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¶3 Attorney Bowe was admitted to
practice law in Wisconsin in 1980 and
practices in Milwaukee. In 1993 she was the
subject of a consensual private reprimand.
The misconduct at issue in that case
involved neglecting two matters for the same
client; failing to keep the client
reasonably informed; and making a
misrepresentation to the Board of Attorneys
Professional Responsibility. Private
Reprimand No. 1993-24 (electronic copy
available at https://compendium.wicourts.
gov/app/raw/000110.html). In 2011, Attorney
Bowe was publicly reprimanded for misconduct
consisting of failing to act with reasonable
diligence and promptness; failing to advise
the court of a jurisdictional defect; filing
a certificate of compliance with statutory
requirements which contained false
information; having ex parte communications
with the court; and making a false statement
to a tribunal. In re Disciplinary
Proceedings Against Bowe, 2011 WI 48, 334
Wis. 2d 360, 800 N.W.2d 367.
¶4 On January 22, 2020, the Office of
Lawyer Regulation (OLR) filed a complaint
alleging two counts of misconduct. Attorney
Bowe filed an answer on February 25, 2020.
On July 2, 2020, the OLR filed an amended
complaint which also alleged two counts of
misconduct. On July 3, 2020, the OLR and
Attorney Bowe filed a stipulation whereby
she agreed that the facts alleged in the
amended complaint formed a basis for the
imposition of a public reprimand. The
following facts are taken from the
stipulation and the amended complaint.
¶5 On December 6, 2016, L.W., Jr. was
charged with hiding a corpse in a Dodge
County case. The charge arose from the
death of S.D., L.W.'s girlfriend and his
first cousin. S.D.'s body was found in
L.W.'s vehicle, which was parked in the
garage of a house owned by L.W. in which
M.J., L.W.'s biological mother, resided.
¶6 On December 6, 2016, M.J. was
charged with harboring or aiding a felon
which was related to L.W.'s case.
¶7 On December 8, 2016, the circuit
court in L.W.'s criminal case ordered
conditions of his bond that included him
having no direct contact with M.J. or the
immediate family of the victim. In
addition, L.W. was to have no third-party
contact with those persons except through an
attorney or investigator.
¶8 On December 14, 2016, S.J., S.D.'s
biological father, filed a wrongful death
action against L.W. S.J. and M.J. are
biological siblings.
¶9 At the preliminary hearing in L.W.'s
criminal case, held on December 22, 2016,
the court found probable cause and bound
L.W. over for trial. An arraignment was
scheduled for February 15, 2017.
¶10 On January 20, 2017, the Dodge
County District Attorney filed an
Information in the L.W. case charging first-
degree intentional homicide-domestic abuse
modifier; hiding a corpse; incest; and two
counts of possession of a firearm by a
felon.
¶11 On February 14, 2017, Attorney Jason
Richard on behalf of S.J. and the estate of
S.D., filed a motion for a temporary
restraining order in the wrongful death
action restraining L.W. and/or his agents
from transferring or dissipating any of
L.W.'s assets, real or personal.
¶12 The arraignment in L.W.'s criminal
case was rescheduled several times and
ultimately was set for June 8, 2017.
¶13 On February 17, 2017, in the
wrongful death action, the circuit court
granted the temporary injunction restraining
L.W. and/or his agents from transferring or
dissipating assets for 90 days, with the
exception of allowing the expenditure of up
to $150,000 for legal fees. The circuit
court issued its findings of fact and
conclusions of law on February 24, 2017.
That meant the temporary injunction would
expire on or about May 25, 2017. Attorney
Richard did not request a hearing to renew
the temporary restraining order when it
expired.
¶14 On May 26, 2017, Attorney Bowe met
with L.W. at the Dodge County jail, at which
time L.W. and Attorney Bowe signed a
representation agreement. Attorneys Donna
Kuchler and Aaron Nelson had been
representing L.W. in his criminal case up to
that point.
¶15 On May 29, 2017, L.W. sent a letter
to Attorney Bowe in which he stated that the
statements by witnesses with respect to the
gun possession charges were "highly
inconsistent" and that DNA evidence on the
guns was "inconclusive." L.W. said the
charge of hiding a corpse was vague and
there was "no prelim or showing proof of any
probably cause to restrain his liberty."
L.W. also wrote there was "no standing for a
tenant or guest to override sole owner's
consent or challenge of a search" which
referred to M.J. and M.V., who were living
at the house owned by L.W., where M.J.
resided and where the corpse was found.
L.W. concluded the letter by saying that "A
good position we are in Ann is I am a Pre-
trial detainee held in violation of U.S.
Constitution. Pre-arraigned at that!"
¶16 On May 31, 2017, Attorney Bowe
deposited $149,397.81 into her trust
account. These were funds belonging to
L.W., which were obtained from Attorney
Kuchler.
¶17 On June 2, 2017, Attorney Bowe met
with L.W. at the Dodge County jail. During
that meeting L.W. signed a motion for
substitution of counsel, which substituted
Attorney Bowe and Attorney Michael Steinle
for Attorneys Kuchler and Nelson.
¶18 On June 3, 2017, at L.W.'s request,
Attorney Bowe wrote the following trust
account checks from L.W.'s funds:
M.J. (L.W.'s mother) $
3,000.00
M.J. (L.W.'s grandmother) $
1,000.00
D.M. (L.W.'s cousin) $
1,197.81
D.P. (D.M.'s daughter) $
200.00
S.J. (S.D.'s father)
$10,000.00
T.J. (S.D.'s mother) $
7,500.00
G.C. (L.W.'s friend) $
2,500.00
¶19 At the time Attorney Bowe wrote the
checks, she knew that S.J. and T.J. were
S.D.'s parents. S.J. and T.J. were
potential State witnesses. Attorney Bowe
also knew that M.J. was a co-defendant in a
criminal case and was a potential witness
against L.W. in his criminal case.
¶20 On June 3, 2017, L.W. telephoned
D.M. to ask him to pick up checks from
Attorney Bowe's law office. D.M. was out of
state at the time and instructed his
daughter, D.P., to go to Attorney Bowe's law
office to retrieve the checks. D.P. went to
Attorney Bowe's law office that day and
Attorney Bowe gave her checks made out to
D.P., D.M., S.J., and T.J. D.P. left the
check for T.J. at D.M.'s house and he
subsequently gave that check to T.J.
¶21 On June 3, 2017, L.W. also
telephoned G.C. to ask her to pick up checks
from Attorney Bowe's law office. G.C. went
to Attorney Bowe's law office that day and
Attorney Bowe gave her checks made out to
G.C., M.J., and M.J. (L.W.'s grandmother).
¶22 On June 8, 2017, a motion hearing
was held in L.W.'s criminal case, at which
time the circuit court dismissed Attorneys
Kuchler and Nelson and allowed Attorneys
Bowe and Steinle to serve as L.W.'s co-
counsel. The arraignment was rescheduled
for July 20, 2017.
¶23 On June 8, 2017, L.W. signed
Attorneys Bowe's and Steinle's fee
agreement. L.W. agreed to pay a flat fee of
$100,000 for representation in the criminal
case. Attorney Bowe wrote a trust account
check in the amount of $50,000, dated June
2, 2017, payable to Attorney Steinle for his
half of the flat fee.
¶24 On or about June 13, 2017, T.J.
notified the Dodge County District
Attorney's Office that she had received a
check for $7,500 from Attorney Bowe's law
office and that S.J. had received a similar
check for $10,000.
¶25 On June 27, 2017, Attorneys Bowe and
Steinle met with L.W. at the Dodge County
jail.
¶26 On July 10, 2017, Attorney Steinle
filed a motion to withdraw from representing
L.W., citing a breakdown in communication.
¶27 On July 14, 2017, the district
attorney filed an "other acts" motion and a
motion to disqualify Attorney Bowe in L.W.'s
criminal case based on a conflict of
interest likely to result in ineffective
assistance of counsel. The "other acts"
motion identified S.J., T.J., and M.J. as
State witnesses. In the motion, the
district attorney argued:
The transfer of large amounts of money
to
State witnesses is designed to influence
their testimony and their cooperation with
the State in its prosecution. It is most
telling that the mother and father of the
victim are in receipt of the largest sums of
money. The next largest documented amount
is to his mother who is a witness to the
events surrounding the homicide. All three
are witnesses against him.
¶28 On July 17, 2017, Attorney Steinle
was allowed to withdraw from representing
L.W.
¶29 On July 13, 2017, Attorney Bowe
wrote a trust account check payable to cash
for $250. L.W. had instructed Attorney Bowe
to deposit this amount into the account of
an incarcerated female friend. On July 17,
2017, Attorney Bowe wrote a trust account
check payable to cash for $5,000. On August
4, 2017, she wrote a trust account check
payable to cash for $2,500. The checks
totaled $7,500, which is the fee amount L.W.
and Attorney Bowe agreed that Attorney Bowe
had earned out of the $50,000 flat fee.
¶30 On July 20, 2017, a motion hearing
in L.W.'s criminal case was held, at which
time Attorney Bowe was provided copies of
the "other acts" motion and motion to
disqualify her. Attorney Bowe agreed to
withdraw from L.W.'s case, and the circuit
court allowed her to do.
¶31 In the stipulation, Attorney Bowe
agreed that her conduct in writing checks on
behalf of L.W. to potential state witnesses
carried a significant risk that her
representation of L.W. would be materially
limited by her personal interests.
¶32 By entering into the stipulation,
Attorney Bowe admitted the following counts
of misconduct alleged in the OLR's amended
complaint:
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