conduct.

ANSWER: Denied.

COUNT III

(Engaging in a conflict ofinterest in the Dieguez matter)

13. Between January 2008 and at least October 2011, Respondent and Karl A.

Szymanski ("Szymanski") were married and practiced law together in Rockford as

partners under the name of "Szymanski Koroll Litigation Group" ("SKLG"). SKLG

handled medical malpractice, domestic relations and personal injury matters.

ANSWER: Admit that Respondent was married to and practiced with Szymanski at

SKLG, deny that SKLG operated throughout all dates described.

14. On or about July 26, 2011, Szymanski, on behalf of SKLG, and Dena Dieguez

("Dieguez") agreed that SKLG would represent Dieguez in a post-decree domestic

relations matter (In re the matter of Diegues, 01D1032), then pending in the Circuit Court

for the 17th Judicial Circuit in Winnebago County, and guardianship matter involving a

minor, Luis Fuller, for whom Dieguez wanted to be appointed guardian. Dieguez agreed

to be billed hourly at a sum of $250 for SKLG's services.

ANSWER: Denied that the law firm of SKLG ever entered an appearance or agree

to representation of Dena Dieguez, however, admit that Respondent in her capacity

as Senior Partner at SKLG, filed a Motion to Withdraw on behalf of SKLG due to

the fact that Szymanski continued to use the SKLG firm address and in an effort to

clear any perception that Szymanski's appearance was on behalf of SKLG. Deny all

remaining allegations contained in paragraph 14.

15. Between July 26, 2011 and November 9,2011, Szymanski, on behalf of SKLG

provided legal services to Dieguez in connection with the post-decree and guardianship

matters.

ANSWER: Admit that Szymanski provided services to Dieguez and that Respondent

was aware of the guardianship case. Admit that Respondent became aware of the

post-decree matter on November 9,2011 at which time she filed a petition to

withdraw in 01D1032. Deny all remaining allegations contained in paragraph 15.

16. On or about October 27, 2011, Szymanski filed a petition to dissolve his marriage

to Respondent. Shortly thereafter, Respondent and Szymanski ceased practicing law

together as SKLG.

ANSWER: Admit that the petition was filed on October 27,2011 and prior to that

date Respondent ceased practicing with Szymanski at SKLG.

17. On or about November 9, 2011, Respondent filed a motion to withdraw SKLG's

appearance as counsel for Dieguez in her post-decree matter. In that motion, Respondent

stated the reasons for the request to withdraw were that "[Differences have arisen

between the client and counsel for the firm" and that "The client has expressed

dissatisfaction with the professionalism of counsel such that the working relationship is

not retrievable."

ANSWER: Admit.

18. As of at least November 2011, if not sooner, Respondent reviewed SKLG's client

file for Dieguez and knew that Dieguez had been an SKLG client, and that Dieguez had

remitted to SKLG at least $500 in fees for the post-decree matter, and a $147 filing fee in

the guardianship matter. Respondent also knew what work SKLG had performed on

Dieguez's matters.

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ANSWER: Denied. Respondent has never reviewed any SKLG client file for Dieguez

as to her knowledge no such client file or billing records ever existed in the office

operating as SKLG. Admit that Respondent was aware of Dieguez's payments of

$147 and $500 in the guardianship matter. Deny all remaining allegations contained

in paragraph 18.

19. On November 21,2011, Szymanski filed a substitute individual appearance on

behalf of Dieguez in her post-decree matter, and the court granted Respondent's motion

to withdraw SKLG's appearance as counsel for Dieguez.

ANSWER: Admit that such filing occurred and that said order was entered.

20. Shortly after November 21,2011, Respondent formed "Koroll Litigation Group"

("KLG") and Szymanski continued to practice under his own name and/or as "Karl's

Litigation Group."

ANSWER: Admit that Respondent formed KLG and that on some date unknown,

Szymanski formed Karl's Litigation Group.

21. On or about December 5, 2011, attorney James T. Zuba ("Zuba") filed an

appearance in the post-decree matteron behalfof Dieguez'sex-husband, John Dieguez

("John").

ANSWER: Admit.

22. Sometime betweenApril 19, 2012 and June 5, 2012, Respondent was attending

court on another matter at the time the Dieguez post-decree matter was scheduled to be

heard in court. At that time, she introduced herself to John and told John that she thought

it was "terrible" what Szymanski and Dieguezwere doing to him, and how much it was

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costing him. Respondent also told John that she would help him in any way she could.

Sometime thereafter, Szymanski learned of Respondent's conversation with John.

ANSWER: Admit that on June 5,2012 Respondent saw John Dieguez at Court and

indicated during the court proceeding that she wanted to speak to him. Respondent

lacks sufficient knowledge or information to admit nor deny anything Szymanski

learned at any time. Deny all remaining allegations contained in paragraph 22.

23. On or about June 5, 2012, Szymanski filed a motion to prohibit contact between

Respondent and John based on Respondent's contact and conversation with John referred

to in paragraph 22, above. Respondent was served on that date in open court with the

motion and the court entered a temporary emergency injunction prohibiting Respondent

was discussing any matters with John. The court then scheduled a hearing on the motion

for June 14, 2012.

ANSWER: Respondent lack sufficient knowledge to admit or deny that Szymanski

took any action as described in paragraph 23. Admit that Szymanski made mention

to the court of Respondent's contact with John and attempted to hand Respondent a

document during her appearance for another client. Admit that after June 5,2012,

Respondent learned that a temporary emergency injunction was entered which was

subsequently dismissed after a June 14,2012 hearing. Deny all remaining

allegations contained in paragraph 23.

24. On June 14, 2012, the court conducted a hearing regarding Szymanski's request

for an injunction. Duringthe hearing, the Honorable Joseph J. Bruce questioned

Respondent about her involvement in the Dieguez casewhile at SKLG. Respondent

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testified that she had not looked at Dieguez's file. In reliance on Respondent's testimony,

Judge Bruce denied Szymanski's motion to prohibit contact between Respondent and

John, and declined to enjoin Respondent from contact with John, concluding that

Respondent was an attorney and was obligated to comply with the Illinois Rules of

Professional Conduct.

ANSWER: Admit that said hearing occurred, and that Respondent was questioned

about the Dieguez file. Admit that Respondent has never reviewed any client file for

Dena Dieguez in any matter and testified consistently with same. Admit that Judge

Bruce denied the injunction. Admit that Respondent is an attorney and that

Respondent is obligated to comply with the Illinois Rules of Professional Conduct.

Deny as to all other allegations and demand strict proof thereof.

25. Respondent's statement to Judge Bruce that she had not looked at Dieguez's file

was knowingly false, because prior to filing the motion to withdraw on behalf of SKLG

in Dieguez's case, Respondent had reviewed Dieguez's client files.

ANSWER: Denied. Respondent had never and has never to date reviewed any

Dieguez client file and did not prior to filing a Motion to Withdraw on the

guardianship case and on the divorce case. Respondent filed the motion based on the

electronic entries in the Winnebago county clerk system.

26. On or about November 19, 2012, Szymanski filed a petition for attorneys' fees in

the amount of $5,625 in Dieguez's post-decree matter, which reflectedthat Dieguezhad

paidhim $500 on August 24, 2011 for the post-decree matter. Respondent knew of that

petition for attorneys' fees because she hadreceived copies of SKLG fee petitions in

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connection with her pending divorce proceedings against Szymanski. The court set the

petition for fees for hearing on December 13, 2012.

ANSWER: Admit that Szymanski, personally, and not on behalf of SKLG and after

SKLG dissolved, filed a petition in the Dieguez matter, seeking payment for services

he provided to Dieguez. Deny that any SKLG fee petition ever existed for Dieguez.

Deny that Respondent ever obtained any copies of SKLG fee petitions in the divorce

proceeding against Szymanski.

27. On December 12, 2012, Respondent faxed a letter to Zuba referencing

Szymanski's November 19, 2012 fee petition, referred to in paragraph 26, above. Zuba

received the letter shortly after Respondent sent it. In that letter, Respondent stated that

she had gone over all billing on Dieguez's matters with Szymanski before filing a motion

to withdraw SKLG's appearance, and that Szymanski's petition for fees contained false

statements, because Dieguez had paid SKLG $500 (as referenced in paragraph a8, above)

for the guardianship matterand not the post-decree matter (as Szymanski claimed in his

fee petition). Respondent also told Zuba that Szymanski's billing listed on the petition

from August 2011 to December 2011 was false because Dieguez was receiving free legal

services from Szymanski. Zuba did not respond to Respondent's letter or otherwise

presentRespondent's allegations in the Dieguez court proceedings.

ANSWER: Admit that Respondent faxed a letter to Zuba on December 12,2012.

Deny all allegations contained in paragraph 27 purporting to characterize the

contents of the letter, and affirmative state that the contents of the letter speak for

themselves. Respondent lack sufficient knowledge or information to admit or deny

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any allegations concerning actions taken by Zuba. Deny all remaining allegations

contained in paragraphs 27.

28. On August 8, 2013, Judge Bruce entered an order allowing Zuba to withdraw as

counsel for John. Sometime between August and October 2013, Respondent and John

agreed that Respondent would represent John in matters related to the post-decree case.

Respondent and John agreed that Respondent would not charge John any fees for her

representation.

ANSWER: Admit that in October 2013 Respondent agreed to represent John

pro-bono in reliance on the prior ruling of Judge Bruce and the applicable case law

regarding conflicts.

29. On October 24, 2013, Respondent filed her appearance in the post-decree matter

on behalf of John.

ANSWER: Admit.

30. On October 31, 2013, Szymanski filed a motion to disqualify Respondent as

counsel for John, based on SKLG's prior representation of Dena in the post-decree case.

ANSWER: Admit.

31. On November 19,2013, after a hearing on the matter, Judge Bruce granted

Szymanski's motion to disqualify and entered an order disqualifying Respondent from

representing John in the post-decree case.

ANSWER: Admit.

32. By reason of the conductdescribedabove, Respondent has engaged in the

following misconduct.

a. knowingly representing John Dieguez in the same

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or substantially related matter in which SKLG hadrepresented Dena Dieguez when Respondent had been aprincipal in SKLG, when John's interest were materiallyadverse to Dena's and when Respondent had acquiredinformation about which matters Dena had paid fees andcosts to SKLG and work that SKLG completed for Dena,that was protected by Rules 1.6 and 1.9(c) and that wasmaterial to the pending petition and motion in thepost-decree case, without Dena's informed consent, inviolation of Rule 1.9(b)(1) and (b)(2) of the Illinois Rulesof Professional Conduct (2010);

b. making a false statement of material fact or law tothe tribunal by the lawyer, by conduct including tellingJudge Bruce she had not reviewed Dieguez's file whenRespondent knew she had, in violation of Rule 3.3(a)(1) ofthe Illinois Rules of Professional Conduct (2010);

c. conduct involving dishonesty, fraud, deceit ormisrepresentation, by conduct including telling JudgeBruce she had not reviewed Dieguez's file whenRespondent knew she had, in violation of Rule 8.4(c) of theIllinois Rules of Professional Conduct (2010); and

d. Engaging in conduct that is prejudicial to theadministration ofjustice, by conduct including delaying theresolution of the post-decree matter and requiring the courtto devote resources to hearing and ruling on the motion todisqualify, in violation of Rule 8.4(d) the Illinois Rules ofProfessional Conduct (2010).

ANSWER: As to items a-d, denied.

DISCLOSURE PURSUANT TO COMMISSION RULE 231

1. Respondent is admitted to practice law in the State of Illinois. SHe is not licensed

to practice in any other state jurisdictions.

2. Respondent holds Illinois registered professional nurse license no. 041249309/

Respondent first obtained a professional nurse license on September 27, 1988. The

current license will expire on May 31, 2018.

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Cynthia Koroll, pro se630 N. Church Street

Suite 202

Rockford, IL 61103

Tel: 815-316-7554

Fax:779-423-2332

CYNTHIA KOROLL-

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