July 2026

DISBARMENT

Charles Aghoian

State Bar #129988, Northridge (May 3, 2026)

Aghoian was summarily disbarred.

He earlier pled guilty to distributing child pornography (18 U.S.C. §§ 2252A(a)(2)(A) and (b)(1))--a felony involving moral turpitude.

The State Bar Court recommended disbarment after receiving evidence that the conviction was not appealed and had become final.

John Charles Eastman

State Bar #193726, Salinas (May 15, 2026)

Eastman was disbarred after appealing the hearing judge's recommendation of disbarment, following a disciplinary trial that lasted 34 days.

The misconduct alleged related to Eastman's actions between October 2020 and January 2021 surrounding his representation of President Donald Trump and his campaign during the 2020 presidential election.

The State Bar Court panel telegraphed its findings--and the profundity of the proceeding--by including in the introductory paragraph of its 102-page opinion: "In this disciplinary matter, we consider the appropriate discipline to recommend to the California Supreme Court when an attorney, who has sworn to uphold the laws and constitutions of the State of California and the United States, attempts to actively undermine the results of an election to the most powerful office in the United States with the goal of delaying or invalidating the lawful installation of his client's electoral opponent and thereby keep his client in office."

The panel then affirmed the hearing judge's findings of culpability on 10 of the 11 counts originally charged. Eastman's wrongdoing included: failing to uphold the law by conspiring with President Donald Trump and others to obstruct the electoral count on January 6, 2021 (18 U.S.C. § 371), seeking to mislead the U.S. Supreme Court by intervening in a case, seeking to mislead a U.S. district court by filing a verified complaint, and seven counts of making multiple misrepresentations to former Vice-President Michael Pence, his counsel and to the general public--misconduct involving moral turpitude.

Eastman raised several issues on review, claiming his due process rights were violated because the trial proceeding lacked an impartial adjudicator; he was unable to compel testimony of out-of-state witnesses and refused an opportunity to substitute witnesses; and bias occurred in the conduct of his trial. The panel, however, found no due process violation occurred. It rejected Eastman's characterization of his case as "the most politicized disbarment proceeding in California's history" by deeming his claims to be "speculative and conclusory."

Gleaning facts based on the trial testimony, documentary evidence, stipulated facts, and the hearing judge's factual and credibility findings, the disciplinary opinion included copious documentation--including excerpts from Eastman's email correspondence and President Trump's tweets.

The count related to misleading the court was based on a complaint Eastman had helped draft that was filed in Texas and alleged that Georgia, Michigan, Pennsylvania, and Wisconsin had unconstitutionally administered the 2020 presidential election and urging that any electoral college votes cast by those states should not be counted. The U.S. Supreme Court dismissed the complaint for lack of standing, but in the days between the filing and dismissal, Eastman filed a motion to intervene to file a bill of complaint on behalf of President Trump

The intervention motion adopted the allegations in the Texas complaint--including that the states had engaged in "rampant lawlessness" arising out of unconstitutional acts that cast "outcome-determinative numbers of electoral votes." The court found Eastman knew the statements to be false and misleading. In fact, he had written in an email to an attorney tasked to recruit people to handle potential election challenges, that "it would be nice to have actually hard documented evidence of the fraud in the areas to which the analyses pointed." The motion also contained references to related cases that had actually been dismissed, and the court concluded that "Failure to disclose pertinent information presumes a intent to mislead the court."

An action filed in Georgia alleged that election officials there permitted several categories of unqualified individuals to vote--and claimed that the officials had removed "suitcases of ballots from under a table where they had been hidden, and processed those ballots without open viewing" in contravention of election laws. The evidence showed the allegations had previously been challenged by numerous experts, as well as an attorney in the Office of White House Counsel, and the found that Eastman made them knowing them to be false, with the intent to deceive the federal district court.

Eastman raised a number of arguments on appeal--including a "division of labor" defense, in which he claimed that his co-counsel was actually responsible for the factual allegations; the court found this unpersuasive. He also explained that his lack of due diligence was because he was busy and at times, "drinking from a fire hose." The court concluded that was "not an appropriate defense to a charge of misleading a court by knowingly presenting a false statement or concealing material information."

An additional seven counts focused on what the court deemed to be "various false and misleading assertions amounting to moral turpitude"--most concerning allegations of fraudulent and illegal tampering with the electoral process. Among them: that fraud occurred in the 2020 presidential election; that dead people voted; that electronic voting machines were used fraudulently to alter the elections results; and that former Vice-President Pence had the authority to delay the vote counting at issue. The court found Eastman had repeated the falsehoods "in his professional capacity as an attorney for President Trump in court filings and other written statements, as well as in conversations with others and in public remarks"--including in a televised statement to the crowd gathered at the Ellipse on January 6, 2021.

In aggravation, Eastman committed multiple acts of wrongdoing and demonstrated indifference toward rectifying or atoning for the consequences of his misconduct. He was also given limited aggravating weight for a lack of candor about whether he had exerted pressure to reject electors.

In mitigation, he presented several references attesting to his good character who had known him for a long time and understood the disciplinary charges against him. He was also allotted limited mitigating weight for cooperating in the investigation by stipulating to facts that were easy to prove. And was assigned nominal weight for practicing law discipline-free for 28 years--the weight reduced because Eastman "fails to recognize his ethical obligations and views any scrutiny of them as an attack on him."s

Pal Anthony Lengyel-Leahu

State Bar #147153, Tustin (May 3, 2026)

Lengyel-Leahu was disbarred. He was found culpable of committing seven acts of misconduct related to a single client case.

His wrongdoing included: appearing as an attorney without the required authority to do so, failing to maintain client funds in a trust account, failing to provide an accounting of client funds despite numerous requests from opposing counsel to do so, and two counts of failing to obey a court order. He was also found culpable of two counts involving moral turpitude: making a false statement of material fact in a legal proceeding, and misappropriating client funds.

In the underlying matter, Lengyel-Leahu represented one of two litigious factions in a religious parish that were in a dispute over whether to transition to the roman Catholic Church. A bishop eventually informed the priest who led the transition movement that he was excommunicated and stripped of his ordination.

Lengyel-Leahu became involved when an appellate court issued an opinion in a forcible detained action stating that his opponents had actual control over the group and the affiliated church property. However, Lengyel-Leahu later represented to a title company that he was "the attorney for the property owner," while knowing that was false. In related court proceedings, Lengyel-Leahu was ordered to "engage in a diligent search and reasonable inquiry" before concluding he did not possess the responsive documents requested. He failed to comply.

Lengyel-Leahu eventually received a check for just over $181,734 "in anticipation of future litigation," which he deposited into his client trust account. He did not inform the relevant parties in the action that he had received the funds, but subsequently issued a check for $180,000 from the trust account, payable to his brother-in-law, causing the account to dip to an impermissibly low level. Neither Lengyel-Leahu nor his brother-in-law had performed any services related to the funds received.

In aggravation, Lengyel-Leahu had a prior record of discipline, committed multiple acts of wrongdoing in the instant case, demonstrated indifference for the consequences of his misconduct, showed a lack of candor during his disciplinary proceeding, and caused significant financial harm to his client.

In mitigation, he received limited weight by entering into a stipulation of facts--most of which were easily provable.

Fari Bari Nejadpour

State Bar #216925, Beverly Hills (May 29, 2026)

Nejadpour was disbarred after being found culpable of eight counts of professional misconduct. He had appealed the hearing judge's findings and recommendation of disbarment, asserting that all counts against him should be dismissed. Upon independent review, the State Bar Court panel affirmed the findings of culpability, as well as the assessment of aggravation and mitigation in the matter.

His wrongdoing included: failing to report judicial sanctions imposed to the State Bar, soliciting another person to violate the State Bar Act, four counts of failing to disclose to clients that he had no professional liability insurance, and two counts of making material misrepresentations to the State Bar--misconduct involving moral turpitude.

Nejadpour filed a complaint alleging breach of contract against a former client. He was sanctioned after a judge determined he had filed an improper amended complaint that "significantly changed the original complaint," though he failed to report the sanction to the State Bar as required.

In a pivotal matter in the case, Nejadpour had been administratively suspended--and during that time, submitted a declaration to the State Bar asserting he did not practice law while suspended. Also during that time, Nejadpour hired an attorney to join his firm; that individual had no litigation experience, but was assure he could learn from the knowledgeable staff. The initial documents the new attorney drafted required substantial editing and reworking. A demand letter was sent with a disclosure in the signature block initially reading: "Nejadpour Law Firm, Instructed/Directed by F. Bari Nejadpour, Esq., but forwarded without signature to avoid delay." (The new attorney, who was unaware of Nejadpour's suspension, was demoted to a junior position in the firm, with a substantial cut in pay.) Opposing counsel then submitted a complaint to the State Bar, claiming Nejadpour had engaged in the unauthorized practice of law while suspended, as he had held himself out as an attorney in the demand letter. Investigators found that Nejadpour had urged the new attorney to write a declaration to the State Bar, falsely asserting that he, not Nejadpour, had personally signed the demand letter. It was also determined that Nejadpour had signed and file a bankruptcy petition in another case while administratively suspended.

An additional count charged Nejadpour with falsely representing to four clients that he had professional liability insurance when they engaged him.

In aggravation, Nejadpour had two prior records of discipline, committed multiple acts of misconduct in the instant case, demonstrated indifference toward rectifying for the consequences of his wrongful actions, and showed a lack of candor during his disciplinary proceedings.

In mitigation, he was allotted limited weight, both for cooperating in the State Bar's investigation by stipulating to easily proven facts and for good character testimony introduced by five character witnesses--several of whom the trial judge found to lack credibility.

James Andrew Pixton

State Bar #193263, Folsom (May 22, 2026)

Pixton was disbarred by default after he did not participate in the disciplinary hearing in which he was charged with two counts of failing to provide a substantive response to the allegations in the State Bar investigation.

He was found culpable of both counts.

The State Bar Court determined that all four factors for recommending disbarment had been satisfied in the matter--including proper service of the notice of charges, actual notice or reasonable diligence in notifying him of the proceedings before the default was entered, proper entry of the default, and factual allegations that support an order of discipline.

There were five additional investigations pending against Pixton, who also had one prior record of discipline, before he was disbarred in the present proceeding.

Ira Seltzer

State Bar #46225, Malibu (May 3, 2026)

Seltzer was disbarred by default after he failed to participate in the proceedings related to the disciplinary charges against him.

In an initial telephone call with State Bar representatives, Seltzer indicated that he did not intend to file a response to the charges but would otherwise cooperate with the Office of Chief Trial Counsel--though he failed to file substantive responses to six letters of inquiry he had received from investigators.

The State Bar Court determined that all procedural requirements had been met in the matter, and that Seltzer did not move to set aside or vacate the default entered against him.

As a result, the factual allegations in the charges were deemed admitted, and Seltzer was found culpable of all eight counts of professional misconduct they contained. His wrongdoing included: failing to deposit client funds in a trust account, failing to maintain a client trust account, improperly dividing legal fees, and failing to cooperate in the State bar's investigation of the misconduct alleged, and two counts of failing to promptly pay settlement funds to clients.

An additional two counts involved moral turpitude: misappropriating more than $127,178 in fund belonging to clients.

 Seltzer had four prior records of professional discipline when he was disbarred in the instant case.

SUSPENSION

Mehran David Alaei

State Bar #283273, Del Mar (May 22, 2026)

Alaei was suspended from practicing law for one year and placed on probation for two years after he stipulated to being convicted of attempting to induce false testimony (Cal. Penal Code §§ 664 and 137(a)). The offense is a crime involving moral turpitude, and the State Bar Court determined that it warranted professional discipline.

In the underlying matter, Alaei was "associated with" an individual who had been charged with committing lewd acts with a child, who was his minor daughter. A protective order was in place preventing the man from contacting either the girl or her mother. Alaei interceded, and contacted the other--promising her that she would get full custody of the girl if she agreed to have the girl refuse to testify against the father and to disclaim her prior accusation of abuse in a declaration instead that "she had been upset and that some of her statements were untrue."

After a three-day trial, a jury found Alaei culpable of attempting to induce false testimony.

In aggravation, Alaei had a prior record of discipline.

In mitigation, he entered into a pretrial stipulation and presented letters from eight individuals--all of whom attested to his good character.

Joseph Lawrence Dunn

State Bar #123063, Santa Ana (May 29, 2026)

Dunn was suspended for 30 days and placed on probation for one year.

Both he and the State Bar had appealed the hearing judge's findings of two counts of misconduct involving moral turpitude and one year stayed suspension. Dunn sought a dismissal of all charges; the State Bar argued that dismissed counts should be reinstated and sought an order imposing 60 days of actual suspension.

On appeal, the judge's findings of culpability and mitigation were affirmed, but 30 days of actual suspension was recommended as the appropriate discipline. Dunn was found culpable of making false and misleading representations and breaching his fiduciary duty to the State Bar Board of Trustees while acting as its executive director. Both counts involve moral turpitude.

Dunn held the position of executive director of the State Bar of California for 14 years, until he was terminated. At a regularly scheduled meeting of the board, to which he owed a fiduciary duty, Dunn explained that officials from Mongolian were working to reform its judicial system, and sought assistance in the task from the California State Bar. Shortly after that meeting, Dunn traveled to Mongolia, accompanied by a State Bar employee and former State Bar president who was then working as an attorney at a law firm. The State Bar was billed and paid $6,041.72 in airfare and telephone expenses for Dunn and the bar employee related to the trip.

After an article appeared in the Daily Journal stating that "no State Bar funds had been used" to support the Mongolia trip, which the bar's chief trial counsel believed Dunn knew to be false, she requested that the matter be referred to an oversight committee to request appointment of a special prosecutor, and also delivered an "improper activity memo" to HR and the executive overseeing it, detailing her concerns about funding and expense issues. Eventually, a third party was hired to investigate. It concluded that: "Dunn had failed to satisfy his contractual and fiduciary duties to provide complete and accurate disclosures," and recommended his termination. The majority of the board voted to terminate him. In response, Dunn sued the State Bar--and that matter was sent to arbitration, where several board members testified they recalled being assured that no State bar funds would be used to finance the trip. T12he arbitrator concluded that Dunn had "breached his duty to keep the board 'fully informed' and to 'safeguard and administer'" State Bar funds.

Unrelated to the funding issue, but relevant to Dunn's disciplinary matter, the "improper activity memo" had also alleged that, after meeting with members of the California Supreme Court staff who expressed concerns about supporting AB 852, Dunn did not inform the board of the skepticism, stating there was "no known opposition"--and instead, advocated board support of the bill. One count and some allegations in another count in the disciplinary charge related to that alleged misconduct were subsequently dismissed.

In mitigation, Dunn has been an active member of the bar since 1986--with fiduciary duties as a law practitioner and CEO for at least 20 years and presented testimony by seven individuals representing a range in the general and legal communities who attested to his good character. He was also allotted limited mitigating weight for performing community service where the level of his involvement was not detailed, as well as nominal weight for entering into a pretrial stipulation that was limited to a few easily proven facts.

Stanley Friedman

State Bar #30899, Windsor (May 14, 2026)

Friedman was suspended from the practice of law for 45 days and placed on probation for one year. He was found culpable of all three counts charged: disobeying a court order to pay sanctions, failing to uphold the law, and knowingly engaging in the unauthorized practice of law--misconduct involving moral turpitude.

Friedman admitted to culpability for two of the acts of professional misconduct, but argued that his actions did not involve moral turpitude. However, the State Bar Court noted that during the time Friedman was "well aware that he was ineligible to practice," he actually practiced law by filing legal documents in which he designated himself as an attorney." And it underscored: "The Review Department has repeatedly found moral turpitude in such circumstances,."

In aggravation, Friedman had a prior record of discipline.

In mitigation, he cooperated in the State Bar's investigation of the wrongdoing alleged and filed a pretrial stipulation.

Donald Charles Schwartz

State Bar #122476, Aptos (May 14, 2026)

Schwartz was suspended for two years and placed on probation for three years after he stipulated to committing two acts of professional misconduct--disobeying two separate court orders.

In both of the underlying matters, Schwartz was ordered to pay sanctions jointly and severally with the clients he represented--a total of nearly $172,000. In a status report filed with the State Bar Court related to one matter, Schwartz informed that he had filed for Chapter 13 bankruptcy, and that he owed PG&E more than $30,000 and had not made a mortgage payment "in many years."

Whie he did not appeal or pay the first sanction imposed, he did issue cashier's checks satisfying the sanctions imposed in the second matter; both checks were sent to the bankruptcy receiver's counsel.

In aggravation, Schwartz had three prior records of discipline; two of the orders in those cases included periods of actual suspension.

In mitigation, he entered into a pretrial stipulation, was suffering from financial hardship during the time of the misconduct, and provided letters from 13 individuals taken from a range in the legal and general communities--all of whom vouched for his good character.

PROBATION

Richard Gerard Cenci

State Bar #79863, Fresno (May 22, 2026)

Cenci was placed on probation for one year after he stipulated to committing nine acts of professional misconduct related to three client matters.

His wrongdoing included: failing to maintain complete records of funds received on behalf of clients and two counts of failing to maintain the required balance in his client trust account, as well as three counts each of failing to pay medical liens owed in client matters and grossly misappropriating client funds for his own purposes--misconduct involving moral turpitude.

Two of the cases involved similar fact patterns. Cenci represented clients in personal injury matters--executing agreements stating that he would provide immediate notice to medical providers of any proceeds received, promptly pay them in full, and then provide a full accounting. However, he failed to do so--instead depositing settlement proceeds into his client trust account, which he depleted by issuing 13 checks for his personal expenses, effectively misappropriating the funds. The healthcare providers eventually turned the matters over to a collection agency. Cenci satisfied both liens two days after receiving letters of inquiry from the State Bar--admitting to investigators that he had not kept ledger cards, monthly statements, or account reconciliations of the client money.

The third case also involved a personal injury client and an agreement to satisfy a medical lien, but in this situation, Cenci deposited settlement funds received into his operating account. He paid the medical lien only after being contacted by the collections agency--and subsequently admitted to State bar investigators that he had not kept the required financial records.

In aggravation, Cenci committed multiple acts of misconduct.

In mitigation, he had practiced law discipline-free for approximately 38 years, cooperated in the State Bar's investigation of the wrongdoing alleged, eventually paid the lienholders the funds they were due, and was also granted mitigating weight due to the State Bar's delay in prosecuting the matter.

--Barbara Kate Repa