I need help to do a disclosure (before the Mock Hearing) at the Mr.Angel /Respondent using these information.

Fact Situation

The Law Society of Ontario (LSO) has brought an application alleging that David Angel, a

paralegal, failed to maintain books and records as required by By-law 9. The LSO also

asserted that the paralegal engaged in professional misconduct by failing to co-operate with

a Law Society investigation. The paralegal was licensed in 2015, has worked as a sole

practitioner, and has no prior discipline history.

The application stems from a complaint the LSO received from an individual who stated she

hired Mr. Angel to pursue investment opportunities in mortgages. The complainant stated: In

April and May of YR-00 she provided Mr. Angel with $50,000 for investment purposes, with

$2000.00 of that being for a personal load to Mr. Angel; She provided copies of cheques

made payable to Mr. Angel in trust;

She eventually received two cheques from an unknown individual ("X"), dated November

YR-00 related to the loans. Both cheques were NSF and copies were provided. She stated

that Mr. Angel now refuses to answer her phone calls or respond to messages. The LSO

authorized an investigation into this complaint on issues as to whether Mr. Angel may have

participated in improper fraudulent investment schemes, used his trust account for improper

purposes and failed to repay a personal loan. Theresa Clarke was assigned the

investigation

Important note:

1) Based on this Notice make a defense for Mr. Angel

2) A clear and concise overview of the witnesses, testimony and physical evidence to

present, stating how each will help prove the case; try to recount the story without

naming which witnesses will tell what information

Mention of the burden of proof (the amount of evidence needed to prove a fact) and

who has it in this case

HEARING DIVISION

NOTICE OF APPLICATION

CONDUCT

To the respondent:

The Law Society of Ontario applies under s. 34(1) of the Law Society Act, RSO 1990,c.L.8

for a determination of whether you have contravened s.33 by engaging in professional

misconduct and/or conduct unbecoming a licensee and for an order under s.35. Details of

the allegations are set out below. This Notice of Application is served together with an

Information Sheet that sets out the next steps in the proceeding.

Additional Information:

Mr. Angels has not provided the following the items:

Mr. Angel's general and trust account bank statements from June YR-00 to May YR-01

including images of the instruments received and disbursed.

Letters from the bank confirming that Mr. Angel's trust account was closed and its balance at closing.

Explanation of L's involvement in the matter, his mailing address, e-mail address and phone number.

Explanation as to how the funds were used.

The related supporting documents for repayments made to the complainant, if any, when

and if such repayments were made. Five days prior to the hearing, Mr. Angel informs you

that he would like to voluntarily admit that he engaged in professional misconduct for failing

to maintain books and records

Mrs. Clarke witness. Will say

Ms. Clarke will be expected to speak about

Ben will say

Ben will speak about his communication with Ms. Clarke. When correspondence was received, how it was received, and what was requested. He will also speak on his interactions with Mr. Angel and communications between the two of them.

"for a period of six months, Mr Angel provide to the monitoring and enforcement department of the Society on a monthly basis, by no later than the 25thof each month, a copy of his monthly trust comparisons, client trust listings, trust reconciliations and trust bank statements."

Mr Angel agrees to this undertaking If there needs to be a fine, a conditional fine of $2,000 payable ONLY if Mr Angel fails to comply with the requirement to rehabilitate his book keeping

Law Society of Upper Canada v. Cherif Rafik Ghobrial, 2014 ONLSHP 5 (CanLII)

Law Society of Ontario v. Shaw, 2022 ONLSTH 31 (CanLII)

Law Society of Upper Canada v. Jay Rudolph Bradley, 2014 ONLSHP 23 (CanLII)

These are the 3 case laws we will be relying on. Please make sure they are mentioned in our disclosure. the statutes are

Law Society Act, RSO 1990, c L.8 s. 42(2)

Paralegal rules of conduct rule 7.02(1)

The Law society act statute does not give an investigator to visit our client's home address. And the paralegal rules of conduct 7.02(1) is about communicating only with the representative of a party

and the law society rules of practice and procedure.