Now, judges have been warned to be on the lookout for Zakrajsek, who has been handling tenant-landlord disputes and other lower-profile civil cases.
On October 15, Zakrajsek appeared before Superior Court Judge Cari Harrison. She was there to ask the judge to certify her as a pro hac vice attorney -- a lawyer from another state who wants to represent a client in Arizona.
Such applications are granted routinely after an applicant completes a two-page form. Among other things, it asks where the attorney's office is located, and where he or she has been admitted to practice law. The out-of-towner also must list a local attorney "with whom the court and opposing counsel may readily communicate regarding the conduct of this case."
Finally, the applicant must sign under a line that says, "I am not currently suspended or disbarred in any court."
Zakrajsek listed a North Aurora, Illinois, address, and said she'd been admitted to practice law in California. She listed two other cases in which she'd applied for pro hac vice status in the past two years. Zakrajsek said correctly that judges in both cases -- one in Superior Court and the other in the Arizona Court of Appeals -- had granted her request.
But Harrison, acting on information provided by opposing counsel, booted Zakrajsek out of her court in a civil case that concerned a contract dispute between a medical clinic and Zakrajsek's two clients. After the hearing, Harrison sent an unusual e-mail to her colleagues at Superior Court, accusing Zakrajsek of misrepresenting herself in her application.
"As far as I can tell, she has at least four or five cases pending in Superior Court, as well as at least one in the Court of Appeals," Harrison wrote. "She also uses the name of Connie Arenberg, primarily for notarizing documents. . . . At least two of the attorneys she has listed in her applications to act as local counsel have either never consented or have withdrawn their consent after the application was filed.
"I [told] Ms. Zakrajsek that she was abusing the pro hac vice process, and needed to become licensed in Arizona if she wished to continue representing clients in Arizona courts. . . . Please carefully review any applications you receive from Ms. Zakrajsek."
Turns out Judge Harrison was on the money, says Fran Johansen of the State Bar of Arizona.
"This woman has quite the checkered background," Johansen says. "Let's start with the disbarments in Illinois and the state of Washington."
Records from three states indicate that Connie Zakrajsek/Arenberg/Fernandez first was licensed to practice law in June 1992, in California. She passed the bar there after graduating from the Willamette University School of Law in Oregon.
In the 1990s, Zakrajsek moved to Cook County, Illinois, where she went by the name of Connie Fernandez (it's not certain if that was a married name) and represented tenants in disputes with landlords. But in March 2000, the hearing board of the Illinois Attorney Registration and Disciplinary Commission found her guilty of 26 counts of abusing her clients financially and otherwise over a three-year period that ended in 1997.
"[Her] misconduct amounts to a pattern of misconduct over a period of several years, which affected numerous clients," the hearing board unanimously concluded in its 120-page report. "[Her] pattern of conversion [of funds] and neglect, along with her lack of remorse, can only be described as disturbing."
In recommending Zakrajsek's disbarment, the board added that she'd "engaged in conduct involving dishonesty, fraud, deceit or misrepresentation."
By this time, Zakrajsek had yet another new name, Connie Arenberg, after her marriage to David Arenberg, a self-proclaimed political activist for renters' rights. The Arenbergs moved to Arizona, where they hooked up for a time with locals already involved in the business of assisting, for a fee, tenants in disputes with landlords.
Last March 30, the Supreme Court of Washington also disbarred Connie Arenberg, citing a local rule that says a disbarment in one state "conclusively establishes the misconduct for purposes of a disciplinary proceeding in this state."
Despite her disbarment in two states, Zakrajsek remains licensed to practice law in California, according to State Bar of California spokesperson Marlon Villa. "You're not disbarred automatically in California if you're disbarred somewhere else," Villa explains. "I have no record available that tells me if we got information from anyone about this woman's problems in other states."
New Times called a Tempe phone number listed in Zakrajsek's name on the State Bar of California's Web site. No one returned a message left at the number. A woman on a message machine said she was with the "Arizona Tenant's Rights Network." Arizona Corporation Commission records show Zakrajsek formed that nonprofit corporation in October 2000, though an annual report due November 4 has not been filed.
In a rambling legal memo sent last August to an attorney who had questioned her credentials in a pro hac vice cases, Zakrajsek responded: "I trust God to take care of my reputation and He tells me that I am His righteousness in and through Jesus Christ (I'm really a preacher too!)"
No one can say for sure exactly how many pro hac vice cases Zakrajsek successfully has filed in Maricopa County, or if she's still the attorney of record in any of those cases. Presiding Superior Court Judge Colin Campbell concedes, "We haven't had a system in place to check up on out-of-town attorneys making pro hac vice applications, which are meant to be rare and occasional, and certainly not an everyday thing in this court and that court."
And the State Bar of Arizona has been powerless to do anything about Zakrajsek, other than to collect information about her from other states.
But Campbell adds that a new Supreme Court rule, which went into effect on December 1, should help keep the Connie Zakrajseks of the legal world at bay. The rule includes the provision, "Attorneys who are residents of the state of Arizona, who are employed in Arizona or who regularly engage in substantial business, professional or other activities in Arizona are not eligible to appear pro hac vice."
The new rule also mandates that the attorney file paperwork with the State Bar of Arizona, which is supposed to check on his or her credentials before an application is granted.
