xavier becerra attorney general of california kent

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XAVIER BECERRA Attorney General of CaliforniaKENT D. HARRIS Supervising Deputy Attorney GeneralSTEPHANIE ALAMO-LATIF Deputy Attorney GeneralState Bar No. 283580 1300 I Street, Suite 125 P.O. Box 944255 Sacramento, CA 94244-2550

Telephone: (916) 210-6112 Facsimile: (916) 327-8643E-mail: [email protected]

Attorneys for Complainant

BEFORE THE PROFESSIONAL FIDUCIARIES BUREAU DEPARTMENT OF CONSUMER AFFAIRS

STATE OF CALIFORNIA

In the Matter of the Accusation Against: Case No. PF 2017-95

DAWN ELIZABETH AKEL 2228 Longport Ct., Suite 100Elk Grove, CA 95758 ACCUSATION

Professional Fiduciary License No. PF 138

Respondent.

PARTIES

1. Rebecca May (Complainant) brings this Accusation solely in her official capacity as

the Bureau Chief of the Professional Fiduciaries Bureau (Bureau), Department of Consumer

Affairs.

2. On or about August 4, 2008, the Bureau issued Professional Fiduciary License

Number PF 138 to Dawn Elizabeth Akel (Respondent). The Professional Fiduciary License was

in full force and effect at all times relevant to the charges brought herein and will expire on April

30, 2020, unless renewed.

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1 (DAWN ELIZABETH AKEL) ACCUSATION

mailto:[email protected]

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JURISDICTION/STATUTORY PROVISIONS

3. This Accusation is brought before the Bureau under the authority of the following

laws. All section references are to the Business and Professions Code (Code) unless otherwise

indicated.

4. Code section 118, subdivision (b), states:

“The suspension, expiration, or forfeiture by operation of law of a license issued by a board

in the department, or its suspension, forfeiture, or cancellation by order of the board or by order

of a court of law, or its surrender without the written consent of the board, shall not, during any

period in which it may be renewed, restored, reissued, or reinstated, deprive the board of its

authority to institute or continue a disciplinary proceeding against the licensee upon any ground

provided by law or to enter an order suspending or revoking the license or otherwise taking

disciplinary action against the licensee on any such ground.”

5. Code section 22, states:

“Board,” as used in any provision of this code, refers to the board in which the

administration of the provision is vested, and unless otherwise expressly provided, shall include

“bureau,” “ commission,” “committee,” “department,” “division,” “examining committee,”

“program,” and “agency.”


(a) A license shall expire one year after it was issued on the last day of the month in which

it was issued.

(b) A license may be renewed by filing a renewal application with the bureau, submitting

the annual statement required by Section 6561, submitting proof of the licensee's compliance with

the continuing education requirements of this chapter, and payment of the renewal fee set by the

bureau, provided that the licensee has not engaged in conduct that would justify the bureau's

refusal to grant the renewal. Acts justifying the bureau's refusal to renew a license shall include

any of the following:

(1) Conviction of a crime substantially related to the qualifications, functions, or duties of a

fiduciary.


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(2) Fraud or deceit in obtaining a license under this chapter.

(3) Dishonesty, fraud, or gross negligence in performing the functions or duties of a

professional fiduciary.

(4) Removal by a court as a fiduciary for breach of fiduciary duty if all appeals have been

taken or the time to file an appeal has expired.


(a) The bureau may upon its own, and shall, upon the receipt of a complaint from any

person, investigate the actions of any professional fiduciary, including a person with a license that

either restricts or prohibits the practice of that person as a professional fiduciary, including, but

not limited to, a license that is retired, inactive, canceled, or suspended. The bureau shall review a

professional fiduciary's alleged violation of statute, regulation, or the Professional Fiduciaries

Code of Ethics and any other complaint referred to it by the public, a public agency, or the

department, and may impose sanctions upon a finding of a violation or a breach of fiduciary duty.

(b) Sanctions shall include any of the following:

(1) Administrative citations and fines as provided in Section 125.9 for a violation of this

chapter, the Professional Fiduciaries Code of Ethics, or any regulation adopted under this chapter.

(2) License suspension, probation, or revocation.

(c) The bureau shall provide on the Internet information regarding any sanctions imposed

by the bureau on licensees, including, but not limited to, information regarding citations, fines,

suspensions, and revocations of licenses or other related enforcement action taken by the bureau

relative to the licensee.

8. Code section 6584, states, in pertinent part:

A license issued under this chapter may be suspended, revoked, denied, or other

disciplinary action may be imposed for one or more of the following causes:

…

(d) Fraud, dishonesty, corruption, willful violation of duty, gross negligence or

incompetence in practice, or unprofessional conduct in, or related to, the practice of a professional

fiduciary. For purposes of this section, unprofessional conduct includes, but is not limited to, acts


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contrary to professional standards concerning any provision of law substantially related to the

duties of a professional fiduciary.

…

(h) Violation of this chapter or of the applicable provisions of Division 4 (commencing with

Section 1400), Division 4.5 (commencing with Section 4000), Division 4.7 (commencing with

Section 4600), or Division 5 (commencing with Section 5000) of the Probate Code or of any of

the statutes, rules, or regulations pertaining to duties or functions of a professional fiduciary.

9. Probate Code section 4232, subdivision (a) states:

(a) An attorney-in-fact has a duty to act solely in the interest of the principal and to avoid

conflicts of interest.

10. Probate Code section 4233 states:

(a) The attorney-in-fact shall keep the principal's property separate and distinct from other

property in a manner adequate to identify the property clearly as belonging to the principal.

(b) An attorney-in-fact holding property for a principal complies with subdivision (a) if the

property is held in the name of the principal or in the name of the attorney-in-fact as attorney-in-

fact for the principal.

REGULATORY PROVISIONS

11. California Code of Regulations (CCR), title 16, section 4470 states, in pertinent part:

…

(d) The licensee shall refrain from representing the consumer in areas outside the scope of

legal authority.

…

(f) Consistent with the licensee's fiduciary duties, the licensee shall provide or arrange for

services to the consumer, to the extent they are appropriate and reasonable based upon the needs

of the consumer, that are in the best interest of the consumer.

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12. CCR, title 16, section 4476 states:

(a) The licensee shall avoid actual conflicts of interest, and consistent with the licensee's

fiduciary duties, shall not engage in any activity where there is the reasonable appearance of a

conflict of interest.

(b) The licensee shall not engage in any personal, business, or professional interest or

relationship that is or reasonably could be perceived as self-serving or adverse to the best interest

of the consumer.

(c) The licensee shall protect the rights of the consumer and the estate against infringement

by third parties.

13. CCR, title 16, section 4480 states, in pertinent part:

…

(b) The licensee shall protect the personal and pecuniary interests of the consumer.

(c) The licensee shall use every reasonable good faith effort to ascertain the desires of the

consumer prior to making any decisions regarding all care, treatment, or services, unless doing so

would violate the licensee's fiduciary duties to the consumer or impose an unreasonable expense

on the estate.

(d) If after every reasonable good faith effort the desires of the consumer cannot be

ascertained or if exercising them would violate the licensee's fiduciary duties to the consumer or

impose an unreasonable expense on the estate, the licensee shall make decisions regarding care,

treatment, and services that are in the best interest of the consumer.

…

14. CCR, title 16, section 4482 states, in pertinent part:

(a) The licensee shall protect the assets of the estate.

…

(d) The licensee may incur expenses that are appropriate to the estate, in relation to the

assets, overall investment strategy, purpose, and other relevant information and circumstances

when investing and managing estate assets.


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(e) Consistent with the licensee's fiduciary duties, the licensee shall manage the assets of

the estate in the best interest of the consumer.

(f) The licensee shall manage the estate with prudence, care and judgment, maintaining

detailed fiduciary records as required by law.

COST RECOVERY

15. Code section 125.3 provides, in pertinent part, that the Board may request the

administrative law judge to direct a licentiate found to have committed a violation or violations of

the licensing act to pay a sum not to exceed the reasonable costs of the investigation and

enforcement of the case, with failure of the licentiate to comply subjecting the license to not being

renewed or reinstated. If a case settles, recovery of investigation and enforcement costs may be

included in a stipulated settlement.

FACTUAL ALLEGATIONS

16. On or about April 17, 2013, G.C. was referred to Respondent by Adult Protective

Services (APS) after he fell in his home and was not found for hours. G.C. is a single male, in his

eighties, and has no living relatives.

17. On or about June 12, 2013, Respondent was appointed as G.C.’s agent for finances

under a Durable Power of Attorney (DPOA). The DPOA was redrafted on July 31, 2015, and

granted Respondent additional powers. On or about May 23, 2014, Respondent was appointed as

G.C.’s heath care agent. The DPOA for health care was redrafted on June 30, 2016.

18. In or about 2015, Respondent liquidated G.C.’s stocks to make a full cash purchase

on a home, incurring significant tax penalties. Respondent failed to discuss details of the home

purchase with G.C., and failed to appropriately consider G.C.’s needs and best interests. Further,

Respondent placed her name on the deed as a co-owner with G.C. despite not having the authority

to do so in the DPOA.

19. On or about July 31, 2015, G.C. established the G.C. Historical Trust (trust), naming

Respondent, her husband, and her brother, as beneficiaries. On or about June 30, 2016, the trust

was amended and Respondent’s brother was removed as a beneficiary. G.C.’s removal of

Respondent’s brother as a beneficiary was influenced by Respondent.


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20. Respondent treated G.C. differently than her other clients with respect to her business

operations processes and procedures.

21. Respondent and her husband strictly managed G.C.’s case instead of assigning it to a

case manager. Respondent kept G.C.’s records and files in her personal office or home versus the

business standard where she kept all her other clients’ records and files at Akel Fiduciary.

22. In and between 2015 and 2018, Respondent allowed her daughter to rent G.C.’s home

significantly below market rate, without a rental agreement, and charged the utilities to G.C.

Respondent managed G.C.’s properties instead of hiring a property management company.

23. Respondent did not ascertain an independent assessment and written report by a care

manager of G.C.’s needs. Respondent did not hire a licensed agency with fully vetted and

approved individuals to fulfill the requirements of G.C. Instead, she hired her brother and office

staff member, both of whom had no previous caregiving/companion experience or training.

24. Respondent did not have G.C.’s personal property items inventoried, appraised,

insured, and properly stored to guard against theft or deterioration.

25. Respondent took G.C.’s property, a military jacket, and gifted it to her uncle in

Arizona without G.C.’s knowledge or permission.

26. Respondent failed to maintain an appropriate standard system of checks and balances,

with a process for receiving and processing incoming mail and bill paying on a timely basis for all

clients. Respondent failed to pay several of G.C.’s bills, resulting in interest and late fees, and

cancellation of credit card accounts, which adversely affected G.C.’s credit rating.

27. Respondent co-mingled G.C.’s credit cards with her personal credit card on her

Amazon account. Respondent failed to create a separate Amazon account and membership with

just the client’s credit card attached to it. Respondent made multiple purchases for herself on

Amazon and Etsy with G.C.’s credit card. Respondent failed to have and/or follow an

appropriate standard business practice of checks and balances, with multiple employees involved,

to avoid erroneous purchases.

28. Respondent failed to provide G.C. with information about his financial status.

Respondent failed to have appropriate monthly meetings with G.C. to share and review


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information accounting reports, indicating assets taken in, liabilities paid out, and a list of the

current asset balances. Additionally, Respondent opened an account at First Citizens Bank that

G.C. had no knowledge of. When interviewed, G.C. did not know basic information about his

finances such as how much money he paid for his house.

29. Respondent failed to bill for services at a standard and reasonable rate/cost.

Respondent’s billing practices were inconsistent, she failed to have detailed billing records, and

she billed for both hourly time and flat fees. In addition, she billed for excessive time regarding

storage unit charges, which indicates that she was not reviewing or managing the amount of time

versus money that this was costing G.C. when she was acting as his DPOA. Respondent

continued to bill and receive payments for professional fiduciary services to G.C. after being

named as a beneficiary in his trust. Respondent benefitted financially for those services and

would stand to gain further benefit by being named as a beneficiary to G.C.’s trust.

30. On or about January 29, 2018, the Bureau received a complaint filed against

Respondent as the agent for finances and health care under a DPOA for G.C.

31. On or about February 26, 2018, Respondent resigned as G.C.’s DPOA of finance and

agent of health care. On or about March 2, 2018, G.C. revoked Respondent’s authority to act as

his agent and DPOA for finances and health care. G.C. also changed his trust to remove

Respondent and her husband as agent, successor, and beneficiaries.

32. Respondent failed to return all of G.C.’s personal belongings at the time of

resignation, instead waiting approximately 6 months after her resignation as DPOA to return

G.C.’s prints and photos, and to pay G.C. cash for personal items she purchased using G.C.’s

credit card.

33. On or about August 31, 2018, Respondent was interviewed by an investigator with

the Department of Consumer Affairs Division of Investigation (DOI Investigator). On or about

October 23, 2018, the DOI Investigator received various records from Respondent.

34. During the interview of Respondent, she stated that G.C. “is a family member.”

However, G.C. was simply an acquaintance of Respondent’s father. Respondent also tried to


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create a familial type of relationship with G.C. by calling him “uncle” and spending personal

family time with him and her family members.

35. On or about July 31, 2019, Respondent was telephonically interviewed by an

investigator with the Bureau (PFB Investigator). Respondent was unable to finish the interview

because she had an appointment with a client. Respondent requested that the PFB Investigator

email Respondent any requested questions or information. The PFB Investigator requested

another phone call to continue the telephonic interview, which was scheduled for the next day,

August 1, 2019. On August 1, 2019, the PFB Investigator was notified by Respondent’s staff that

she was unavailable for the phone call. The PFB Investigator’s subsequent requests for another

phone call with Respondent to continue/complete the interview were ignored. To date,

Respondent has failed to contact the PFB Investigator to complete the requested interview.

36. On or about August 1, 2019, the PFB Investigator emailed Respondent with a list of

information to provide to the Bureau. On or about August 14, 2019, the PFB Investigator

received Respondent’s written response to the investigator’s requests.

37. During the course of the investigation, Respondent provided inconsistent information

to the investigators, as more fully set forth below in paragraph 52 and its subparts.

FIRST CAUSE FOR DISCIPLINE

(Failure to Arrange for Appropriate and Reasonable Services in the Best Interest of

Consumer)

38. Complainant re-alleges paragraphs 16 through 37 as if fully set forth herein.

Respondent is subject to disciplinary action under Code section 6584, subdivisions (d) and (h),

for unprofessional conduct, in that she committed acts contrary to the professional standards of a

professional fiduciary when she violated the Professional Fiduciaries Code of Ethics, California

Code of Regulations, title 16, section 4470, subdivision (f), by failing to arrange for appropriate

and reasonable services, in the best interest of the Consumer, as follows:

a. Respondent failed to appropriately manage G.C.’s properties, as set forth more fully

above in paragraph 22.


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b. Respondent failed to hire appropriate caregivers/companions for G.C., as more fully

set forth above in paragraph 23.

SECOND CAUSE FOR DISCIPLINE

(Engaging in Activity where there is a Reasonable Appearance of Conflict of Interest)





Code of Regulations, title 16, section 4476, subdivision (a), by engaging in activity where there is

a reasonable appearance of conflict of interest, as follows:

a. Respondent established and maintained an inappropriate relationship with client G.C,

as set forth more fully above in paragraphs 20, 21 and 34.

b. Respondent failed to ensure that she or anyone related to her, were not named as

beneficiaries in G.C.’s trust, as more fully set forth above in paragraph 19.

c. Respondent failed to provide G.C. with reasonable opportunities to exercise

individual choices when she influenced G.C. to remove Respondent’s brother as a beneficiary to

G.C.’s trust, as more fully set forth above in paragraph 19.

d. Respondent failed to appropriately manage G.C.’s properties, as set forth more fully


e. Respondent took G.C.’s property, a military jacket, and gifted it to her uncle in

Arizona without G.C.’s knowledge or permission. Respondent failed to have G.C.’s items

inventoried, appraised, insured, and properly stored to guard against theft or deterioration.

f. Respondent failed to hire appropriate caregivers/companions for G.C., as more fully


g. Respondent failed to have and/or follow an appropriate standard business practice of

checks and balances, with multiple employees involved, to avoid erroneous purchases, as set forth

more fully above in paragraph 27. Respondent also failed to return all of G.C.’s personal

belongings at the time of resignation, as set forth more fully above in paragraph 32.


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THIRD CAUSE FOR DISCIPLINE

(Engaging in Professional Interest Reasonably Perceived as Self Serving)





Code of Regulations, title 16, section 4476, subdivision (b), by engaging in professional interest

reasonably perceived as self-serving, as follows:

a. Respondent failed to ensure that she or anyone related to her, were not named as

beneficiaries in G.C.’s trust, as more fully set forth above in paragraph 19.

b. Respondent failed to provide G.C. with reasonable opportunities to exercise

individual choices when she influenced G.C. to remove Respondent’s brother as a beneficiary to

G.C.’s trust, as more fully set forth above in paragraph 19.

c. Respondent failed to appropriately manage G.C.’s properties, as set forth more fully


d. Respondent failed to hire appropriate caregivers/companions for G.C., as more fully


FOURTH CAUSE FOR DISCIPLINE

(Failure to Protect the Estate Against Infringement by Third Parties)





Code of Regulations, title 16, section 4476, subdivision (c), by failing to protect the estate against

infringement by third parties, as follows:




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b. Respondent took G.C.’s property, a military jacket, and gifted it to her uncle in



c. Respondent failed to hire appropriate caregivers/companions for G.C., as more fully


d. Respondent failed to have and/or follow an appropriate standard business practice of




e. Respondent failed to maintain an appropriate standard system of checks and balances,


clients, as set forth more fully above in paragraph 26.

FIFTH CAUSE FOR DISCIPLINE

(Failure to Protect the Personal and Pecuniary Interests of the Consumer)





Code of Regulations, title 16, section 4480, subdivision (b), by failing to protect the personal and

pecuniary interests of the consumer, as follows:






c. Respondent failed to have and/or follow an appropriate standard business practice of


more fully above in paragraph 27.


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d. Respondent failed to maintain an appropriate standard system of checks and balances,


clients, as more fully set forth above in paragraph 26.

SIXTH CAUSE FOR DISCIPLINE

(Failure to Ascertain the Desire of the Consumer Prior to Making Decisions)





Code of Regulations, title 16, section 4480, subdivision (c), by failing to ascertain the desire of

the consumer prior to making decisions, as follows:




Arizona without G.C.’s knowledge or permission. Respondent failed to have G.C. items


c. Respondent failed to provide G.C. with information about his financial status, as

more fully set forth above in paragraph 28.

SEVENTH CAUSE FOR DISCIPLINE

(Failure to Make Decisions Regarding Care, Treatment, and Services in the Best Interest of

Consumer)





Code of Regulations, title 16, section 4480, subdivision (d), by failing to make decisions

regarding care, treatment, and services in the best interest of the consumer, as follows:


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a. Respondent failed to hire appropriate caregivers/companions for G.C., as more fully


EIGHTH CAUSE FOR DISCIPLINE

(Failure to Protect Assets of the Estate)





Code of Regulations, title 16, section 4482, subdivision (a), by failing to protect the assets of the

estate, as follows:

a. Respondent failed to bill for services at a standard and reasonable rate/cost, and


named as a beneficiary in his trust, as more fully set forth above in paragraph 29.

b. Respondent failed to appropriately manage G.C.’s properties, as set forth more fully


c. Respondent took G.C.’s property, a military jacket, and gifted it to her uncle in




checks and balances, with multiple employees involved, to avoid erroneous purchases, as more

fully set forth above in paragraph 27. Respondent also failed to return all of G.C.’s personal

belongings at the time of resignation, as more fully set forth above in paragraph 32.




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NINTH CAUSE FOR DISCIPLINE

(Failure to Incur Appropriate Expenses to the Estate)





Code of Regulations, title 16, section 4482, subdivision (d), by failing to incur appropriate

expenses to the estate, as follows:










TENTH CAUSE FOR DISCIPLINE

(Failure to Manage the Assets of the Estate in the Best Interest of the Consumer)





Code of Regulations, title 16, section 4482, subdivision (e), by failing to manage the assets of the

estate in the best interest of the consumer, as follows:





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belongings at the time of resignation, as more fully set forth above 32.



clients, as set forth more fully above in paragraph 26.

f. Respondent failed to provide G.C. with information about his financial status, as


ELEVENTH CAUSE FOR DISCIPLINE

(Failure to Manage the Estate with Prudence, Care, and Judgment)





Code of Regulations, title 16, section 4482, subdivision (f), by failing to manage the estate with

prudence, care and judgment, as follows:







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f. Respondent failed to provide G.C. with information about his financial status, as


TWELFTH CAUSE FOR DISCIPLINE

(Engaging in Conflict of Interest as an Attorney-in-Fact)


Respondent is subject to disciplinary action under Code section 6584, subdivision (h), in that she

violated Probate Code section 4232, subdivision (a) by engaging in conflict of interest as an

attorney-in-fact, as follows:

a. Respondent established and maintained an inappropriate relationship with client G.C,

as set forth more fully above in paragraphs 20, 21 and 34.








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THIRTEENTH CAUSE FOR DISCIPLINE

(Failure to Keep the Principal's Property Separate and Distinct from other Property)


Respondent is subject to disciplinary action under Code section 6584, subdivision (h), in that she

violated Probate Code section 4233, by failing to keep the principal’s property separate and

distinct from other property in a manner adequate to identify the property as clearly belonging to

the principal, as follows:

a. Respondent liquidated G.C.’s stock to make a full cash purchase on a home, incurring

significant tax penalties. Respondent failed to discuss the details of the home purchase with G.C.,

and failed to appropriately consider G.C.’s needs and best interests. Further, Respondent placed

her name on the deed as a co-owner with G.C. despite not having the authority to do so in the

DPOA.





checks and balances, with multiple employees involved, to avoid erroneous purchases, as set

forth more fully above in paragraph 27. Respondent also failed to return all of G.C.’s personal


FOURTEENTH CAUSE FOR DISCIPLINE

(Dishonesty)


Respondent is subject to disciplinary action under Code section 6584, subdivision (d), in that she

engaged in acts constituting dishonesty by failing to act professionally when she provided

dishonest and inconsistent information to the Bureau, as follows:

a. Respondent was dishonest to the Bureau when she provided inconsistent information

related to dates of G.C.’s referral to her by Adult Protective Services (APS), and Respondent’s

appointment as DPOA. On or about July 31, 2019, Respondent informed the PFB Investigator


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that G.C. was referred to Respondent by APS sometime in 2015 as a client, and was appointed as

DPOA in 2015.

On or about August 14, 2019, Respondent submitted written statements to the PFB

Investigator stating that G.C.’s APS referral to Respondent was on April 17, 2013. The

investigation revealed that G.C. was referred to Respondent by APS on April 17, 2013,

Respondent was appointed as G.C.’s DPOA for finances on June 12, 2013, and as DPOA agent

for health care on May 23, 2014.

b. Respondent was dishonest to the Bureau when she provided inconsistent information

related dates that she started working for G.C. On or about July 31, 2019, Respondent informed

the PFB Investigator that she did not start acting as G.C.’s agent at the time that she was

appointed and only started “acting” shortly before G.C.’s home was purchased. Records

indicated that the home was purchased in January 2015.

On or about August 14, 2019, Respondent submitted written statements to the PFB

Investigator stating that she started acting as agent for finance and healthcare shortly after she was

appointed. The investigation revealed that Respondent was appointed as agent for finances under

DPOA on or about June 12, 2013 and as agent for health care under DPOA on or about May 23,

2014.

Respondent’s invoices show that she started charging G.C. for various services under Akel

Fiduciary beginning on our about April 17, 2013. Respondent started charging G.C. for

Financial management services on or about July 1, 2013.

c. Respondent was dishonest to the Bureau when she provided inconsistent information

related to services and payments after Respondent was named as a beneficiary in G.C.’s trust.

On or about July 31, 2019, Respondent informed the PFB Investigator that G.C. started to

pay Respondent at first, but once she was written into the trust and “because of the relationship”

she stopped accepting payments from G.C. She started to bill him again for her services when

G.C.’s needs increased and he required more attention.

Respondent’s records show that she never stopped receiving payments from G.C., and even

collected a monthly fee plus an hourly fee during some periods.


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FIFTEENTH CAUSE FOR DISCIPLINE

(Gross Negligence)



engaged in acts constituting gross negligence, when she failed to act professionally by providing

inconsistent information to the Bureau and ignoring requests for interviews by Bureau staff.

Respondent failed to cooperate, be accountable, transparent, and available to the licensing bureau.

Respondent also failed to treat her business relationship with G.C. with respect. The facts and

circumstances are more fully set forth above in paragraph 52, and its subparts.

SIXTEENTH CAUSE FOR DISCIPLINE

(Unprofessional Conduct)



engaged in acts constituting unprofessional conduct, in that she willfully violated her duties as a

professional fiduciary and engaged in acts contrary to professional standards, as more fully set

forth above in paragraphs 16 through 52.

PRAYER

WHEREFORE, Complainant requests that a hearing be held on the matters herein alleged,

and that following the hearing, the Professional Fiduciaries Bureau issue a decision:

1. Revoking or suspending Professional Fiduciary License Number PF 138, issued to

Dawn Elizabeth Akel;

2. Ordering Dawn Elizabeth Akel to pay the Professional Fiduciaries Bureau the

reasonable costs of the investigation and enforcement of this case, pursuant to Business and

Professions Code section 125.3; and,

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3. Taking such other and further action as deemed necessary and proper.

DATED: April 9, 2020 Signature on File REBECCA MAY Bureau Chief Professional Fiduciaries Bureau Department of Consumer AffairsState of California Complainant

SA2020100199 33968644.docx


xavier becerra attorney general of california kent

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