Matter of Elan

2025 NY Slip Op 00216 (Appellate Division Second Judicial Department 2025) · Appellate Division, Second Judicial Department · January 15, 2025 · No. 2024-00546

Summary

This Appellate Division, Second Department order imposes reciprocal discipline on attorney Evan Stuart Elan following his disbarment by the Virginia State Bar Disciplinary Board. The Virginia board revoked Elan's license due to multiple violations of professional conduct rules, including failing to communicate with a client, abandoning a lawsuit, and obstructing a disciplinary investigation by ignoring subpoenas. Upon review of the Virginia orders and Elan's failure to respond to the show cause order, the New York court ordered his immediate disbarment and stricken his name from the roll of attorneys.

Court
Appellate Division, Second Judicial Department
Writing for the Court
HECTOR D. LASALLE, P.J.; MARK C. DILLON, J.; COLLEEN D. DUFFY, J.; BETSY BARROS, J.; FRANCESCA E. CONNOLLY, J.
Jurisdiction
New York
Decision date
January 15, 2025
Docket number
2024-00546
Procedural posture
Reciprocal discipline proceeding after out‑of‑state revocation and failure to respond to order to show cause under 22 NYCRR 1240.13.
Precedential value
published
Disposition
other

Topics

appellate procedureappellate jurisdictionstandard of review

Practice areas

professional responsibilityattorney discipline

Questions Presented

  1. Whether the Appellate Division should impose reciprocal discipline (disbarment) on the respondent based on the Virginia revocation and his failure to respond to the New York order to show cause.

Holdings

  1. The court disbars the respondent, effective immediately, because the misconduct underlying the Virginia revocation and the respondent's failure to respond to the order to show cause justify reciprocal discipline.

Factual background

Evan Stuart Elan, a New York‑licensed attorney, repeatedly failed to communicate with a client, missed court appearances, and ignored a subpoena issued by the Virginia State Bar. The Virginia Board found violations of multiple Rules of Professional Conduct and revoked his Virginia license. He did not notify the New York Grievance Committee of the revocation and failed to respond to a New York order to show cause.

Procedural history

The Virginia State Bar Disciplinary Board revoked the respondent's Virginia law license. The New York Grievance Committee notified this Appellate Division, which issued an order to show cause. The respondent failed to respond, waiving defenses, and the court imposed disbarment.

Court Document

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