IN RE: Anokye S. BLISSETT (2026)

OPINION & ORDER

The Grievance Committee for the Second, Eleventh, and Thirteenth Judicial Districts commenced a formal disciplinary proceeding against the respondent by serving and filing a notice of petition and a verified petition, both dated February 2, 2023.  The petition contains seven charges of professional misconduct.  The respondent served and filed a verified answer dated February 17, 2023.  By decision and order on application dated November 2, 2023, the matter was referred to the Honorable Randall T. Eng, as Special Referee, pursuant to 22 NYCRR 1240.8(b)(1), to hear and report.  In a report dated June 3, 2024, the Special Referee sustained all seven charges in the petition.  By notice of motion dated March 20, 2025, the Grievance Committee moves to confirm so much of the Special Referee's report as sustained the seven charges of professional misconduct and disaffirm so much of the report as made certain findings regarding mitigation.  The Grievance Committee requests that the Court impose such discipline upon the respondent as the Court deems just and proper.  In response, the respondent, through counsel, supports the confirmation of the Special Referee's report in its entirety and requests the imposition of a public censure.

The Petition

The verified petition alleges seven charges of misconduct that relate to the respondent's two escrow accounts maintained at Chase Bank:  one entitled “Anokye S. Blissett PC, Attorney Trust Account IOLA” with an account number ending in 4045 (hereinafter escrow account 4045) and one entitled “Anokye S. Blissett PC, Escrow Account” with an account number ending in 8427 (hereinafter escrow account 8427).

Charge one alleges that in or about October 2016, the respondent was retained by her aunt, Earline Nelson, in connection with the sale of Nelson's marital home.  On November 1, 2016, the respondent deposited a down payment in the sum of $10,000 into escrow account 8427 in connection with the sale of Nelson's home.  As of November 21, 2018, the balance in escrow account 8427 had been depleted to $1,646.28, without any disbursements relating to the Nelson transaction.

On November 21, 2018, the opening balance in escrow account 4045 was $8,221.04, of which $5,165 represented funds the respondent was holding for nine different clients.  On November 21, 2018, the respondent made a wire transfer in the amount of $7,000 from escrow account 4045 to Nelson, representing some of the proceeds of the sale of Nelson's marital home, when insufficient funds were on deposit for the Nelson matter.  The wire transfer cleared escrow account 4045, at least in part, against other client and/or third-party funds.

Based on the foregoing, the respondent was charged with misappropriating funds entrusted to her as a fiduciary incident to her practice of law, in violation of rule 1.15(a) of the Rules of Professional Conduct (22 NYCRR 1200.0).

Charges two and four allege that between June 1, 2018, and January 31, 2019, the respondent maintained client funds on deposit in escrow account 4045.  On August 20, 2018, the respondent made a mortgage payment in the amount of $15,465.70 from escrow account 4045 on behalf of her parents' company, 344 Lafayette Avenue, LLC, when there were no correlating funds on deposit, causing an invasion, at least in part, of client and/or third-party funds.  On September 11, 2018, the respondent deposited a total sum of $18,000 into escrow account 4045 in connection with 344 Lafayette Avenue, LLC. The deposited funds, of which $16,000 was in cash, represented rent payments collected for 344 Lafayette Avenue, LLC. These funds were not fiduciary funds received by the respondent incident to her practice of law.

Based on the foregoing, the respondent was charged with misappropriating funds entrusted to her as a fiduciary incident to her practice of law, in violation of rule 1.15(a) of the Rules of Professional Conduct (charge two), and improper use of her escrow account, in violation of rule 1.15(b) of the Rules of Professional Conduct (charge four).

Charge three alleges that on or about May 25, 2018, the respondent deposited an immigration filing fee in the amount of $1,760, from client Sandra Maynard Morris into escrow account 4045.  As of November 30, 2018, without any disbursements on behalf of Morris, the balance in escrow account 4045 had been depleted to $28.64, a deficiency of $1,731.36.  As a result, the respondent was charged with misappropriating funds entrusted to her as a fiduciary incident to her practice of law, in violation of rule 1.15(a) of the Rules of Professional Conduct.

Charge five alleges that between August 2018 and February 2019, the respondent routinely deposited funds belonging to friends and family into escrow account 8427.  These funds were not fiduciary funds received by the respondent incident to her practice of law.  The respondent was charged with improperly using her escrow account, in violation of rule 1.15(b) of the Rules of Professional Conduct.

Charge six alleges that between August 2018 and February 2019, the respondent's escrow account 8427 was improperly titled, as it failed to include one of the following phrases:  “Attorney Special Account,” “Attorney Trust Account,” or “Attorney Escrow Account,” in violation of rule 1.15(b)(2) of the Rules of Professional Conduct.

Charge seven alleges that between August 2018 and February 2019, the respondent failed to maintain required bookkeeping records, in violation of rule 1.15(d) of the Rules of Professional Conduct.

The Hearing Record

On September 21, 2021, the respondent appeared for an examination under oath (hereinafter EUO).  On February 26, 2024, a hearing was conducted.  The Grievance Committee entered six exhibits into evidence to prove its case in chief.  The respondent submitted six character letters and a personal statement as exhibits, called one witness to testify about remedial measures taken, and testified on her own behalf.  The respondent admitted to all of the factual allegations as outlined in the petition.

The respondent opened her law firm in 2008 and focused her law practice in the areas of real estate and immigration.  In 2021, the respondent had approximately 15 immigration matters and approximately 30 active real estate matters.  The respondent testified that she maintained three escrow accounts and that she was the sole signatory on the escrow accounts.

As to escrow account 8427, the respondent opened the account in 2008 or 2009 and used it originally for real estate matters.  Later, in 2012 or 2014, the respondent began using the account for her immigration law practice and “used it as a way to preserve [her] friends['] and family's money for parties [and] festivals around the world.”  The respondent explained that she

“used to help them get tickets [and] accommodation[s] voluntarily because [she] just had access.  [She] met people throughout the years.  And against the rules, [she] took their money and [she] put it into this escrow account because [she did not] want to commingle it with [her] personal mon[ies].  They were not clients of [hers].  So [she] know[s] now or knew that [she should not] have done so.”

The respondent testified that she linked escrow account 8427 with PayPal, Zelle, and Venmo because “escrow account [8427] is a personal account of sorts.”  The respondent admitted that she did not maintain a proper ledger for the account.  The record reflects that the respondent was holding funds for at least 60 individuals from August 2018 until February 2019, making at least as many transactions for her party planning venture from escrow account 8427.

As to escrow account 4045, the respondent testified that she primarily used the account for real estate matters, to receive funds for her parents' business, and for her immigration client matters.

On November 1, 2016, the respondent deposited the sum of $10,000, representing the down payment for the Nelson matter, in escrow account 8427.  The respondent testified that the contract of sale was signed on October 21, 2016, and the closing occurred on April 4, 2017.  On April 5, 2017, the respondent received $144,000 in net proceeds for the Nelson matter, which she deposited into escrow account 4045.  The respondent testified that she did not realize that she had deposited the down payment in escrow account 8427 until one week before her EUO, in September 2021, when her accountant informed her of the discrepancy in her accounts.  The respondent incorrectly believed she had deposited the full amount of $154,000 in connection with the Nelson matter in escrow account 4045.  With that belief, the respondent issued a number of disbursements from escrow account 4045, including a wire transfer in the amount of $7,000, which cleared the respondent's escrow account, at least in part, against other client and/or third-party funds.  The record reflects that the respondent depleted the $10,000 down payment that she had deposited into escrow account 8427.

As to the funds deposited associated with 344 Lafayette Avenue, LLC, the respondent testified that she was essentially the manager of the building owned by her parents under 344 Lafayette Avenue, LLC. The respondent acknowledged that she deposited rental income for 344 Lafayette Avenue, LLC, into escrow account 4045 because it was easier for her to pay expenses out of her escrow account even though the company has its own operating account.  Further, the respondent admitted that between August 1, 2018, and September 11, 2018, she made a number of disbursements from escrow account 4045 for 344 Lafayette Avenue, LLC, when she did not have sufficient funds on deposit.  The disbursements included paying herself two management fees, which cleared against other client and/or third-party funds.  The respondent explained that because her entire family was traveling at that time, it was easier if she disbursed funds from escrow account 4045.

In reflecting on her misconduct, the respondent testified that she thought

“it was just a busy period in my life, handling, juggling multiple, multiple practices and then this party thing.  It's not small because there's a lot of money, as you can see, that went back and forth.  And I just didn't have the right temperament and time to sit down and do it diligently.

I think the practices I have put in place now is a lot easier because now work is just separate, if that makes sense, work is separate.  There's a checks and balances for that work.”

The respondent testified that now her “accounts are just boring” and that she still maintains three escrow accounts.  She has since closed down her private law practice.  The respondent acknowledged her poor bookkeeping practices, testified that she now maintains escrow account ledgers, and admitted that she should have maintained proper bookkeeping and that it was not a priority for her until the Grievance Committee's investigation.  The respondent believed that any client who had been affected was made whole and that “[t]he only person who suffered harm was [herself].”

The Special Referee's Report

In a report dated June 3, 2024, the Special Referee sustained all seven charges of professional misconduct.  In aggravation, the Special Referee noted that the respondent's violations of the Rules of Professional Conduct were not those of a novice practitioner.  The Special Referee found that the respondent failed to offer evidence of any contemporary illnesses or traumatic events that might have contributed to her admitted misconduct.

The Special Referee noted the evidence presented by the respondent in mitigation, including the respondent's belief that she did not act with venality, that she believed no client suffered financial harm, and that she has now hired a bookkeeper.  The Special Referee found that the respondent accepted responsibility, expressed contrition and remorse, and recognized the serious nature of her misconduct.  The Special Referee found that the respondent “has made a determined effort to regularize her accounting and bookkeeping responsibilities but this does not serve to mitigate the violation[s] of the Rules of Professional Conduct which she should have been fully aware of.”

The Grievance Committee now moves to confirm so much of the Special Referee's report as sustained the seven charges of professional misconduct and disaffirm so much of the report as made certain findings regarding mitigation.  The Grievance Committee asserts that the Special Referee's findings related to intentionality and venality, “that no clients, friends, or family members suffered any financial harm,” and the statement that the respondent “offered evidence in mitigation which suggests that she has taken steps to adhere to the Rules of Professional Conduct” should be disaffirmed, as they were unsupported by the record.  The Grievance Committee notes that the respondent was issued a Letter of Advisement in 2020 based upon her failure to satisfy two default judgments during the same time period as the charged misconduct.  In connection with the Letter of Advisement, the respondent told the Grievance Committee that she was “not paying attention ․ not giving important matters the time and dedication they deserve.”

In response, the respondent, through counsel, supports the confirmation of the Special Referee's report in its entirety.  The respondent's counsel asserts that the respondent's conduct was aberrational and was the result of improper bookkeeping practices, ignorance of the Rules of Professional Conduct governing escrow accounts, and prior inexperience with escrow accounts.  The respondent requests the imposition of a public censure.

Findings and Conclusion

In view of the evidence adduced at the hearing and the admissions, we find that the Special Referee properly sustained all seven charges.  Accordingly, that branch of the Grievance Committee's motion which is to confirm so much of the Special Referee's report as sustained the seven charges of professional misconduct is granted, and the remaining branches of the Grievance Committee's motion are denied.

In determining an appropriate measure of discipline, notwithstanding the mitigation advanced, the respondent knowingly and intentionally failed to honor her obligations as a fiduciary until the Grievance Committee's investigation.  The respondent admitted to using her escrow accounts as her personal bank accounts for several years, including using her escrow accounts as repositories for nonfiduciary funds for her convenience.  Further, the respondent's failure to keep proper bookkeeping records or reconcile her escrow accounts caused ongoing deficiencies in both her escrow accounts that persisted for several years.

Under the totality of the circumstances, we find that the respondent's conduct warrants a suspension from the practice of law for a period of two years.

ORDERED that that branch of the Grievance Committee's motion which is to confirm so much of the Special Referee's report as sustained the seven charges of professional misconduct is granted, and the remaining branches of the Grievance Committee's motion are denied;  and it is further,

ORDERED that the respondent, Anokye S. Blissett, admitted as Anokye Soyini Blissett, is suspended from the practice of law for a period of two years, commencing September 18, 2026, and continuing until further order of this Court.  The respondent shall not apply for reinstatement earlier than March 20, 2028.  In such application (see 22 NYCRR 1240.16), the respondent shall furnish satisfactory proof that during the period of suspension, she (1) refrained from practicing or attempting to practice law, (2) fully complied with this opinion and order and with the terms and provisions of the rules governing the conduct of disbarred or suspended attorneys (see id. § 1240.15), (3) complied with the applicable continuing legal education requirements of 22 NYCRR 691.11(a), and (4) otherwise properly conducted herself;  and it is further,

ORDERED that the respondent, Anokye S. Blissett, admitted as Anokye Soyini Blissett, shall comply with the rules governing the conduct of disbarred or suspended attorneys (see id. § 1240.15);  and it is further,

ORDERED that pursuant to Judiciary Law § 90, the respondent, Anokye S. Blissett, admitted as Anokye Soyini Blissett, shall desist and refrain from (1) practicing law in any form, either as principal or as agent, clerk, or employee of another, (2) appearing as an attorney or counselor-at-law before any court, Judge, Justice, board, commission, or other public authority, (3) giving to another an opinion as to the law or its application or any advice in relation thereto, and (4) holding herself out in any way as an attorney and counselor-at-law;  and it is further,

ORDERED that if the respondent, Anokye S. Blissett, admitted as Anokye Soyini Blissett, has been issued a secure pass by the Office of Court Administration, it shall be returned forthwith to the issuing agency, and the respondent shall certify to the same in her affidavit of compliance pursuant to 22 NYCRR 1240.15(f).

PER CURIAM.

LASALLE, P.J., DILLON, DUFFY, BARROS, and CHRISTOPHER, JJ., concur.