DCBABRIEF - AN ALTERNATIVE FOR ALLOCATION OF PARENTAL RESPONSIBILITIES - DUPAGE COUNTY BAR ASSOCIATION
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DCBA Brief
The Journal of the DuPage County Bar Association
Volume 31, Issue 8 | April 2019
An Alternative for
Allocation of Parental
Responsibilities
www.dcbabrief.org
Volume 31, Issue 8
April 2019
Table of Contents
Brian M. Dougherty
Family and friends gathered to help dedicate the DBF memorial plaque. Editor-in-Chief
L to R: Roger Ritzman, Lee Henninger, Tom Newman, Mark Ritzman, Jodi
Henninger, Bob Kay, Dawn Henninger and Carl Henninger, Jr. Christopher J. Maurer
Associate Editor
Editorial Board
Anthony Abear
Terrence Benshoof
3 Editor’s Message
22 InBrief
- By Terrence Benshoof
Annette Corrigan
Teresa Dettloff
Dexter Evans
5 President’s Message
23 DCBA Update
- By Robert Rupp
Peter Evans
Timothy Hickey
Raleigh D. Kalbfleisch
Timothy Klein
24 ISBA Update
Articles
Andrea L. Kmak
- By Kent A. Gaertner Clarissa R.E. Myers
Jane Nagle
26 Legal Aid Update Joseph K. Nichele
- By Cecilia Najera Azam Nizamuddin
John J. Pcolinski, Jr.
8 The Illinois Probate Act: A Non-Parent’s Alternative to the Jay Reese
29 DBF Dedicates New Memorial Plaque
IMDMA for Allocation of Parental Responsibilities Arthur W. Rummler
- By Henry Kass 31 New Offerings from the IICLE/DCBA
James L. Ryan
Jordan Sartell
ON Demand Site David N. Schaffer
14 Fast Markets: The Prosecution of Commodities Jolianne Walters
Rules Violations by Futures Exchanges 32 Classifieds
- By Trevor J. Orsinger Jacki Hamler
Publication Production
34 Where to be with DCBA
18 Illinois Law Update
- Editor Joseph K. Nichele Ross Creative Works
Graphic Design
Fuse/Kelmscott
Printing
DCBA Brief April 2019 1
AD here
From the Editor
The Dissenting Opinion
By Brian Dougherty
After reading a recent Seventh Circuit en same statute that explicitly referenced “appli-
banc opinion, I recalled back to law school cants for employment” to find that applicants
Brian M. Dougherty is a partner
textbooks. Every so often a case brief would were not covered by the disparate impact pro-
in the litigation group at Golds-
also include the dissenting opinion. In some vision of the ADEA, which did not explicitly tine, Skrodzki, Russian, Nemec
instances, I found the dissent more persua- reference applicants. Seems straightforward, and Hoff, Ltd. in Burr Ridge.
sive than the majority opinion. A few years but the dissent took a different route: when His practice area primarily
ago, I read part of Judge Richard A. Posner’s Title VII was amended to include “applicants includes representing employees
book, How Judges Think (2008). He described for employment”, that amendment just clarified and employers in employment
a concept known as dissent aversion. Here it existing law, so the absence of “applicants for disputes arising under state and
federal law as well as business
goes: Appellate judges A, B and C are decid- employment” in the ADEA is not a big deal.
torts and general business-re-
ing a case. A has an interest in the subject
lated litigation. He also counsels
matter at issue, and B and C have a lesser The takeaway from the case is worth noting. businesses on best practices
interest. A writes the majority opinion and Eight judges (all nominated by Republican under labor and employment law
B is inclined to go along with it. However, Presidents, which is an interesting fact, but and contract law. He is an active
C disagrees and writes a dissent. A does not not a necessary predictor of judicial ideology member of the DCBA and is a
want the opinion magnified by a dissent. So A (known as the attitudinal theory) did not member of the DCBA’s Labor and
decides to join C’s opinion, which now becomes need to look behind the statute’s language, Employment Section. In his spare
time, he manages youth baseball
the majority opinion. B as we know does not but three judges did just the opposite because
and basketball teams.
feel strongly on the topic so he joins A and they felt strongly that Congress could not have
C. Thus, the panel, which was going to side left open the possibility that it would be legal
with one party on a 2-1 vote, now has swung to discriminate against job applicants using
in the opposite direction with a 3-0 vote. age-neutral policies. Griggs outlawed similar
tactics in a racial context. The three-judge
This brings me to the court opinion refer- dissenting opinion felt strongly that Title VII’s
enced above, Kleber v. CareFushion Corpo- legislative history supplied the answer, which
ration, where the court had what is thought can be fraught with peril. The late Justice
to be a simple job: discerning Congress’s Antonin Scalia would certainly have agreed.
intent when it enacted a statute. The
12-judge panel decided the case 8-4, with Without dissenting opinions, opposing argu-
two dissenting opinions (the first dissent ments can easily go by the wayside because
joined parts of the second dissent to make judges may not feel strongly about the issue
it more interesting). To simplify things, at hand. In some instances, on appeal to the
Title VII as it existed before 1972 was inter- Supreme Court, those arguments may be
preted by the Supreme Court (Griggs v. Duke adopted and carry the day. Just because it’s
Power Co.) to cover applicants for employment a minority view does not mean it should be
under a disparate impact analysis. The Age overlooked or lightly cast aside. There was a
Discrimination in Employment Act (ADEA) reason, after all, why some dissenting opin-
was patterned after Title VII’s disparate impact ions were cited in our law school materials – to
provision. Eight judges discerned Congressio- show the care taken by judges on important
nal intent by looking at the plain language of issues coming before them.
the statute and then to other provisions of the (Continued on Page 6)
DCBA Brief April 2019 3
President’s Message
The Costs of “Free” Speech and Press
By J. Matthew Pfeiffer
On May 1st each year, we celebrate Law Day idea that it’s impossible to get something for
by recognizing the role of law in our society and nothing, a deeper connotation is that there
foster a more profound understanding of the is always a cost to a person or to society as J. Matthew Pfeiffer is the Pres-
ident of DCBA. He is the owner
legal profession as a whole. DCBA is pleased to a whole even if something appears to be free,
of Pfeiffer Law Offices, P.C., in
have Clarissa Myers serve as this year’s Law though that cost may be hidden or an external- Wheaton, which concentrates
Day Chair and looks forward to a wonderful ity. In the context of free speech, this means its practice in the areas of civil
program celebrating this annual event. that we certainly can say almost anything we litigation, employment matters,
want under the protection of the First Amend- business law, estate planning,
This year’s Law Day theme addresses freedom ment to the U.S. Constitution. and commercial real estate.
of speech, freedom of the press, and a free Matt also serves as the current
society. Freedom of speech and the press are Yes, I understand that the First Amendment Chair of the Board of Visitors for
his alma mater, Northern Illinois
cornerstones of a free society. It’s difficult to protects one’s right to free speech and free
University College of Law. In his
imagine a free society without these civil lib- press. But having this right doesn’t equate to scant spare time, Matt patroniz-
erties, yet recent litigation (such as Pappas v. what we say or what we publish actually being es area golf courses.
Hurst, 2018 IL App (1st) 171759-U; Clifford “free” – i.e., devoid of repercussions. In some
v. Trump, 2:18-cv-06893 (C.D.Cal. Oct. 15, instances, what you say or write might result
2018); Jacobus v. Trump, 55 Misc.3d 470 (2017); in a lawsuit against you. It might result in a
Dobias v. Oak Park & River Forest High Sch. quick exodus of sponsorships. It could cost
Dist. 200, 2016 IL App (1st) 152205; Sandholm you your job. It might leave you ostracized
v. Kuecker, 2012 IL 111443) and historical nationally (just ask Nick Sandmann), let
debates surrounding them continually chal- alone in your community. While “Congress
lenge us to consider their boundaries. shall make no law…abridging the freedom of
speech, or of the press,” these are all very real,
Technological advances also have transformed very possible costs of your exercise of those
how free speech and free press work in our “freedoms.”
society. Twitter seems to be the medium of
choice for President Donald Trump’s free For this year’s Law Day, consider exactly what
speech rights, and there are probably 10,000 “freedom of speech” and “freedom of the
times the amount of comments and opinions press” mean to our society now versus what
in response to his tweets as there are tweets of they meant in 1791. Are they timeless con-
his. Facebook allows seemingly endless com- cepts? How “free” is our speech? How “free” is
ment threads expressing user rancor on social our press? How many of us go about our daily
and political topics. And the tail end of this activities actually speaking our minds about
decade has seen the proliferation of “fake matters that concern us or upon which we have
news” as a byproduct of freedom of the press particular opinions among a “free” society?
in a modernized world.
There are a lot of things I have opinions about.
As my former colleague, mentor, and DCBA Some of them are the same opinions you hold
Past President Steven M. Ruffalo often on certain subjects, whether openly or behind
advised me in our days working together, closed doors. Some other opinions that I have
“There is no such thing as a free lunch.” While might surprise you.
this adage usually is associated with the basic (Continued on Next Page)
DCBA Brief April 2019 5
From the Editor (Continued from page 3)
In this issue, Henry Kass discusses the doctrine of standing for
non-parents under the Illinois Marriage and Dissolution of Marriage
Act and the Illinois Probate Act of 1975 for purposes of allocating
parental responsibilities. Trevor J. Orsinger provides us with an
The DCBA BRIEF is a publication of the
DuPage County Bar Association overview on how traders can face prosecution for illegal trading
126 South County Farm Road actions.
Wheaton Illinois 60187
(630) 653-7779
Jolianne S. Alexander was the Articles Editor for this issue and
DCBA Brief welcomes members’ feedback. Joseph K. Nichele was the Illinois Law Update Editor, and their
Please send any Letters to the Editor to the attention contributions are welcomed.
of Brian Dougherty, at email@dcbabrief.org
J. Matthew Pfeiffer
President
Tricia Buhrfiend
Secretary/Treasurer
President’s Message (Continued from page 5)
Stacey A. McCullough
Before becoming President of the DCBA, I often joked that I would
Angel M. Traub
President-Elect Assist. Treasurer use the President’s Page each month for my “Airing of Grievances” à la
Frank Costanza during Festivus to share these personal views. Then,
Wendy M. Musielak Directors:
Terrence Benshoof just before my first column was due, I realized the wisdom my plan
2nd Vice President
Mark S. Bishop lacked. So, I instead write largely neutral pieces that, as my friend
Kiley M. Whitty Patrick L. Edgerton
David J. Fish puts it, resemble “Deep Thoughts by Jack Handey.”
3rd Vice President James S. Harkness
Karen R. Mills
John J. Pcolinski, Jr. But that’s fine with me. It beats being sued. Or losing my job. Or
Gerald A. Cassioppi
Amalia M. Romano
Immediate Past President losing my standing in the community. Or not being able to enjoy the
Arthur W. Rummler
James L. Ryan “freedoms” I have.
Charles G. Wentworth Richard J. Veenstra
General Counsel Alissa C. Verson
Bradley N. Pollock Kent A. Gaertner
Assoc. Gen’l Counsel ISBA Liaison
Robert T. Rupp
Letter to the Editor
Executive Director
DCBA Members,
The DCBA Brief is the Journal of the DuPage County Bar Association
Thank you so much for the beautiful plaque presented to me on my
(“DCBA”). Unless otherwise stated, all content herein is the property of retirement. The DCBA has been so important to me and so instru-
the DCBA and may not be reprinted in whole or in part without the express mental in my career I can only hope to continue to contribute to the
permission of the DCBA. ©2019 DCBA. Opinions and positions expressed
in articles appearing in the DCBA Brief are those of the authors and not bar and community through the DCBA. It has been my honor and
necessarily those of the DCBA or any of its members. Neither the authors pleasure.
nor the publisher are rendering legal or other professional advice and this
publication is not a substitute for the advice of an attorney. Publication
Guidelines: All submitted materials are subject to acceptance and editing Brian McKillip
by the Editorial Board of the DCBA Brief. Material submitted to the DCBA
Brief for possible publication must conform with the DCBA Brief’s Writers
Guidelines which are available at dcbabrief.org. Advertising and Promo-
tions: All advertising is subject to approval. Approval and acceptance of
an advertisement does not constitute an endorsement or representation
of any kind by the DCBA or any of its members. Contact information: All
Articles, comments, criticisms and suggestions should be directed to the
editors at email@dcbabrief.org.
6 DCBA Brief April 2019
Articles 8 The Illinois Probate Act: A Non-Parent’s Alternative to
the IMDMA for Allocation of Parental Responsibilities
- By Henry Kass
14 Fast Markets: The Prosecution of Commodities
Rules Violations by Futures Exchanges
- By Brett R. Geiger
18 Illinois Law Update
- Editor Joseph K. Nichele
Articles Editor
Jolianne S. Alexander
Jolianne S. Alexander, as a practicing labor and employment attorney, has
represented clients in a wide variety of labor and employment-related mat-
ters. She has worked in an in-house setting, and as both a plaintiff’s and
defense attorney. She also has experience litigating employment claims at
the administrative, trial, and appellate levels, and has argued before the
Illinois Supreme Court.
ARTICLES
For a non-parent to seek the allocation of parental responsi-
bilities of a child, the non-parent must first establish that she
or he has standing to pursue the cause of action. The non-par-
ent’s path to establishing standing under the Illinois Marriage
and Dissolution of Marriage Act (“IMDMA”) is limited to
situations in which the child is not in the parent’s physical
custody.1 The Illinois Probate Act of 1975 (“Probate Act”)
offers the same opportunity for non-parents to establish stand-
ing but provides another avenue where the IMDMA falls short.2
The Illinois The Non-Parent’s Path to Standing
Under the IMDMA: Physical Custody
Probate Act:
Section 601.2 of the IMDMA states that any person, other
than a parent, can seek the allocation of parental responsibili-
ties of a child in the county in which the child is permanently
A Non-Parent’s Alternative residing or found, but only if the child is not in the physical
custody of one of the child’s parents.3 Thus, the litmus test for
to the IMDMA for Allocation determining whether a non-parent has standing to pursue the
allocation of parental responsibilities is whether a parent of the
of Parental Responsibilities child has physical custody. No definitive definition exists, how-
ever, for the term “physical custody,” nor is there a clear test by
By Henry Kass which a court may determine the issue.4
That said, there are three predominate, non-statutory factors
to which a court must look in making a physical custody
determination. These factors include: (1) who was responsible
for the care and welfare of the child prior to the initiation of
the allocation proceedings; (2) the manner in which physical
1. 750 ILCS 5/601.2(b)(3).
2. 755 ILCS 5/11-5(b).
3. Note 1, supra.
4. Young v Herman, 2018 IL App (4th) 170001, at ¶ 53, citing In re Custody of M.C.C. 383 Ill. App. 3d 913,
917 (1st Dist. 2008).
8 DCBA Brief April 2019ARTICLES
possession of the child was acquired; and (3) the nature and co-parent with her.14 Thereafter, until mid–2008, the child
duration of the physical possession.5 No single factor is con- spent four nights a week at the paternal grandmother’s home.15
trolling.6 From mid–2008 through October 2015, the child spent five
or six nights a week at the paternal grandmother’s home.16
Factors two and three introduce the term “physical possession.” Although the mother was involved with the child’s care, the
Much like the factors detailed in the preceding paragraph, the paternal grandmother was responsible for the child’s day-to-
IMDMA makes no mention of this term. Nor, as with the term day care, education, extracurricular activities, and social life.17
“physical custody,” is there a definitive definition. Although
Black’s Law Dictionary includes definitions for “possession,” In October 2015, the mother reclaimed the child from the
it offers none for the term “physical possession.”7 Even as the paternal grandmother and resumed caretaking responsi-
legal dictionary defines “possession,” the definitions make little bilities.18 In December 2015, two months later, the paternal
sense in the context of the cases that analyze physical posses- grandmother and her husband filed a petition for allocation of
sion.8 To add to the list of qualifications not mentioned by the parental responsibilities.19
IMDMA in determining whether a parent has physical custody,
a court must also look to whether the physical custody was Following a hearing, the trial court found that the mother vol-
voluntarily and indefinitely relinquished.9 untarily and indefinitely relinquished physical custody to the
paternal grandmother.20 In affirming the trial court, the Fourth
Whether a parent has voluntarily and indefinitely relinquished District held that the mother’s reclamation of and resumption
physical custody is highly fact-dependent.10 Even where the of care for the child for two months did not reinvest her with
facts of cases are similar, courts may arrive at different con- physical custody but, rather, constituted only physical posses-
clusions. sion of the child.21
In Young v. Herman, the father told the paternal grandmother in Under similar facts, the Second District found differently. In
December 2006 that the mother had given birth to his child.11 Dumiak v. Kinzer-Somerville, the mother and father married in
The father was not involved in the child’s life.12 From February January 2007.22 The mother gave birth to their child in Febru-
of 2007 until March or April 2007, the child stayed with the ary 2007.23 The mother and father lived apart.24 The mother
paternal grandmother two to four times per week.13 In March and the child lived together until August 2008.25 From August
or April 2007, the mother asked the paternal grandmother to 2008, the child began living with the paternal grandparents.26
5. In re Marriage of Rudsell, 291 Ill. App. 3d 626, 632 (4th Dist. 1997).
6. Dumiak v. Kinzer-Somerville, 2013 IL App (2d) 130336, at ¶ 20.
7. Possession Definition, Black’s Law Dictionary (10th ed. 2014), available at Westlaw.
8. Id.
About the Author
9. In re Petition of Kirchner, 164 Ill.2d 468, 491 (1995), abrogated on other grounds by In re R.L.S., 218 Ill.2d
428 (2006).
10. Dumiak, note 6, supra.
11. Young, note 4, supra, at ¶ 19.
12. Id. Henry D. Kass is a partner with Mirabella Kincaid
13. Id. at ¶ 20.
14. Id.
Frederick Mirabella Law, LLC focusing his prac-
15. Id. tice in the areas of domestic relations, probate,
16. Id. and criminal law. He attended the University of
17. Id. at ¶ 58.
18. Id. at ¶ 59.
the Basque Country in Spain, graduated from the
19. Id. at ¶ 1. University of Iowa where he also obtained his J.D.
20. Id. at ¶ 27. He was an ASA with DuPage County from 2001
21. Id. at ¶ 59.
22. Dumiak, note 6, supra, at ¶ 3.
to 2005. Thereafter, he began his practice in
23. Id. domestic relations law. He is currently
24. Id. Vice-Chair for the Family Law Section.
25. Id.
26. Id.
DCBA Brief April 2019 9ARTICLES
The mother advised the paternal grandmother that she was challenging. This is not only due to the facts required to make
very happy that the child would be living with the paternal such a case, but also that so often the non-parent who is caring
grandparents.27 The mother further advised that she wished for the child is a close relative of the parent. In these cases, the
to establish visitation with the child and pay support to the parent often has some significant life challenges (e.g. illness,
paternal grandparents.28 mental health, addiction, etc.), which inhibits the parent from
effectively caring for the child. Win or lose, the non-parent
In October 2010, the mother reclaimed the child from the recognizes that a legal entanglement with the parent over the
paternal grandparents and resumed caretaking responsi- parent’s child will come at the cost of the non-parent’s relation-
bilities.29 In February 2011, three months later, the paternal ship with the parent.
grandparents filed a petition for allocation of parental
responsibilities.30 More distressing is the outcome of losing the case for allo-
cation of parental responsibilities. Should the non-parent fail
Following a hearing, the trial court found that as of October to prove physical custody, the cost may also include the non-
2010, the mother was in “possession” of the child and, therefore, parent’s relationship with the child (if the parent then decides
the paternal grandparents did not have standing.31 In affirming to take the child from the non-parent) or even the child’s well-
the trial court, the Second District held that although the being (if the parent remains incapable of caring for the child).
paternal grandparents had physical custody from August 2008 To the non-parent, these uncertainties are paralyzing. The
until October 2010, the mother’s reclamation of and resump- Probate Act, however, offers non-parents an additional avenue
tion of care for the child for three months reinvested her with by which to establish standing or make a case for standing
physical custody.32 The Second District noted that its holding where none existed previously.
did not create a bright-line rule based upon the number of days
in which a non-parent waits to file a petition for allocation of The Probate Act’s Alternative Path
parental responsibilities.33 to Standing: Unwilling or Unable
On January 1, 2011, the Illinois General Assembly amended
With these holdings in mind, consider the following hypothet- Section 11-5(b) of the Probate Act to bring it in conformity
ical. A parent suffers from drug addiction. For several years with Section 601.2 of the IMDMA and its progeny of case
the parent allows the child to live with the non-parent. During law.34 Specifically, Section 11-5(b) states, in relevant part,
this time, the non-parent assumes caretaking responsibilities that a court lacks jurisdiction to proceed on a petition for the
for the child. Periodically, the parent visits with the child and appointment of a guardian of a child if it finds that the child has
performs caretaking functions. One day, the parent reclaims a living parent, adoptive parent, or adjudicated parent, whose
and resumes care for the child. The parent remains unrecov- parental rights have not been terminated, whose whereabouts
ered from drug addiction. Two and one-half months later, the are known, and who is willing and able to make and carry out
non-parent files a petition for allocation of parental respon- day-to-day child care decisions concerning the child, unless the
sibilities. Pursuant to the holdings in Young and Dumiak, the parent or parents voluntarily relinquished physical custody of
non-parent and the parent each have a claim for physical custody the child.35
of the child, respectively.
The Probate Act, therefore, offers the same path to stand-
Proving that a non-parent has physical custody of a child is ing as the IMDMA (physical custody), which is obviated by
27. Id. at ¶ 7.
28. Id. 34. In re Guardianship Estate of Tatyanna T., 2012 IL App (1st) 112957, at ¶ 22.
29. Id. at ¶ 11. 35. Note 2, supra. Section 5/11-(b) additionally provides that a non-parent may acquire standing if (1) after
30. Id. at ¶ 4. receiving notice of the hearing on the petition for appointment of a guardian of the child (pursuant to
31. Id. at ¶ 17. Section 11-10.1), the parent or parents fail to object to the appointment at hearing, or (2) the parent or
32. Id. at ¶¶ 25-26. parents consent to the appointment as evidenced by a written document that has been notarized and
33. Id. at ¶ 39. dated or by a personal appearance and consent in open court.
10 DCBA Brief April 2019ARTICLES
“
the verbiage following the conjunction “unless.” However,
Proving that a parent employing the contrapositive to the verbiage that precedes that
conjunction bears out the Probate Act’s alternative. Otherwise
stated, if the court lacks jurisdiction to proceed on a petition
is not willing or is not for appointment of a guardian of a child where the parent is
willing and able to make and carry out day-to-day child care
decisions, the court has jurisdiction to proceed on a petition for
able to make or carry appointment of a guardian of a child where the parent is either
unwilling or unable to make or carry out day-to-day child care
out day-to-day child decisions.36
Although Section 11-5(b) provides a rebuttable presumption
care decisions typically that a parent is willing and able to make and carry out day-to-
day child care decisions, this presumption must be rebutted by
only a preponderance of the evidence. Thus, if the non-parent
requires a less unique is able to rebut the presumption and prove that the parent is
not willing or is not able to make or carry out day-to-day child
set of circumstances
care decisions, the non-parent may be successful in establish-
ing standing (and ultimately securing guardianship, which is
tantamount to an allocation of parental responsibilities).
than proving physical Referring back to the hypothetical above, assume that the
court was to find that the parent did not voluntarily and in-
custody of a child. Thus, definitely relinquish physical custody. If the non-parent argued
alternatively that the parent was not willing or able to make or
carry out day-to-day child care decisions due to the parent’s
where a non-parent has drug addiction, the court could still find that the non-parent
has standing and allocate to her or him parental responsibili-
no facts to substantiate
ties (via guardianship).
Proving that a parent is not willing or is not able to make or
physical custody, a case carry out day-to-day child care decisions typically requires a
less unique set of circumstances than proving physical custody
of a child. Thus, where a non-parent has no facts to substan-
for standing may yet exist tiate physical custody, a case for standing may yet exist under
the Probate Act. As mentioned before, in those situations in
which a non-parent has a claim for physical custody, the phys-
under the Probate Act. ical custody has likely come about as a result of the parent’s
36. Id. “Jurisdiction,” as the term is used in both the IMDMA and the Probate Act, refers to a standing
requirement for persons petitioning for allocation of parental responsibilities. The legislature used the
term “jurisdiction” to limit the court’s exercise of existing jurisdiction. In re Marriage of Schlam, 271 Ill.
App. 3d 788, 794 (2d Dist. 1995). Thus, a non-parent’s standing does not refer to whether a litigant has
a justiciable interest in a controversy. In re Estate of Wellman, 174 Ill.2d 335, 344 (1996). Rather, it is
a threshold issue and although the non-parent’s standing must be determined before proceeding to a
best interests’ determination, it is not a component of the court’s actual subject matter jurisdiction. In
re Custody of McCuan, 176 Ill. App. 3d 421, 425 (5th Dist. 1988).
DCBA Brief April 2019 11AD here
ARTICLES
unwillingness or inability to care for the child. As such, the Rather, it is subject to the best interests of the child.41 Thus,
Probate Act offers to those non-parents with a case for physical once the non-parent has established standing, regardless of
custody, an argument in the alternative, should the physical whether by employing the IMDMA or the Probate Act (or
custody claim fail. both), the court must ultimately determine whether it is in
the best interests of the child that the non-parent be allocated
Regardless of the Path Employed, the Ultimate parental responsibilities.
Issue Remains: The Best Interests of the Child
The superior rights doctrine presumes that parents have the Conclusion
superior right to the allocation of parental responsibilities re- Before a court may allocate parental responsibilities to a
garding their child.37 The standing requirement protects the non-parent, the non-parent must first establish that she or
superior rights of parents and ensures that statutes governing he has standing. Under the IMDMA, to have standing, the
non-parents’ ability to acquire parental rights, whether through non-parent must have physical custody of the child. Proving
the IMDMA or Probate Act, pass constitutional muster.38 physical custody requires specific facts that can be difficult to
Thus, proving that the non-parent has physical custody of the substantiate. In addition to physical custody, the Probate Act
child or that the parent is unwilling or unable to make or carry offers an alternate path to standing. Under the Probate Act, a
out day-to-day decisions concerning the child, addresses only non-parent need only prove that the parent is either unwilling
the threshold issue of the non-parent’s standing to pursue the or unable to make or carry out day-to-day child care decisions.
right to seek the allocation of parental responsibilities.39 Regardless of whether the non-parent elects the IMDMA or
Probate (or both) as the path to standing, the court must ulti-
Although constitutionally protected, a parent’s superior right mately decide if it is in the best interests of the child to allocate
to the allocation of parental responsibilities is not absolute.40 parental responsibilities to the non-parent.
37. In re R.L.S., 218 Ill.2d 428, 432 (2006).
38. In re Tatyanna T., note 34, supra, at ¶ 22.
39. Young, note 4, supra, at ¶ 46.
40. In re Custody of Townsend, 86 Ill.2d 502, 507 (1981), abrogated on other grounds by In re R.L.S., 218
Ill.2d 428 (2006).
41. Id. at 508.
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DCBA Brief April 2019 13ARTICLES
Fast Markets:
The Prosecution of Commodities
Rules Violations by Futures Exchanges
By Trevor J. Orsinger
During the 1980s, the Federal Bureau of Investigation con- an unprecedented manner and at nearly unobservable speed.
ducted a sting operation on the floor of the Chicago commodi- What many may not understand is that this new frontier can
ties and futures exchanges to tamp down on criminal behavior have significant consequences.
in the trading pits.1 Their work – which involved placing agents
in the trading pits – ultimately led to the conviction of over The government and individual exchanges remain committed
20 traders for a variety of crimes that were generally related to minimizing the opportunity for nefarious actors and have
to depriving market participants of the best price, trading on implemented ever-evolving laws and regulations that attempt
customer information, and other fraud-based activities.2 to curb electronic trading violations. As such, practitioners may
benefit from a more thorough understanding of the various
Despite any concerns about chronic criminal activity in the ways (and venues) their clients may be prosecuted for viola-
financial markets, the Chicago metropolitan area remains the tions that are as old as the ones used in the 1980s to convict
hub of the nation’s futures trading. The physical pits – those traders; however, new ones exist and many are directed at reg-
areas on the trading floor where swarms of people made ulating electronic trading.
almost unrecognizable hand gestures at an incomprehensible
rate – have been all but eliminated by the implementation of The case of Michael Coscia demonstrates how a series of
electronic platforms. This relatively new trading venue allows “disruptive” trades can have severe consequences in the three
market participants around the planet to access a number of forums traders can be prosecuted. Mr. Coscia engaged in a
exchanges, including those owned by Chicago-based CME practice known as “spoofing.” Codified by the Commodity
Group, Inc. (“CME Group”), and trade any multitude of prod- Enforcement Act, according to the Commodity Futures Trad-
ucts quickly at almost any point in the day. ing Commission (“CFTC”), spoofing occurs when a “trader
bids or offers with the intent to cancel a bid or offer before
The industry is trying to adapt at a similar speed. As the execution.”3
electronic markets become more complex, and in some ways
less transparent than the physical pits, electronic traders are In general, spoofing occurs when a trader places a “large”
finding ways to take advantage of the evolving landscape in bid or offer – a request to purchase or offer to sell a specific
1. Eric N. Berg, Kurt Eichenwald, & Julia F. Siler, F.B.I. Commodities ‘Sting’: Fast Money, Secret Lives, N.Y.
Times, Jan. 30, 1989, available at https://www.nytimes.com/1989/01/30/business/fbi-commodities-
sting-fast-money-secret-lives.html. 3. Commodity Futures Trading Commission, Office of Public Affairs, Q&A – Interpretive Guidance and Policy
2. David Greising & Laurie Morse, Brokers, Bagmen & Moles: Fraud and Corruption in the Chicago Futures Statement on Disruptive Practices, available at https://www.cftc.gov/sites/default/files/idc/groups/
Markets (John Wiley & Sons, Inc. 1991). public/@newsroom/documents/file/dtpinterpretiveorder_qa.pdf.
14 DCBA Brief April 2019ARTICLES
commodity at a certain price – on one side of the market at a can bring a civil suit against traders for the same violation.
certain price. He or she then quickly cancels that large order Under 7 U.S.C. § 6c of the Commodity Exchange Act, trad-
after smaller orders, previously placed on the opposite side of ers are prohibited from certain activities, to include disruptive
the market are filled.4 The large order essentially acts like a trading, which is defined as “bidding or offering with the in-
lure, all but guaranteeing the small orders are obtained at a tent to cancel the bid or offer before execution.”8 Last, and as
better price on the other side of the market. explained in greater detail below, individual exchanges can also
bring actions for trade-related violations.
For offenses like spoofing and other violations, traders may
face prosecution by at least three separate agencies in three dif- In Mr. Coscia’s case, he and his firm, Panther Energy, LLC,
ferent venues: (1) the Department of Justice in criminal court; were administratively prosecuted by each of CME Group’s
(2) the CFTC in a civil suit; and (3) the individual exchanges four exchanges for violations of their rules against spoofing.
in an administrative proceeding. In agreeing to resolve the matter, Mr. Coscia was barred from
trading on any of the CME Group exchanges for a period of
From a criminal perspective, under 18 U.S.C. § 1348, the 6 months, was required to pay a total fine of $200,000, (the
Department of Justice can prosecute individuals who “de- trading firm agreed to pay a total fine of $600,000), and he and
fraud any person in connection with any commodity for future Panther Energy, LLC, were jointly and severally liable for total
delivery” and who “obtain[s], by means of false or fraudulent disgorged profits in the amount of approximately 1.3 million
pretenses, representations, or promises, any money or property dollars.9 The CFTC also filed and settled civil charges against
in connection with the purchase or sale of any commodity for Mr. Coscia and his firm for a 1.4 million dollar fine, disgorge-
future delivery…”5 A conviction can result in a fine and up to ment of 1.4 million dollars, and a one-year suspension.10 Lastly,
25 years in prison.6 he was prosecuted and convicted by the Department of Jus-
tice with the judge imposing a sentence of “thirty six months’
In examining the civil component to trading violations, imprisonment to be followed by two years’ supervised release.”11
About the Author
because the CFTC’s mission is “to foster open, transparent,
competitive, and financially sound markets,”7 the commission
Trevor Orsinger is managing partner at the Ors-
4. See generally, CME Group, Notice of Disciplinary Action, COMEX 15-0265-BC, (Dec. 5, 2018), available inger Law Group, P.C. and of Counsel at O’Mara
at https://www.cmegroup.com/notices/disciplinary/2018/12/COMEX-15-0265-BC-MIHIR-SALLA.html Gleason O’Callaghan focusing his practice on
#pageNumber=1.
5. 18 U.S.C. § 1348; See also, the indictment of Michael J. Coscia, infra note 8. financial services litigation. Prior to private
6. 18 U.S.C. § 1348. practice, Trevor worked for CME Group, Inc. as
7. U.S. Commodity Futures Trading Commission, available at https://www.cftc.gov/About/Mission an enforcement attorney. In 2003, Trevor began
Responsibilities/index.htm.
8. 7 U.S.C. § 6c(a)(5); See also, In re Panther Energy Trading LLC and Michael J. Coscia, CFTC Docket No. his legal career as a Public Defender in Cook
13-26 (Commodity Futures Trading Com’n July 22, 2013) (Order). County and joined the U.S. Air Force JAG Corps in
9. See generally, Press Release, U.S. Commodity Futures Trading Com’n, CFTC Orders Panther Energy Trading 2006. He has worked for the federal government
LLC and its Principal Michael J. Coscia to Pay $2.8 Million and Bans Them from Trading for One Year, for
Spoofing in Numberous Commodity Futures Contracts, Release No. 6649-13, (July 22, 2013), available at and continues to serve as a Lieutenant Colonel
https://www.cftc.gov/PressRoom/PressReleases/pr6649-13. in the Wisconsin Air National Guard.
10. Id.
DCBA Brief April 2019 15ARTICLES
Under CFTC regulations, individual exchanges are self-reg- While not ever y investigation results in a disciplinar y
ulated.12 Thus, CME Group, which owns the Chicago Board action, and cases can be administratively closed as quietly
of Trade, (“CBOT”), the Chicago Mercantile Exchange, as they are opened, when Market Regulation determines a
“
(“Mercantile Exchange”), the violation occurred, they can issue the “respondent” a letter of
New York Mercantile Exchange warning or refer the matter to
(“NYMEX”), and the Commod-
ity Exchange (“COMEX”), has
For offenses like spoofing the exchange’s Department of
Enforcement, composed of
developed its own set of trading
rules specific to each exchange.
and other violations, traders attorneys in Chicago and New
York, for administrative pros-
CME Group’s division of Mar-
ket Regulation is responsible for
may face prosecution by ecution.16 Once received, the
enforcement attorney reviews
carrying out these mandates.
Composed primarily of depart-
at least three separate the matter and makes a determi-
nation as to whether prosecution
ments of investigation, market
surveillance, data investigations,
agencies in three different is warranted.17
and enforcement, Market Regu-
lation “conducts trade, position,
venues: (1) the Department While allegations of rule vio-
lations frequently settle and
account, and market surveillance
to identify and prevent potential
of Justice in criminal the fine, disgorgement of prof-
its, and possible suspension
rule violations and ensure that all
four of our Designated Contract
court; (2) the CFTC in are approved by an exchange
Business Conduct Committee,
Markets, (DCMs) – Mercantile
Exchange, CBOT, NYMEX,
a civil suit; and (3) the (“BCC”), should a trader wish to
challenge it, the enforcement
and COMEX – fulfill their self-
regulatory responsibilities.”13
individual exchanges in an division must first present
the investigative report to the
The investigations and sur-
administrative proceeding. Probable Cause Committee,
(“PCC”), a five-member panel,
veillance divisions run routine who determines by a quorum
audits and inquiries of both individual traders and firms. whether there is a “reasonable basis” to believe charges should
CME Group’s Market Regulation will also consider customer be issued against the respondent.18 If the PCC determines
complaints and review trading records to determine whether that a reasonable basis exists to believe a violation of the rules
a violation occurred.14 Frequently, exchange personnel will occurred, the market regulation issues “a charging memorandum
interview traders about their activity to understand the specific to the respondent with a brief statement of factual allegations
behavior of a trader, and according to exchange rules, the trader that identifies the charged Rule violation(s).”19 In addition to
is required to answer – a complexity which lawyers now must sending the charging memorandum, the trader should receive
navigate carefully in light of the Coscia matter.15 a “notice of charges”20 that “set forth the Rule(s) alleged to
staff or any investigative or hearing committee at a duly convened hearing, scheduled staff interview
or in connection with any investigation).
16. Chicago Mercantile Exchange, Inc., CME Rulebook 407 (noting “[u]pon conclusion of an investigation,
the Market Regulation Department may issue a warning letter to any party as a result of the investiga-
tion. Such letter shall not constitute either the finding of a Rule violation or a penalty.” See also, CME
11. U.S. v. Coscia, 866 F.3d 782 (7th Cir. 2017). Group, Market Regulation Enforcement, available at https://www.cmegroup.com/market-regulation/
12. 17 CFR § 1.52. enforcement.html (noting “[t]he Enforcement team takes on cases referred by Investigations, Data
13. CME Group, Market Regulation, available at https://www.cmegroup.com/market-regulation.html. Investigations, and Market Surveillance and attempts to resolve such matters through a settlement”).
14. CME Group, Market Regulation, available at https://www.cmegroup.com/market-regulation/ 17. CME Group, Market Regulation Enforcement, available at https://www.cmegroup.com/market-
investigations.html (noting “[t]rade practice inquiries generally originate from one of three sources: regulation/enforcement.html (“[t]he Enforcement attorneys may issue warning letters instead of seek-
complaints; programmatic reviews of potential trade practice violations; and research performed by ing charges”).
Market Regulation Investigators. During the course of reviewing complaints, trade practice program 18. See generally, Chicago Mercantile Exchange, Inc., CME Rulebook 406.
output, and research, the Investigations team may request information from participants and firms”). 19. See generally, Chicago Mercantile Exchange, Inc., CME Rulebook 407 B.
15. Chicago Mercantile Exchange, Inc., CME Rulebook 432 L.1 (to fail to appear before the Board, Exchange 20. Id.
16 DCBA Brief April 2019ARTICLES
have been violated, and shall advise the respondent regarding
the submission of a responsive answer to each charge.”21 Once
issued, the respondent has 21 days to submit an answer.22 If the
respondent fails to provide an answer, the charges are deemed
admitted and market regulation proceeds to the BCC for a
determination of penalty.23
While the matter can settle at any point in the process,
after the PCC issues charges and the respondent answers them,
the trial process takes form and includes normal discovery and
pre-trial motions.24 However, the facts are not heard by a judge
or jury – rather, the five-member BCC hears the evidence
and makes a determination by a majority vote of guilt based
on a preponderance of evidence.25 If a trader or firm is found
guilty, “[i]n the absence of exceptional circumstances, as deter-
mined by the Hearing Panel Chair, the sanctioning phase shall
proceed immediately upon the conclusion of the evidence and
determination of the committee.”26 While the exchanges do not
have the authority to order a trader to a prison term, sanctions
can be serious, and the rules outline 18 potential outcomes,
ranging from a fine of $5 million per violation to expulsion of
membership.27
Conclusion
Whether Chicago will continue to serve as the world’s hub for
futures trading in a global electronic market remains to be
seen. However, as trading moves away from the open out-cry
system to the electronic platform, traders will inevitably try to
take advantage of any edge they can find – and as they become
more creative in their methodologies, it is certain regulators
are not too far behind.
21. Id.
22. See generally, Chicago Mercantile Exchange, Inc., CME Rulebook 407 C.
23. Id
24. See generally, Chicago Mercantile Exchange, Inc., CME Rulebook 408 B.2.
25. Id.
26. Id.
27. See generally, Chicago Mercantile Exchange, Inc., CME Rulebook 402 B.
DCBA Brief April 2019 17ARTICLES
Illinois Law Update
Editor Joseph K. Nichele
The Eighth Amendment’s Excessive Fines Clause is Post-Accident Photographs of Vehicles
Incorporated into the Fourteenth Amendment are Admissible Without Expert Testimony
and is Applicable to the States Peach v. McGovern, 2019 IL 123156
Timbs v. Indiana, 586 U.S. ___ (2019) Plaintiff sued after sustaining injuries in a rear-end motor
Timbs pled guilty to a drug offense and theft and was sentenced. vehicle accident. A jury found Defendant not liable. The
A civil forfeiture proceeding was brought against Timbs to appellate court reversed and remanded, holding that the
seize his Land Rover SUV (which cost $42,000) which was circuit court erred in allowing admission of post-accident pho-
alleged to have transported heroin. The SUV was not pur- tographs of the vehicles absent expert testimony.
chased with money used in the sale of drugs.
The Supreme Court ruled that post-accident photos of the
The case made its way to the Indiana Supreme Court which vehicles are relevant to the issue of proximate cause and injury.
reversed the court of appeals ruling, which found that the The Court reasoned that since jurors hear testimony from wit-
seizure of the SUV violated the Eighth Amendment’s Exces- nesses about the speed and force of impact, that a jury should
sive Fines Clause. The Indiana Supreme Court found that the be permitted to consider photos that depict the damage (or
Excessive Fines Clause only restrained federal action and is lack thereof) to the vehicles. It also reasoned that requiring
inapplicable to the states. an expert physician or automobile reconstruction engineer to
testify and explain evidence already understood by most jurors
The United States Supreme Court found that the Excessive imposes financial burdens on an already expensive process.
Fines Clause is applicable to the states. The Court traced the
history of the Clause to the Magna Carta, to the Virginia
Declaration of Rights, and then the Eighth Amendment. The Unnatural Accumulation of
Court also noted that when the Fourteenth Amendment was Snow was Open and Obvious
ratified, 35 of 37 States expressly prohibited excessive fines. Winters v. MIMG LII Arbors at Eastland,
Now, 50 States have such a constitutional provision. Thus, LLC, 2018 IL App (4th) 170669
the Court concluded that the “[p]rotection against excessive Plaintiff filed suit after he slipped and fell on a pile of snow.
punitive economic sanctions secured by the Clause is, to He alleged that the snow removal agency pushed snow from
repeat, both ‘fundamental to our scheme of ordered liber- the parking lot onto a sidewalk, causing the sidewalk to be
ty’ and ‘deeply rooted in this Nation’s history and tradition.” “blocked by a large mound of snow,” which forced him to “nav-
The Court also rejected Indiana’s argument that the Clause’s igate around the snow pile,” causing him to slip and fall in the
specific application to civil forfeitures is not fundamental or process due to the “unnatural accumulation of snow.”
deeply rooted.
18 DCBA Brief April 2019ARTICLES
The circuit court granted Defendants’ motions for summa- Plaintiff appealed and argued that the statute mandated the
ry judgment, holding that the large pile of snow and ice was garnishment of $172.00 from Defendant’s paychecks regard-
open and obvious, and that the deliberate encounter excep- less of the hardship. The appellate court recognized that until
tion (when the possessor of land has reason to expect that an 2007, Section 12-803 of the Code of Civil Procedure provided
invitee will proceed to encounter a known or obvious danger the “maximum” wage subject to collection under a deduc-
because a reasonable person in Plaintiff’s position would do so) tion order could not exceed 15% of the employee’s gross pay;
did not apply to the facts. Plaintiff knew there were multiple however, in 2007, the General Assembly enacted Public Act
ways to reach his destination and failed to show that a reason- 95-661 that eliminated the word “maximum.” The appellate
able person in his position would have found greater utility in court examined the legislative history of the new enactment
walking over the pile of snow rather than using an alternative and held the wage deduction provisions of the Code of Civil
path. Accordingly, the circuit court’s decision was affirmed. Procedure leave the trial court no discretion to deny a request
for a wage deduction order on grounds of extreme hardship. In
so ruling, the appellate court commended the trial court’s con-
A Wage Deduction Order Cannot sideration of the equities to determine to the amounts taken
Be Denied Based On Hardship from the debtor and suggested that the legislature consider
National College Collegiate Student Loan Trust 2004-1 amending the statute.
v. Deborah Ogunbiyi and Emmanuel Ogunbiyi, 2018 IL
App (1st) 170861
Plaintiff filed suit against Defendant after Defendant
defaulted on her student loan. A default judgment was en- About the Editor
tered against Plaintiff in the amount of $10,472.91. Defendant Joseph K. Nichele is a partner with Broida and
subsequently sent a wage deduction notice to her employer; Nichele, Ltd. where he concentrates his practice
however, Defendant persuaded the trial court that the wage in civil litigation. He received his undergraduate
deduction would impose an excessive hardship on her. The degree from Purdue University and his law degree
trial court entered an order dismissing the wage deduction from Valparaiso University School of Law.
proceeding against the employer and directed the employer
to cease all withholdings and release Defendant’s earnings
to her. Plaintiff subsequently filed a motion to vacate the
dismissal of the wage deduction complaint and the trial court
denied the motion.
DCBA Brief April 2019 19ARTICLES 20 DCBA Brief April 2019
News &
Events 22 InBrief
- By Terrence Benshoof
23 DCBA Update
- By Robert Rupp
24 ISBA Update
- By Kent A. Gaertner
26 Legal Aid Update
- By Cecilia Najera
29 DBF Dedicates New Memorial Plaque
31 New Offerings from the IICLE/DCBA ON Demand Site
32 Classifieds
34 Where to be with DCBANews & Events
InBrief
By Terrence Benshoof
April. Another baseball season opens in Hope, golf club in hand? Check out the at large of the Executive Board of the
Chicago. The city waits in joyous antici- May edition for the reviews, and see how Midwest Shelter for Homeless Veterans.
pation…of the last of the mounds of snow good a night it was for Legal Assistance.
from that “global warming” at the end of Did Director Nick Nelson grace the The ARDC has a new Chair, the DC-
January finally melting! The spring thaw adoring fans with his best shirtless Adam BA’s own Dave Rolewick. He’s been
is upon us! InBrief has almost thawed Levine impression? involved with the ARDC in numerous
out enough from that 26 below nonsense capacities over his legal career.
to be able to stop wearing a parka to work!
People Notes And the DCBA continues to be Super.
The 44th edition of Judges’ Nite has come Kent Gaertner has joined Matt Pfeiffer’s Joining the ranks of Super Lawyers:
and gone. If you didn’t attend, wait un- office in an of counsel capacity. He’ll con- Adrian Mendoza of Lillig & Thorsness,
til our May Brief to get the latest on the tinue his bankruptcy concentration. and Don Ramsell, Ramsell & Asso-
performance of DCBA President Matt ciates. In the Rising Star category. The
Pfeiffer. Did he sing? Did he dance? Did Terry Benshoof is now Chair of the Lillig office boasts DCBA vice-president
he do his best imitation of the late Bob Governance Committee and a member Kiley Whitty, and Angela Iaria.
22 DCBA Brief April 2019News & Events
DCBA Update
No Foolin’…DCBA is your CLE Solution
By Robert Rupp
Back in my January column, I wrote a conference facility that seats at least 30 is hosting “What am I missing? – A Town
about the Board’s decision to break with and could be used for a program, I would Hall on Diversity in the Legal Profes-
tradition and explore a year without a be excited to hear from you. sion.” This program will be moderated by
Mega Meeting. We have now come to Hon. Vince Cornelius and will feature
April and I feel obliged to report, having The DCBA Library on IICLE contin- a unique selection of speakers that will
been questioned by some, that no, this ues to grow, now offering over 60 hours challenge assumptions and provide prac-
was not a protracted April Fool’s joke. of free online CLE covering a wide tical advice and applicable solutions to
The winter came and went without a array of subject areas. Free DCBA improve your practice and professional
Mega Meeting, but the CLE offerings of online CLE through IICLE is a benefit relationships. On June 14th, the annual
the DCBA have never been stronger. As of DCBA membership. Enter the catalog Eleventh Hour PRMCLE seminar will
we rush towards the July MCLE report- through the portal on DCBA.org to take offer health and wellness subject matter
ing deadline for many of you, the DCBA advantage of the library whether you are to meet the requirements for that credit
is ready to provide you with the quality looking to earn a few credits at the dead- along with other timely issues related to
CLE you need and expect. line or are looking for an answer to a professional conduct.
question. It is always there for you.
In January and February, our Sections When you attend, view or present at these
hosted 21 (free) lunchtime MCLE In February, we launched the Joseph F. or any DCBA CLE programs, know that
programs that were attended by over Mirabella, Jr., Domestic Relations Trial you are doing far more than just earning
1,450 DCBA members. Our calendar Advocacy Program with a sold out pro- a credit to check a box. You are part of
is stacked through the July CLE report- gram providing 14 hours of lecture and a rich tradition that is constantly evolv-
ing deadlines, so I am certain there is at courtroom exercises over four weeks. ing and striving to improve the practice
least one program of interest to anyone Instructor and participant reviews were of law in our community. Thank you for
reading this. We look forward to seeing extremely positive, and we look forward that.
you at a program and buying you lunch! to repeating this program in cycle with
the Keith E. Roberts, Sr. Civil Law Trial
About the Author
Of the programs mentioned above, two Advocacy Program.
were held under the banner of our new
“On the Road” (OTR) CLE initiative that Finally, this year will be the first with
Robert Rupp is the Executive Director of
is taking free CLE to locations around new PRMCLE reporting requirements
the DuPage County Bar Association. He
the county. These are consistently filling calling for one hour of diversity pro- has worked in professional association
up, so if you see an OTR program of in- gramming and one hour of wellness pro- management since 1994, serving a variety
terest to you, it is smart to sign up early. gramming. In response to this, The CLE of national and international medical and
In May, we look forward to visiting the Committee has planned two showcase legal associations, including the American
offices of the DuPage Foundation with programs that will meet the full PRMCLE Bar Association.
an Estate Planning program. If you have requirement. On May 16th, the DCBA
DCBA Brief April 2019 23You can also read
