Preview
FILED
PER ATTY 7/31/2023 4:31 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Christi Undewvood DEPUTY
DC-23-1 0843
CAUSE NO:
95th
IN RE: § IN THE DISTRICT
CHRISTOPHER L. GRAHAM § COURT 1N AND FOR
Petitioner § DALLAS COUNTY, TEXAS
VERIFIED PETITION FOR REINSTATEMENT
STATE BAR OF TEXAS
TO THE HONORABLE JUDGE OF SAID COURT:
Comes now, Christopher L. Graham, “Petitiorier”, and presents this Petition for
Reinstatement as a lawyer licensed by the State of Texas, and would show as follows;
1. This verified Petition for Reinstatement is brought pursuant to Part H, Section 11.02 of the
Texas Rules of Disciplinary Procedure. Petitioner is eligible to bring this petition as more than
five years have passed since Petitioner’s Judgment of Disbarment, 29 November, 2017.
Petitioner’s disbarment was not by reason of conviction of or having been placed on probation
without an adjudication of guilt for any crime. Venue here is proper because Dallas County is the
county of Petitioner’s residence.
2. The Petitioner sets forward the foliowing information;
A. Petitioner’s full name is Christopher L. Graham, his date of birth is
04, December 1980, and he resides at 1104 Rio Verde Drive, DeSoto, Texas
75115.
Petitioner was first licensed in the State of Texas in 2005, and was subject to
Judgment of Disbartnent on 29 November, 2017, based upon a finding of
Professional Misconduct as defined in Rule 1.06(w) of the Texas Rules of
Disciplinary Procedure by violating Texas Disciplinary Rules of Professional
Conduct 3.03(a)(1), 8.02(a) and 8.04(a)(3). Specifically, Petitioner’s Professional
Misconduct was found to have included duplicative and excessive filing for court-
appointed attorney ’3 fees for criminal defendants in Dallas County, and for making
a statement on a Motion to Recuse a Dallas County Criminal Judge with reckless
disregard as to its truth or falsity concerning the qualifications or integrity of the
Judge, which have been found facially insufficient as a matter of law.
This Disciplinary Proceeding took place in the 193rd Judicial District Court of
Dallas County, Texas, and was before the Honorable Jefferson Moore, in Cause No.
DC-16—13821.
Full restitution for fines, costs and interest has been made to the State Bar of Texas
on 6 July, 2023, by Cashier’s Check in the amount of $32,344.31, delivered to the
Austin Regional Office of the Chief Disciplinary Counsel, 1414 Colorado Street,
Austin, Texas 78701, 512-427-1350.
At the time of the filing of this Petition the Petitioner is of good moral character,
and he possesses the mental and emotional fitness to practice law, and during the
preceding five years Petitioner has been living a life of exemplary conduct.
Petitioner has recently read and understands the Texas Disciplinary Rules of
Professional Conduct and the Texas Lawyer’s Creed-A Mandate for
Professionalism, and has a current knowledge of the law. The public and profession
will be served by the petitioner’s reinstatement.
From the date of Petitioner’s disbarment, he has had no outside employment, as he
has spent his time taking care of his sick mother. Petitioner has assisted his father,
Calvin Graham, in his work in real estate projects.
From the date of Petitioner’s disbarment, he has continued to reside at 1104 Rio
Verde Drive, DeSoto, Texas 75115. His landlord is CBAX PM LLC, 2555 Ridge
Road, # 150, Rockwall, Texas 75087, phone (972) 922-5622.
From the date of Petitioner’s disbarrnent, he has been involved in one civil action:
CC-19-05792-C, County Court at Law No. 3, Dallas County, styled Compton v.
LGI et al, which was a suit brought against Petitioner and his former company for
alleged unpaid private investigative fees. A judgment was obtained against
Petitioner.
From the date of Petitioner’s disbarment there has been no matter pending at
any time involving the prosecution of Petitioner for any crime, felony or
misdemeanor.
From the date of Petitioner’s disbarment Petitioner has made no application for a
license requiring proof of good moral character for its procurement.
L. From the date of Petitioner’s disbarment, the Petitioner’s standing as a member of
other state bar associations has been subject to reciprocal disbarment:
1. The State Bar of California
845 South Figueroa Street
Los Angeles, Califomia 90017
(213) 765-1000;
2. The State Bar of Illinois
Once Prudential Plaza
130 East Randolph Drive, Suite 1500
Chicago, Iilinois 60601-6219
(312)565-2600; (800)826-8625; and
3. The State Bar of New York
Third Judicial District
Attorney Grievance Committee
286 Washington Avenue Extension, Suite 200
Aibany, New York 12203
(518) 285-8350
M. Since the date of Petitioner’s disbarment there has been no allegation or charge,
formai or informal, of fraud on the part of Petitioner.
N. Petitioner knows and understands that it is his duty to amend and keep current all
information in this Petition until it is heard and determined by the triai court.
Petitioner knows and understands that the has the burden of establishing by a
preponderance of the evidence that the best interests of the public and the
profession, as weil as the ends ofjustice, would be served by his reinstatement, and
that the Court shall deny his Petition if it is found to contain any false statement of
a material fact or if Petitioner fails to meet his burden of proof.
Petitioner shall serve notice of this Petition for Reinstatement by U.S. Certified
Mail, Return Receipt Requested, on the Chief Disciplinary Counsel, and he shall
publish the notice as a paid classified announcement in the Texas Bar Journal.
Petitioner knows and understands that in determining Petitioner’s fitness for
reinstatement, in addition to any other relevant matters, the trial Court may
consider:
1. Evidence concerning the nature and degree of Professional
Misconduct for which Petitioner was disbarred and the
circumstances surrounding the misconduct.
2. Petitioner‘s understanding of the serious nature of the acts for which
he was disbarred.
3. Petitioner’s conduct during the Disciplinary Proceedings;
4. The profit to Petitioner and the hardship to others;
5. Petitioner’s attitude toward the administration of justice and the
practice of law.
6. Petitioner’s good works and other accomplishments.
7. Any other evidence relevant to the issues of Petitioner ’5 fitness to
practice law and the likelihood that Petitioner will not engage in
further misconduct.
WHEREF ORE, PREMISES CONSIDERED, Petitioner prays that this Honorable Court
set this matter for a hearing to afford Petitioner the opportunity to shoulder his burden of proof as
to the material elements of this Petition, and that the best interests of the public and the profession,
as well as the ends ofj ustice, will be served by the Court rendering judgment authorizing Petitioner
to be reinstated upon his compliance with Rule 11 of the Rules Governing Admission to the Bar
of Texas in efi'ect as of the date upon which judgment authorizing reinstatement is entered herein.
Respectfully submitted,
ROBERT C. HINTON, JR.
SBOT# 09710800
3300 Oak Lawn Ave.
Suite 700
Dallas, Texas 75219
(214) 213-9300
Hinton.law@airmail.net
ATTORNEY FOR PETITIONER GRAHAM
STATE OF TEXAS )(
)(
COUNTY OF DALLAS )(
BEFORE ME, the undersigned Notary Public, on this day personally appeared Christopher
L. Graham, who, being by me duly sworn on his oath and stated the following:
“My name is Christopher L. Graham. I am the Petitioner in the
foregoing Petition for Reinstatement State Bar of Texas and I hereby state
that all of the factual allegations contained therein are true and correct.”
47/7”
CHRISTOPHER L/GRAHAM
SUBSCRIBED AND SWORN to before me this the 3 [5+ day of
3; (L4 20713.
_J
ROBBIE JOHNSON
My Notary ID # 864167
Expires April 16, 2025
{WW
NOTARY PUBLIC, IN AND FOR
THE STATE OF TEXAS
CERTIFICATE OF SERVICE
I, undersigned counsel, hereby certify a true and correct copy of the foregoing Petition
was served via United States Mail, Certified Mail and Regular Mail, upon:
Seana Willing
Chief Disciplinary Counsel
State Bar of Texas
1414 Colorado Street
Austin, Texas 78701
WM . .
RbeERT C. HINTON, JR 29%
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FILED PER ATTY 7/31/2023 4:31 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Christi Undewvood DEPUTY DC-23-1 0843 CAUSE NO: 95th IN RE: § IN THE DISTRICT CHRISTOPHER L. GRAHAM § COURT 1N AND FOR Petitioner § DALLAS COUNTY, TEXAS VERIFIED PETITION FOR REINSTATEMENT STATE BAR OF TEXAS TO THE HONORABLE JUDGE OF SAID COURT: Comes now, Christopher L. Graham, “Petitiorier”, and presents this Petition for Reinstatement as a lawyer licensed by the State of Texas, and would show as follows; 1. This verified Petition for Reinstatement is brought pursuant to Part H, Section 11.02 of the Texas Rules of Disciplinary Procedure. Petitioner is eligible to bring this petition as more than five years have passed since Petitioner’s Judgment of Disbarment, 29 November, 2017. Petitioner’s disbarment was not by reason of conviction of or having been placed on probation without an adjudication of guilt for any crime. Venue here is proper because Dallas County is the county of Petitioner’s residence. 2. The Petitioner sets forward the foliowing information; A. Petitioner’s full name is Christopher L. Graham, his date of birth is 04, December 1980, and he resides at 1104 Rio Verde Drive, DeSoto, Texas 75115. Petitioner was first licensed in the State of Texas in 2005, and was subject to Judgment of Disbartnent on 29 November, 2017, based upon a finding of Professional Misconduct as defined in Rule 1.06(w) of the Texas Rules of Disciplinary Procedure by violating Texas Disciplinary Rules of Professional Conduct 3.03(a)(1), 8.02(a) and 8.04(a)(3). Specifically, Petitioner’s Professional Misconduct was found to have included duplicative and excessive filing for court- appointed attorney ’3 fees for criminal defendants in Dallas County, and for making a statement on a Motion to Recuse a Dallas County Criminal Judge with reckless disregard as to its truth or falsity concerning the qualifications or integrity of the Judge, which have been found facially insufficient as a matter of law. This Disciplinary Proceeding took place in the 193rd Judicial District Court of Dallas County, Texas, and was before the Honorable Jefferson Moore, in Cause No. DC-16—13821. Full restitution for fines, costs and interest has been made to the State Bar of Texas on 6 July, 2023, by Cashier’s Check in the amount of $32,344.31, delivered to the Austin Regional Office of the Chief Disciplinary Counsel, 1414 Colorado Street, Austin, Texas 78701, 512-427-1350. At the time of the filing of this Petition the Petitioner is of good moral character, and he possesses the mental and emotional fitness to practice law, and during the preceding five years Petitioner has been living a life of exemplary conduct. Petitioner has recently read and understands the Texas Disciplinary Rules of Professional Conduct and the Texas Lawyer’s Creed-A Mandate for Professionalism, and has a current knowledge of the law. The public and profession will be served by the petitioner’s reinstatement. From the date of Petitioner’s disbarment, he has had no outside employment, as he has spent his time taking care of his sick mother. Petitioner has assisted his father, Calvin Graham, in his work in real estate projects. From the date of Petitioner’s disbarment, he has continued to reside at 1104 Rio Verde Drive, DeSoto, Texas 75115. His landlord is CBAX PM LLC, 2555 Ridge Road, # 150, Rockwall, Texas 75087, phone (972) 922-5622. From the date of Petitioner’s disbarrnent, he has been involved in one civil action: CC-19-05792-C, County Court at Law No. 3, Dallas County, styled Compton v. LGI et al, which was a suit brought against Petitioner and his former company for alleged unpaid private investigative fees. A judgment was obtained against Petitioner. From the date of Petitioner’s disbarment there has been no matter pending at any time involving the prosecution of Petitioner for any crime, felony or misdemeanor. From the date of Petitioner’s disbarment Petitioner has made no application for a license requiring proof of good moral character for its procurement. L. From the date of Petitioner’s disbarment, the Petitioner’s standing as a member of other state bar associations has been subject to reciprocal disbarment: 1. The State Bar of California 845 South Figueroa Street Los Angeles, Califomia 90017 (213) 765-1000; 2. The State Bar of Illinois Once Prudential Plaza 130 East Randolph Drive, Suite 1500 Chicago, Iilinois 60601-6219 (312)565-2600; (800)826-8625; and 3. The State Bar of New York Third Judicial District Attorney Grievance Committee 286 Washington Avenue Extension, Suite 200 Aibany, New York 12203 (518) 285-8350 M. Since the date of Petitioner’s disbarment there has been no allegation or charge, formai or informal, of fraud on the part of Petitioner. N. Petitioner knows and understands that it is his duty to amend and keep current all information in this Petition until it is heard and determined by the triai court. Petitioner knows and understands that the has the burden of establishing by a preponderance of the evidence that the best interests of the public and the profession, as weil as the ends ofjustice, would be served by his reinstatement, and that the Court shall deny his Petition if it is found to contain any false statement of a material fact or if Petitioner fails to meet his burden of proof. Petitioner shall serve notice of this Petition for Reinstatement by U.S. Certified Mail, Return Receipt Requested, on the Chief Disciplinary Counsel, and he shall publish the notice as a paid classified announcement in the Texas Bar Journal. Petitioner knows and understands that in determining Petitioner’s fitness for reinstatement, in addition to any other relevant matters, the trial Court may consider: 1. Evidence concerning the nature and degree of Professional Misconduct for which Petitioner was disbarred and the circumstances surrounding the misconduct. 2. Petitioner‘s understanding of the serious nature of the acts for which he was disbarred. 3. Petitioner’s conduct during the Disciplinary Proceedings; 4. The profit to Petitioner and the hardship to others; 5. Petitioner’s attitude toward the administration of justice and the practice of law. 6. Petitioner’s good works and other accomplishments. 7. Any other evidence relevant to the issues of Petitioner ’5 fitness to practice law and the likelihood that Petitioner will not engage in further misconduct. WHEREF ORE, PREMISES CONSIDERED, Petitioner prays that this Honorable Court set this matter for a hearing to afford Petitioner the opportunity to shoulder his burden of proof as to the material elements of this Petition, and that the best interests of the public and the profession, as well as the ends ofj ustice, will be served by the Court rendering judgment authorizing Petitioner to be reinstated upon his compliance with Rule 11 of the Rules Governing Admission to the Bar of Texas in efi'ect as of the date upon which judgment authorizing reinstatement is entered herein. Respectfully submitted, ROBERT C. HINTON, JR. SBOT# 09710800 3300 Oak Lawn Ave. Suite 700 Dallas, Texas 75219 (214) 213-9300 Hinton.law@airmail.net ATTORNEY FOR PETITIONER GRAHAM STATE OF TEXAS )( )( COUNTY OF DALLAS )( BEFORE ME, the undersigned Notary Public, on this day personally appeared Christopher L. Graham, who, being by me duly sworn on his oath and stated the following: “My name is Christopher L. Graham. I am the Petitioner in the foregoing Petition for Reinstatement State Bar of Texas and I hereby state that all of the factual allegations contained therein are true and correct.” 47/7” CHRISTOPHER L/GRAHAM SUBSCRIBED AND SWORN to before me this the 3 [5+ day of 3; (L4 20713. _J ROBBIE JOHNSON My Notary ID # 864167 Expires April 16, 2025 {WW NOTARY PUBLIC, IN AND FOR THE STATE OF TEXAS CERTIFICATE OF SERVICE I, undersigned counsel, hereby certify a true and correct copy of the foregoing Petition was served via United States Mail, Certified Mail and Regular Mail, upon: Seana Willing Chief Disciplinary Counsel State Bar of Texas 1414 Colorado Street Austin, Texas 78701 WM . . RbeERT C. HINTON, JR 29%