IN THE MATTER OF HAKEEM BERTRAND BROCK

In the
Supreme Court of Georgia
No. S26Y0645
In the Matter of Hakeem Bertrand Brock
Decided: October 14, 2026
Per Curiam.
This disciplinary matter is before the Court on the report
and recommendation of the State Disciplinary Review Board
(“Review Board”) that Hakeem Bertrand Brock (State Bar No.
705137) be disbarred for the mishandling of his trust account and
conduct in five client matters, resulting in violations of Rules 1.1;
1.2(a); 1.3; 1.4; 1.5(a) and (c); 1.15(I)(a), (b), (c), and (d); 1.15(II)(a)
and (b); 1.15(III)(b); 5.3; 8.4(a)(4); and 9.3 of the Georgia Rules of
Professional Conduct (“GRPC” or “Rules”). 1 Upon careful review,
we agree with the recommendation to disbar Brock, and conclude
that, if Brook seeks readmission, he must provide restitution to
all affected clients and provide proof of restitution to this Court
and the State Bar.
1. 	Procedural History
The State Bar filed two formal complaints in this matter
1 This is the second time in seven years that Brock has been disciplined
for misconduct. In 2019, this Court previously disciplined Brock for misconduct
related to his handling of his firm’s trust account and his failure to properly
supervise a nonlawyer employee. See In the Matter of Brock, 306 Ga. 388 (2019)
(accepting petition for voluntary discipline and imposing a Review Board rep-
rimand).

2
charging Brock with violating the Rules referenced above. To-
gether, the complaints comprise seven separate disciplinary mat-
ters: State Disciplinary Board Docket (“SDBD”) Numbers 7531,
7718, and 7720–24. In response, Brock filed before the Special
Master a petition for voluntary discipline, in which he admitted
to violating some of the Rules with which he was charged and re-
quested a six- to 12-month suspension. The State Bar requested
that the Special Master reject the petition. Brock then submitted
a second petition for voluntary discipline (the “second petition”),
in which he unconditionally admitted to violating additional
Rules that were charged and requested a one-year suspension.
The State Bar agreed to the second petition. The Special Master,
however, rejected the second petition because it proposed insuffi-
cient discipline, set the matter for a hearing, and found that
Brock’s admissions established by clear and convincing evidence
that, “at minimum,” Brock violated all of the rules he admitted
violating in the second petition. Following the evidentiary hear-
ing, the Special Master issued her report and recommendation,
finding that Brock had violated the Rules charged in the com-
plaints.
2. 	Special Master’s Report and Recommendation
(a) Allegations and the Special Masters Findings
(i) 	SDBD Nos. 7531 & 7718
These two matters concern Brock’s mishandling of his trust
accounts. Regarding SDBD No. 7531, the State Bar alleged that
it received notice that two checks from an “Interest on Lawyers’
Trust Account” (“IOLTA”) belonging to Brock had been returned
for insufficient funds. In SDBD No. 7718, the Bar alleged that it
received another notice that two checks from a different IOLTA
belonging to Brock had been returned for insufficient funds; that

3
the checks did not designate that the funds were withdrawn from
an attorney trust account; and that Brock was using new recover-
ies to pay off shortfalls in the IOLTA from prior recoveries.
The Special Master found the following. Despite having
promised this Court during his first disciplinary matter in 2019
that he had “straightened out” his trust accounting practices,
Brock failed to do so. At the evidentiary hearing, Brock readily
admitted the following: he treated his IOLTA as if it were a check-
ing account; he deposited and kept personal funds in his IOLTA
and was unsure how much of the funds belonged to clients and
third parties; he was aware that commingling client funds with
his own was “unethical” but continued to do so; he did not start
keeping trust account ledgers until “maybe a year after” opening
the IOLTA at issue in SDBD No. 7718; and the checks at issue
did not indicate that they were from an IOLTA as required by the
Rules. Brock’s use of other clients’ funds to make up for shortfalls
caused by his own misappropriation of client funds was “obvious.”
Brock’s suggestion that hiring attorney Michael Powell to help
manage Brock’s firm’s finances brought him into compliance with
the trust accounting rules was not credible, because Powell testi-
fied at the evidentiary hearing that he was unaware of several of
those Rules. 2 As for the specific dishonored checks at issue,
Brock’s attempt to blame his bouncing checks on fraudulent ac-
tivity — like he did in his previous disciplinary matter — was not
credible.
Based on this evidence and Brock’s second petition, the
2 The State Bar filed a formal complaint against Powell regarding the
same matters and charging many of the same Rule violations. Powell submit-
ted a petition for voluntary discipline requesting a public reprimand, which
this Court rejected. See In the Matter of Powell, S25Y1162 (Aug. 26, 2025).

4
Special Master concluded that Brock violated Rules 1.15(I)(a)3 by
failing to hold third party funds separate from his own and
1.15(II)(b)4 by depositing personal funds into the firm’s trust ac-
count, failing to keep and preserve complete IOLTA records and
client ledgers, and improperly and prematurely withdrawing
funds from his trust accounts and applying those funds to per-
sonal or firm operational use. The Special Master also found that
Brock violated Rules 1.15(III)(b),5 because the checks drawn from
his trust account did not designate that they were drawn from an
IOLTA and 8.4(a)(4)6 by repeatedly using funds belonging to one
client to pay another client’s obligations.7
3 Rule 1.15(I)(a) provides, in relevant part, that “[a] lawyer shall hold
funds or other property of clients or third persons that are in a lawyer’s pos-
session in connection with a representation separate from the lawyer’s own
funds or other property…. Complete records of such account funds and other
property shall be kept by the lawyer.”
4 Rule 1.15(II)(b) provides, in relevant part, that “[n]o personal funds
shall ever be deposited in a lawyer’s trust account” and “[n]o funds shall be
withdrawn from such trust accounts for the personal use of the lawyer main-
taining the account except earned lawyer’s fees debited against the account of
a specific client and recorded as such.”
5 Rule 1.15(III)(b) provides, in relevant part, that “[a] lawyer shall des-
ignate all trust accounts, whether general or specific, as well as all deposit slips
and checks drawn thereon, as an ‘Attorney Trust Account,’ ‘Attorney Escrow
Account’ ‘IOLTA Account’ or ‘Attorney Fiduciary Account.’”
6 Rule 8.4(a)(4) provides, in relevant part, that it shall be a violation of
the GRPC for a lawyer to “engage in professional conduct involving dishonesty,
fraud, deceit, or misrepresentation.”
7 The Special Master also concluded that Brock violated Rule
1.15(II)(a) by failing to administer client funds from his IOLTA. However, be-
cause the State Bar charged Brock with violating this Rule only in SDBD No.
7720, we only address the Rule 1.15(II)(a) violation in connection with that
matter.

5
(ii) SDBD No. 7720
The State Bar alleged that Brock represented the client’s
deceased child in a wrongful death case and received a settlement
in the amount of $100,000. In March 2021, the client signed a re-
lease 	in 	connection 	with 	the 	settlement, 	after 	which 	Brock
stopped communicating with the client. Brock failed to set up an
estate for the deceased child and failed to pay the medical bills
owed by the estate, as the client expected him to do. The client
reached out to Brock’s now former paralegal, who informed her
that Brock’s trust account had a negative balance and that the
settlement proceeds were gone. Brock’s bank records showed that
in January 2022, the amount in his IOLTA was less than $9,000
and that in April 2022, a cashier’s check in the amount of $60,000
payable to the client was obtained but was not given to the client.
The Special Master recounted that at the evidentiary hear-
ing, the client testified that she was informed of the $100,000 set-
tlement by Brock’s office and was told that she “should be getting
[a] check in the mail soon.” However, the client did not receive a
check and despite “waiting and waiting” and “calling and calling,”
the client did not receive any updates on the status of the settle-
ment funds and never received a settlement statement. The client
also testified that she was told that the estate’s hospital bills
“would be taken care of” but they were not and that she “felt like
[she] was taken advantage of because [her] son died, and [she]
wasn’t in [her] right [mind]” while grieving. 	Further, both the
client and Brock’s former paralegal testified that the client never
authorized Brock to collect $40,000 as his fee.
As to the ultimate disposition of the $100,000 recovery,
Brock received the $100,000 payment in February 2021, depos-
ited the funds into an IOLTA account, and withdrew the entirety
of those funds later that year. The Special Master’s review of

6
Brock’s bank records showed that his IOLTA account did not con-
tain the client’s funds. Thus, Brock’s failure to provide the client
with the settlement funds was due to Brock having converted the
client’s recovery to his own use and his reluctance or inability to
pay it back. Although the client testified that Brock and Powell
attempted to give her $60,000 after she filed her grievance, she
did not believe that it was acceptable for Brock to retain $40,000,
as he had originally converted her money to his own use, and she
disagreed with the way her case was handled. Accordingly, the
Special Master found that given Brock’s conduct in this matter,
his claim to a $40,000 share of the recovery was “specious.”
Citing Brock’s second petition, the Special Master found
that Brock unconditionally admitted that he violated Rules 1.3 8
by failing to act with reasonable diligence around the estate-for-
mation process; 1.5(c) 9 by failing to prepare a settlement state-
ment; 1.15(I)(a) by failing to hold the client’s settlement funds in
the trust account, failing to maintain proper IOLTA records, and
failing to maintain client ledgers; and 1.15(II)(b) by depositing
personal funds to cover a trust shortfall and by improperly and
prematurely withdrawing the settlement funds for personal or
firm operational use. Additionally, the Special Master concluded
that Brock violated Rules 1.4 10 by failing to communicate truth-
fully and completely with the client about the status of her case
8 Rule 1.3 provides, in relevant part, that “[a] lawyer shall act with
reasonable diligence and promptness in representing a client.”
9 Rule 1.5(c) provides, in relevant part, that “[a] contingent fee agree-
ment shall be in writing and shall state the method by which the fee is to be
determined” and requires that “[u]pon conclusion of a contingent fee matter,
the lawyer shall provide the client with a written statement stating … the out-
come of the matter.”
10 Rule 1.4 provides, in relevant part, that “[a] lawyer shall: (1)

7
and her recovery; 1.5(a)11 because his $40,000 fee was unreason-
able under the circumstances; 1.15(I)(b)12 because he disregarded
apparent 	interests 	of 	third 	parties 	in 	the 	client’s 	recovery;
1.15(I)(c)13 because he failed to notify, deliver, and account for the
funds owed; 1.15(I)(d)14 because he admittedly failed to keep the
amount of funds in dispute separate until a resolution could be
reached; 1.15(II)(a)15 because he did not administer the client’s
funds from his IOLTA account; and 8.4(a)(4) by converting the
client’s funds to his own use.
promptly inform the client of any decision or circumstance with respect to
which the client’s informed consent … is required; (2) reasonably consult with
the client about the means by which the client’s objectives are to be accom-
plished; (3) keep the client reasonably informed about the status of the matter;
[and] (4) promptly comply with reasonable requests for information.”
11 Rule 1.5(a) provides, in relevant part, that “[a] lawyer shall not make
an agreement for, charge, or collect an unreasonable fee or an unreasonable
amount for expenses.”
12 Rule 1.15(I)(b) provides, in relevant part, that “a lawyer may not
disregard a third person’s interest in funds or other property in the lawyer’s
possession.”
13 Rule 1.15(I)(c) provides, in relevant part, that “[u]pon receiving
funds or other property in which a client or third person has an interest, a
lawyer shall promptly notify the client or third person” and “shall promptly
deliver to the client or third person any funds or other property that the client
or third person is entitled to receive.”
14 Rule 1.15(I)(d) provides, in relevant part, that “[w]hen in the course
of representation a lawyer is in possession of funds or other property in which
both the lawyer and a client or a third person claim interest, the property shall
be kept separate by the lawyer until there is an accounting and severance of
their interests.”
15 Rule 1.15(II)(a) provides, in relevant part, that “[a]ll funds held by
a lawyer for, or related to the representation of, a client … shall be deposited
in and administered from a trust account.”

8
(iii) SDBD No. 7721
The State Bar alleged that Brock represented the client in
a personal injury matter after she was involved in a car accident
and, although he filed suit in the case, he failed to take any steps
in the case, causing the case to be dismissed for want of prosecu-
tion. Rather than telling the client that her case had been dis-
missed, Brock told her that he had recovered $15,000 and that
she would receive $6,000. Later, Brock gave the client an undated
settlement statement providing that Brock would take a reduced
fee of $3,000 and use the remaining $6,000 to pay the client’s med-
ical providers. Brock provided the client with a cashier’s check
payable from his IOLTA.
The Special Master found that Brock admitted in his sec-
ond petition that he provided the client with a settlement state-
ment that was a “misleading document” that “likely gave [her] the
impression that her payment was from an insurance settlement”
when that was not true. Brock had created this document to cover
up the fact that he had allowed the client’s matter to be dismissed
in an attempt to deceive the client, the State Bar, and the State
Disciplinary Board. Although Brock argued at the evidentiary
hearing that the client knew that he had “botched” her case and
was willing to accept $6,000, this argument was not credible be-
cause Brock presented the settlement document to make it ap-
pear as if the case had been settled with the insurance company
and Brock did not raise this argument until the hearing. Further,
Brock did not pay the client’s medical providers until after the
client filed a grievance against him.
The Special Master also found that based on his second pe-
tition, Brock admitted that he violated Rule 1.3 by failing to
timely pay the client’s medical providers. Brock also admitted
that he violated Rules 1.4 and 8.4(a)(4) by “transmitting what

9
may objectively be considered misleading information about the
nature of the settlement.” The Special Master further found that
the record showed that Brock’s actual violations in this matter
were much more serious and that he violated Rules 1.2(a)16 by
failing to abide by the client’s objectives of obtaining a settlement
by pursuing her case; 1.5(c) because his settlement statement did
not truthfully state the outcome of the matter; 1.15(I)(a) and
1.15(II)(b) by using funds from his IOLTA that did not belong to
the specific client to pay her and her providers; 8.4(a)(4) because
the settlement statement providing that the insurer had paid the
client’s claim was dishonest; and 9.317 because Brock presented
the fabricated statement to disciplinary authorities in response to
the investigation as if it was genuine.18
(iv) SDBD No. 7722
The State Bar alleged that Brock, along with Powell, rep-
resented the client in a motor-vehicle personal injury suit. In
2019, Brock filed suit on her behalf, and the trial court directed
16 Rule 1.2(a) provides, in relevant part, that “a lawyer shall abide by
a client’s decisions concerning the scope and objectives of representation and,
as required by Rule 1.4, shall consult with the client as to the means by which
they are to be pursued.”
17 Rule 9.3 provides that “[d]uring the investigation of a matter pursu-
ant to these Rules, the lawyer complained against shall respond to disciplinary
authorities in accordance with State Bar Rules.”
18 The Special Master explained that the conduct supporting the Rule
9.3 violation also supported a Rule 8.1(a) violation but acknowledged that
Brock was not charged with violating this Rule in the formal complaint. See
Rule 8.1(a) (prohibiting a lawyer, in connection with a disciplinary matter,
from “knowingly making a false statement of material fact”). To the extent that
the Special Master’s report can be read to find a Rule 8.1(a) violation, we clarify
that we have considered no such violation because it was not charged in the
formal complaint.

10
the parties to participate in mediation. Brock failed to notify the
client of the mediation date, and neither Brock nor the client ap-
peared. Subsequently, the trial court ordered Brock and Powell to
submit the client’s portion of a pretrial order, which they failed to
do. The judge then directed Brock and the client to appear at a
pretrial conference. Once again, Brock failed to notify the client
that she needed to appear, and neither she nor Brock appeared.
The case was then dismissed for want of prosecution. Neither
Brock nor Powell communicated with the client about the status
of her case despite repeated requests for information. Brock’s for-
mer paralegal informed the client that Brock abandoned her case,
and the client contacted his office and spoke to another one of his
nonlawyer employees who advised her that the matter had not
been dismissed. The client later requested her client file from
Brock, but, according to Brock, his former paralegal took the files
of several of his clients when she left his employ.
The Special Master found that the client was not aware of
what was going on in her case even after it had been dismissed
because Brock instructed his employees to tell the client that the
case was “in litigation even though it had been dismissed.” Brock
admitted in the second petition that the client’s “injury action was
dismissed without prejudice due to calendaring errors, which
caused a failure to meet certain litigation deadlines” due to his
lack of “competence” to handle her case.
The Special Master also found that Brock admitted to vio-
lating Rule 1.1 19 by failing to maintain his duty of competence to
the client. The Special Master also determined that the record
showed that Brock violated Rules 1.2(a) by failing to abide by the
19 Rule 1.1 provides, in relevant part, that “[a] lawyer shall provide
competent representation to a client.”

11
objectives of his representation; 1.3 by failing to diligently pursue
the client’s matter which resulted in the dismissal of the case;
1.4(a) by failing to notify the client of important deadlines; and
5.3(c)20 by failing to manage his staff’s communications with the
client.
(v) SDBD No. 7723
The State Bar alleged that the client hired Brock and Pow-
ell to represent her in three different cases. Brock did not com-
municate with the client about her cases and failed to respond to
discovery requests in one case, resulting in the case being dis-
missed. Brock then failed to refile the case within the renewal
period, and the case was barred by the statute of limitations.
When the client learned that her claim was time-barred due to
Brock’s actions, the client filed a grievance against Brock, to
which Brock responded that he deliberately allowed the case to
be dismissed with the client’s permission because it had “signifi-
cant causation issues.” On the second case, Brock informed the
client that he had settled the case for $6,666.66 and purportedly
presented her with a “Hold Harmless Agreement” that he claimed
was prepared by an insurance company. But the insurer did not
actually provide Brock with this agreement, and Brock never pro-
vided the client with a settlement statement and failed to pay any
of her medical providers. At the time she filed her grievance, the
client had not received any funds from her alleged $6,666.66 set-
tlement. In response to the grievance, Brock blamed the delay in
20 Rule 5.3(c) provides, in relevant part, that “a lawyer shall be respon-
sible for conduct of [a nonlawyer under his employment] that would be a viola-
tion of the [GRPC] if engaged in by a lawyer.”

12
disbursing the settlement funds on his former paralegal’s “mis-
management of the client file.” Following the grievance, Brock
withdrew $8,368 from his IOLTA, obtained two cashier’s checks
payable to the client in the amounts of $3,418 and $4,950, but
delivered only the $3,418 check to the client. Additionally, Brock
did not promptly satisfy a lien against the client for her medical
bills and, as a result, her Social Security benefits were garnished.
On the third case, Brock filed the suit but took little action to
prosecute the case. The client then terminated Brock’s represen-
tation and hired new counsel.
The Special Master found that Brock mismanaged the cli-
ent’s cases and some of her claims were extinguished because
Brock did not timely pursue certain filings. Despite his claims
that one of the client’s cases had been dismissed because of cau-
sation issues, Brock admitted at the evidentiary hearing that the
case had been dismissed because of his failure to meet discovery
requirements and to file a renewal action.
The hold-harmless agreement was a deliberately mislead-
ing document, and particularly troublesome, because the client
testified that she had never actually seen or signed the document
and Brock had apparently forged the client’s signature. Brock’s
reason for creating the bogus agreement and signing the client’s
name on it — because the insurer directed him to do so — was not
credible. Additionally, although Brock delivered one of the cash-
ier’s checks, the remainder of the settlement funds were unac-
counted for.
Regarding 	the 	Social 	Security 	garnishment, 	although
Brock blamed his failure to protect the client from garnishment
on account of Medicare not sending him a lien and his own inabil-
ity to navigate the federal government’s portal, Brock testified

13
that he was familiar with the portal used to access claim infor-
mation and admitted that it was his duty to determine for which
charges Medicare was seeking reimbursement.
Based on these findings, Brock violated Rules 1.3 by failing
to act with reasonable diligence in disbursing settlement funds
and 1.5(c) by failing to prepare a proper settlement statement.
Brock also violated Rules 1.2(a) by failing to abide by the client’s
objectives of representation; 1.4 by failing to communicate truth-
fully and completely with the client about the status of her mat-
ters; 1.15(I)(a) by converting the client’s settlement funds to his
own use; 1.15(I)(b) by disregarding known obligations regarding
the settlement funds; 1.15(I)(c) by failing to promptly deliver the
recovery funds to the client’s medical providers; 8.4(a)(4) by
falsely telling the client that one of her cases had been dismissed
due to causation problems when it was Brock’s negligence that
caused it to be dismissed; and 9.3 by presenting a fabricated doc-
ument to the disciplinary authorities in violation of the GRPC. 21
(vi) SDBD No. 7724
The State Bar alleged that the client hired Brock to handle
a premises liability matter after she slipped and broke her leg.
Brock failed to communicate with the client regarding the status
of her matter or prepare her for her deposition. The defendants
filed a motion for summary judgment alleging that there was no
premises liability because the client had slipped on rainwater,
and Brock failed to timely respond to the motion. Brock eventu-
ally submitted untimely affidavits from other witnesses who
stated that the client had not slipped on rainwater. Subsequently,
21 Again, the Special Master noted that this conduct also supported a
Rule 8.1(a) violation, but that this Rule was not charged in the formal com-
plaint, so we do not address it here.

14
Brock’s former paralegal contacted the client to give her an honest
status update in her matter and told her that Brock had failed to
timely respond to the motion. The client hired new counsel and
contacted Brock to discuss his failure to timely respond to the mo-
tion for summary judgment, and Brock told her that the case was
fine. However, the trial court subsequently granted the motion for
summary judgment, noting that it was not considering the un-
timely affidavits.
The Special Master found that Brock admitted in his sec-
ond petition that he failed to timely respond to the defendants’
summary judgment motion, which demonstrated a lack of capac-
ity and a disregard of the client’s case to her detriment. Brock
admitted at the evidentiary hearing that had he timely responded
with evidentiary support, the defendants’ motion for summary
judgment likely would have been denied.
Brock’s conduct amounted to violations of Rules 1.1 by fail-
ing to provide competent representation and 1.3 by failing to dil-
igently respond to the opposing party’s motion for summary judg-
ment, which led to the client’s matter being dismissed. The record
also showed that Brock violated Rules 1.2(a) by failing to abide by
the client’s objectives of the representation and 1.4 by failing to
communicate with the client completely and truthfully.
(b) ABA Standards
After discussing her findings of fact and conclusions of law
as to the Rules violated, the Special Master applied the frame-
work set out in the ABA Standards for Imposing Lawyer Sanc-
tions (1992) (“ABA Standards”). 22 The Special Master determined
22 See ABA Standard 3.0 (when imposing a sanction, “a court should

15
that Brock violated his duty of competence owed to his clients;
that his actions and repeated Rule violations were knowing and
intentional; and that his conduct harmed the reputation of the
profession and his clients were injured by his creation of false set-
tlement documents, the conversion of client funds to his own use,
and his failure to pursue their claims.
The Special Master determined that several aggravating
factors were applicable: prior disciplinary history; a dishonest or
selfish motive, as Brock “persistently resorted to dishonesty in or-
der to selfishly conceal his misconduct”; a pattern of misconduct;
multiple offenses; bad faith obstruction of the disciplinary pro-
ceedings, as his “overall approach to this disciplinary matter has
been an attempt, in bad faith, to obstruct the finding of the truth”;
refusal to acknowledge the wrongful nature of his conduct, as he
continued to “obfuscate the truth or blame others”; the vulnera-
bility of his victims; substantial experience in the practice of law;
and indifference to making restitution “except strictly according
to his own terms.” See ABA Standard 9.22(a), (b), (c), (d), (e), (g),
(h), (i), and (j). 23
Regarding mitigating circumstances, the Special Master
acknowledged Brock’s claims that, during the period of miscon-
duct, he was caring for his son, who has autism, and had to close
consider the following factors: (a) the duty violated; (b) the lawyer’s mental
state; (c) the potential or actual injury caused by the lawyer’s misconduct; and
(d) the existence of aggravating or mitigating factors”).
23 The Special Master also determined that the submission of false ev-
idence during the disciplinary process was applicable as an aggravating factor.
See ABA Standard 9.22(f). However, this same conduct was also used to sup-
port the Rule 9.3 violation, and “this Court generally declines to rely on con-
duct in aggravation of discipline when the same specific conduct is also charged
as a violation of the GRPC.” See In the Matter of Hood, 320 Ga. 440, 445 n.15
(2024).

16
an unrelated business due to financial difficulties caused by the
Covid-19 pandemic. The Special Master explained that such cir-
cumstances “might have provided some mitigating context for a
few isolated violations” but “less so for the tidal wave of ethical
misconduct in [these] cases.” Further, the Special Master ex-
plained that several mitigating factors did not apply, as Brock did
not make a timely good-faith effort to make restitution and his
display of remorse was undermined by his failure to accept re-
sponsibility for so many of his violations. See ABA Standard
9.32(d) and (l).
(c) 	Recommended Discipline
The Special Master then concluded that disbarment was
the appropriate penalty for Brock’s Rule violations. Further, the
Special Master recommended that the Court require Brock to pay
restitution to his clients as a condition for reinstatement.
3. 	Review Board’s Report and Recommendation
Brock filed exceptions to the Special Master’s report and
recommendation. The Review Board adopted the Special Master’s
findings of fact, conclusions of law as to the Rules violated, deter-
minations regarding the ABA standards, and recommendation of
disbarment. But the Review Board made no recommendations as
to restitution.
4. 	Brock’s Exceptions
Brock filed exceptions in this Court to the Review Board’s
report and recommendation. In his exceptions, Brock contends
that the Special Master adopted the State Bar’s proposed report
and recommendation without conducting her own independent
analysis; that the Special Master made several erroneous find-

17
ings of fact, conclusions of law as to the Rules violated, and deter-
minations regarding the ABA Standards; and that Brock’s re-
quested one-year suspension is a more appropriate sanction than
disbarment. The State Bar challenges these contentions.
5. 	Analysis
(a) The Special Master’s Report
We first address Brock’s contention that the Special Master
erred by adopting the State Bar’s proposed report and recommen-
dation. The record shows that following the evidentiary hearing,
the Special Master asked both Brock and the State Bar to submit
proposed reports for her review and consideration, which is com-
mon practice in disciplinary matters. 24 According to Brock, the
Special Master adopted the State Bar’s report without conducting
a meaningful review or any independent analysis. But he pro-
vides no evidence for his assertion that the Special Master did not
conduct her own analysis before issuing the report. Further, while
it is not clear from the record the extent to which the Special Mas-
ter relied upon or adopted the State Bar’s report, we are not aware
of any legal principle prohibiting this practice, and Brock has
cited none. Accordingly, we reject this contention of error as mer-
itless.
(b) The Special Master’s Factual Findings and Legal Con-
clusions
Brock next argues that several of the Special Master’s fac-
tual findings and conclusions of law regarding the Rules violated
are erroneous. Specifically, Brock argues that the Special Master
erred by failing to take into consideration several explanations for
24 The submitted proposed reports were not included in the record.

18
his conduct that rebut many of his alleged Rule violations, includ-
ing that the overdrafts in the trust accounting matters were due
to fraudulent activity and a bank error and that he never con-
verted client funds to his own use; that his former paralegal sab-
otaged his firm by removing several client files, diverting settle-
ment checks, and orchestrating the submission of the client griev-
ances; and that he attempted to give the client in SDBD No. 7720
her settlement check, but neither the client nor her new attorney
would communicate with him. The record shows that the Special
Master considered Brock’s proffered explanations. The Special
Master was authorized to reject Brock’s attempt to blame third
parties for his misconduct upon finding that Brock’s testimony
was not credible and, in any case, did not erase the fact that the
overwhelming 	evidence, 	including 	Brock’s 	own 	admissions,
showed that he committed several serious ethical violations
against his clients. See In the Matter of Tuggle, 317 Ga. 255, 258
(2023) (because “the special master is in the best position to de-
termine the witnesses’ credibility,” this Court “generally defers to
the factual findings and credibility determinations made by the
special master unless those findings or determinations are clearly
erroneous” (cleaned up)).
Brock also argues that the State Bar failed to prove several
Rule violations. “[W]e review de novo the conclusions of law
reached below on what rules were violated.” Id. Upon our review,
we question whether the evidence supports Brock’s violation of
Rule 9.3 in SDBD No. 7723. Although there is no dispute that the
hold-harmless agreement was fabricated, the evidence does not
show that it was created during the course of the investigation
such that it amounted to a Rule 9.3 violation.
We also question whether Brock violated Rule 1.4 in SDBD

19
No. 7724. Although the State Bar alleged that Brock failed to com-
municate with the client in this matter, it did not produce evi-
dence at the hearing to show Brock’s lack of communication, nor
did Brock admit in his second petition that he failed to communi-
cate with this client.
It is also unclear that the evidence supports the Special
Master’s conclusion that Brock violated Rule 1.5(a) in SDBD No.
7720 because his claim that he was entitled to $40,000 of the
$100,000 settlement as his fees for the case was “unreasonable
under the circumstances.” Although the Special Master rightly
concluded that Brock’s handling of the client’s case violated other
Rules, including by initially converting the entire recovery for his
own use (Rule 8.4(a)(4)) and by not providing the client a written
settlement statement (Rule 1.5(c)(2)), there is no dispute that
Brock later attempted to give the client $60,000, albeit after the
client filed a grievance against him. The Special Master relied on
the fact that the client never agreed to a $40,000 amount as a
reasonable fee arrangement. But the client testified that she re-
jected the $60,000 because Brock initially converted all of the
funds for his own use. The record is silent as to what amount or
percentage, if any, the client had agreed to regarding a fee ar-
rangement. The lack of a written fee arrangement does constitute
a violation of Rule 1.5(c). But the lack of evidence as to any fee
agreement does not establish that the $40,000 that Brock claimed
he was entitled to retain was unreasonable such that it would
constitute a violation of Rule 1.5(a), as the Special Master con-
cluded.
Despite our doubts as to these three charges, it is clear
from the record that Brock committed every other Rule violation
for which he was formally charged and that supported the recom-

20
mended sanction of disbarment, so we need not address the mer-
its of these three charged violations. See In the Matter of Dalziel,
322 Ga. 212, 217 (2026) (pretermitting consideration of whether
attorney violated Rule 3.1 “because it would not change the ap-
propriate discipline”).
Brock also argues that many of the Rule violations are un-
fairly duplicative because they are based upon the same conduct,
that the State Bar conceded that several of the Rule violations it
had alleged in the formal complaints were inapplicable by agree-
ing to the second petition, and that he cannot be determined to
have violated the Rules charged in SDBD Nos. 7722 and 7724 be-
cause the clients in these matters did not testify. But this claim
fails because every Rule in the GRPC outlines different, specific
prohibited actions and the Special Master adequately explained
how Brock’s conduct violated each individual Rule. Further, there
is no indication from the record that by agreeing to the second
petition, in which Brock admitted only some Rule violations, the
State Bar in any way conceded that the other Rules charged in
the formal complaints were inapplicable. Finally, we have never
required the State Bar to introduce client testimony in order to
establish that an attorney has violated the GRPC, and the Special
Master was authorized to conclude that Brock violated the Rules
charged in these matters based on his own admissions in his sec-
ond petition, his testimony, and the testimony of his former par-
alegal. Accordingly, this contention lacks merit.
(c) 	The Special Master’s Determinations of the ABA Stand-
ards
Brock also takes issue with the Special Master’s determi-
nations regarding the aggravating and mitigating factors. We
have explained that “whether the facts constitute an aggravating

21
or mitigating factor is a matter we consider de novo.” In the Mat-
ter of Melnick, 319 Ga. 730, 738 (2024). And, upon our review, we
reject Brock’s argument that the Special Master erred in her de-
terminations as to these factors. Regarding aggravating factors,
Brock contends that the Special Master erred in considering his
failure to take responsibility for his misconduct as an aggravating
factor, relying on this Court’s explanation in In the Matter of Tay-
lor that “refusing to admit guilt from the outset generally means
the mitigating effect of showing remorse — one factor among
many — is absent, not that the aggravating effect of refusing to
acknowledge [the] wrongful nature of [one’s] conduct is present.”
323 Ga. 214, 236 (2025) (punctuation omitted). But even if the
Special Master erred in this respect, the Special Master found
many other aggravating factors that Brock does not challenge and
which are supported by the record, including his prior discipli-
nary history, the multiple Rules violations, his dishonest or self-
ish motive in violating the Rules, the vulnerability of his victims,
and his indifference to making restitution “except strictly accord-
ing to his own terms.”
As for mitigation, Brock argues that the Special Master
failed to consider that he faced significant stressors during the
operative period, including the financial and legal burdens of clos-
ing a business heavily affected by the Covid-19 pandemic; that he
took on full-time legal practice responsibilities while dealing with
the sudden departure of his staff and clients; and that he provided
intensive caregiving for his son. But we agree with the Special
Master that 	such circumstances fail to justify Brock’s systemic
misconduct in these matters.
(d) The Appropriate Discipline
Finally, Brock argues that the Special Master’s recommen-
dation of disbarment is too severe and asks this Court to impose

22
a punishment more in line with the one-year suspension as re-
quested in his second petition. We disagree. Brock admitted in his
second 	petition 	that 	he 	violated 	Rules 	1.1, 	1.3, 	1.4, 	1.5(c),
1.15(I)(a), 1.15(II)(b), and 8.4(a)(4) in connection with his mis-
management of two IOLTAs and conduct in five client matters.
These Rule violations alone are sufficient to warrant disbarment.
See, e.g., In the Matter of Crowther, 318 Ga. 277 (2024) (attorney
disbarred for violations of Rules 1.3, 1.4, 1.5, 1.8(e), 1.15(I),
1.15(II), and 8.4(a)(4) in connection with two separate cases); In
the Matter of Lemoine, 322 Ga. 463 (2025) (attorney disbarred for
violations of Rules 1.2(a) 1.3, 1.4, 1.15(I)(a), 1.15(I)(c), 1.15(II)(c),
1.15(III), and 8.4(a)(4) in connection with two disciplinary mat-
ters even where attorney had no prior disciplinary history); In the
Matter of Harris, 301 Ga. 378, 379 (2017) (attorney disbarred for
violations 	of 	Rules 	1.15(I) and 1.15(II) by 	“misappropriat[ing]
trust funds and commingl[ing] those funds with his own,” even
though attorney deposited personal funds to cure deficiencies in
his trust account).
Further, given the number of Brock’s Rule violations, their
severity, his repeated dishonesty, and the several applicable ag-
gravating factors — including prior discipline for failure to abide
by the GRPC’s trust accounting rules — disbarment is the appro-
priate sanction. We further agree with the Special Master that,
should Brock ever seek readmission, he must first make full res-
titution to all affected clients and proof of restitution must be of-
fered to this Court and the State Bar.
Accordingly, it is hereby ordered that the name of Hakeem
Bertrand Brock be removed from the roll of persons authorized to
practice law in the State of Georgia. Brock is reminded of his du-
ties under Bar Rule 4-219(b).
Disbarred. All the Justices concur.