CO20151176:

1. It is alleged that Catherine Stark represented to lawyer T that she had $1M in trust when she knew or ought to have known that the representation was not true and that such conduct is deserving of sanction;
2. It is alleged that Catherine Stark executed an Acknowledgement of an Assignment that she knew or ought to have known contained false representations and that such conduct is deserving of sanction;
3. It is alleged that Catherine Stark breached undertakings given to lawyer T in releasing funds to her client and that such conduct is deserving of sanction;
4. It is alleged that Catherine Stark represented to a Complaints Resolution Officer employed by the Law Society that she had $400,000 in trust when she knew or ought to have known that the representation was not true and that such conduct is deserving of sanction;
5. It is alleged that Catherine Stark represented to lawyer M that she had $400,000 in trust when she knew or ought to have known that the representation was not true and that such conduct is deserving of sanction;
6. It is alleged that Catherine Stark represented to lawyer M that she was holding $400,000 cash on behalf of her client when she did not know whether the representation was true and that such conduct is deserving of sanction;
7. It is alleged that Catherine Stark represented to the Law Society investigators that she had $400,000 cash in a safe located in her office when she knew or ought to have known that the representation was not true and that such conduct is deserving of sanction;
8. It is alleged that Catherine Stark deposited funds to her trust account from her client’s company for no legal purpose and immediately disbursed those funds to her client and that such conduct is deserving of sanction;
   CO20143116:
9. It is alleged that Catherine Stark acted while in a conflict or potential conflict of interest without obtaining her clients’ consent or in circumstances where it was not in the best interests of her clients that she do so, and that such conduct is deserving of sanction;
10. It is alleged that Catherine Stark failed to conscientiously serve her lender clients and that such conduct is deserving of sanction;
11. It is alleged that Catherine Stark failed to be candid with her client and that such conduct is deserving of sanction;
12. It is alleged that Catherine Stark breached the Law Society accounting rules and that such conduct is deserving of sanction;
13. It is alleged that Catherine Stark failed to be candid with the Law Society and that such conduct is deserving of sanction;
14. It is alleged that Catherine Stark failed to properly supervise her support staff and that such conduct is deserving of sanction;
15. It is alleged that Catherine Stark failed to respond promptly and completely to communication from the Law Society and that such conduct is deserving of sanction;
    CO20161198
16. It is alleged that Catherine Stark acted while in a conflict or potential conflict of interest without obtaining her clients’ consent or in circumstances where it was not in the best interest of her clients that she do so, and that such conduct is deserving of sanction;
17. It is alleged that Catherine Stark failed to conscientiously serve her lender client and that such conduct is deserving of sanction;
18. It is alleged that Catherine Stark falsely signed a personal guarantee as a witness to a client’s signature, and falsely signed a certificate of notary public, and that such conduct is deserving of sanction; and
19. It is alleged that Catherine Stark failed to respond promptly and completely to communication from the Law Society and that such conduct is deserving of sanction.