Whether the Hearing Board's and the Review Board's Recommendation and Report violated Petitioner's due-process rights

QUESTIONS PRESENTED 1. In an attorney disciplinary matter in which charges against an attorney must be proven by clear and convincing evidence, and without any substantive evidence of misconduct presented, whether the Hearing Board’s and the Review Board’s Recommendation and Report (collectively “the Board” and “the Report”) violated Petitioner’s rights as set forth in the Due Process Clauses of the Fourteenth Amendment to the U. S. Constitution and Article 1§2 of the Illinois Constitution. The Fourteenth Amendment Due Process Clause states: “nor shall any State deprive any person of life, liberty, or due process of law.” (a) Whether the Administrator’s enhancement of a new Rule 8.2(a) violation— when one did not exist in the initial federal district court’s citation or suspension order—in the one-count complaint against the Petitioner violated Petitioner’s Fourteenth Amendment due process rights. (b) Whether the Board’s denial of Petitioner’s request for a four-day hearing to present Petitioner’s evidence, and instead only allowing for two-day hearing, violated Petitioner’s Fourteenth Amendment due process rights. (©) Whether the Board’s exclusion of Petitioner’s exhibits during the hearing, including but not limited to the federal u court reporter’s certified transcripts of court proceedings, violated Petitioner’s Fourteenth Amendment due process rights. (d) Whether the Board’s denial of Petitioner’s March 14, 2021 Motion for Leave to Add Character Witness, Officer of Consulate General of Turkey pursuant to ARDC Rule 253(©), for mitigation at her hearing, as well as exclusion of the disclosed expert witness, Dr. Michael Fields, from testifying in his capacity as an expert, and instead allowing him to testify only as acharacter witness, violated Petitioner’s Fourteenth Amendment due process rights. 2. The Equal Protection Clause of the Fourteenth Amendment to the U.S. Constitution provides protection to every individual, including attorneys, and prohibits states from treating individuals differently based on certain characteristics without a valid justification. The Equal Protection Clause states: “No State shall deny to any person within its jurisdiction the equal protection of the laws.” This clause has been interpreted by courts to ensure that individuals are treated equally by the government and that laws do not discriminate against people based on characteristics such as race, gender, religion, or national origin. Whether the Boards’ Report violated Petitioner’s rights under Equal Protection Clause of the Fourteenth Amendment to the U.S. Constitution and Article 1§2 of the Illinois Constitution when it imposed suspension rather than censure or reprimand, per Rule 108(a) and/or did not allow an ARDC Rule 56 diversion program, for the eligible Petitioner. 3. The First Amendment to the United States Constitution protects the freedom of speech, religion, and the press, as well as the right to assemble and petition the government for redress of grievances. These protections apply to individuals, including attorneys, and prohibits the government from abridging their freedom of speech or other constitutional rights. Whether the Boards’ Report (affirmed by the Illinois Supreme Court) violated Petitioner’s rights under the First Amendment to the U.S. Constitution and of Article 1§4 (Freedom of Speech) and Article 1§5 of the Illinois Constitution (Right to Petition and to Apply for Redress of Grievances). Illinois Rules of Professional Conduct 8.2(a), 3.5(d) and 8.4(d), as applied, are unconstitutional, restricting attorney speech and in so doing imposing a chilling effect.