Order re Disciplinary Referral — No. 3:21-cr-00018 (Dkt. 274, N.D. Cal.)

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An order re disciplinary referral by United States District Judge Charles R. Breyer in USA v. Stevenson, Case No. 21-cr-00018-CRB-1, in the U.S. District Court for the Northern District of California, filed September 8, 2026 as Document 274. The order states that the defendant was convicted of wire fraud and that it concerns his counsel, Jeremy Ross and Ryan D'Ambrosio, describing the court's view of their conduct as the most egregious example of ineffective assistance of counsel it has seen. It lists examples including improper statements before the jury, tardiness, failure to prepare witnesses and failure to proffer exhibits. The court refers both lawyers to the district's Standing Committee on Professional Conduct and to the State Bar of California, and orders them to self-report by September 15, 2026.

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Case 3:21-cr-00018-CRB        Document 274      Filed 09/08/26    Page 1 of 2




                                   1
                                   2
                                   3
                                   4
                                   5                        IN THE UNITED STATES DISTRICT COURT
                                   6                    FOR THE NORTHERN DISTRICT OF CALIFORNIA
                                   7
                                   8     USA,                                          Case No. 21-cr-00018-CRB-1
                                   9                  Plaintiff,
                                                                                       ORDER RE DISCIPLINARY
                                  10            v.                                     REFERRAL
                                  11     STEVENSON,
                                  12                  Defendant.



 United States District Court
                                  13         Defendant was convicted of wire fraud. But his counsel, Jeremy Ross and Ryan
                                  14   D’Ambrosio, are the subject of this order. In the Court’s view, it has never seen a more
                                  15   egregious example of ineffective assistance of counsel. Here are some examples of Ross



Northern District of California
                                  16   and D’Ambrosio’s poor and unprofessional conduct:
                                  17             • Improper statements before the jury, such as asking about the Government’s
                                  18                 readiness to cross-examine Defendant when counsel had represented that
                                  19                 Defendant would not testify;
                                  20             • Tardiness;
                                  21             • Improper outbursts, such as crying during offers of proof and improperly
                                  22                 delaying the questioning of witnesses;
                                  23             • Failure to prepare witnesses—including Defendant—for direct or cross-
                                  24                 examination;
                                  25             • Failure to proffer relevant exhibits during the defense case-in-chief and
                                  26                 waiting until after the Government’s closing argument to disclose potentially
                                  27                 relevant evidence, which ignored disclosure obligations and authenticity
                                  28                 requirements;

                                       Case 3:21-cr-00018-CRB          Document 274        Filed 09/08/26   Page 2 of 2




                                   1               • Failure to proffer a finished Rule 16 report of their expert to the Government
                                   2                  until after the prosecution’s case-in-chief, with the report also including
                                   3                  improper opinions;
                                   4               • Failure to make a Rule 29 motion;
                                   5               • Failure to provide an instruction on the defense theory of the case;
                                   6               • Failure to know and follow the Federal Rules of Evidence;
                                   7               • Failure to provide Defendant with the Government’s offer of a plea
                                   8                  agreement; and
                                   9               • Delay and mismanagement of production of materials to post-trial counsel.
                                  10   See, e.g., July 8, 2026 Tr. (dkt. 273) 6:24–9:22.
                                  11            Ross and D’Ambrosio’s conduct suggests that they are likely unable to represent
                                  12   their clients in accordance with California Rule of Professional Conduct 1.1, which



 United States District Court
                                  13   provides that a “lawyer shall not intentionally, recklessly, with gross negligence, or
                                  14   repeatedly fail to perform legal services with competence.” Cal. R. Pro. Conduct Rule
                                  15   1.1(a). “Competence” includes the ability to apply the “mental, emotional, and physical



Northern District of California
                                  16   ability reasonably necessary for the performance of [legal] services.” Cal. R. Pro. Conduct
                                  17   Rule 1.1(b).
                                  18            Considering the foregoing, the Court refers Ross and D’Ambrosio to the Northern
                                  19   District’s Standing Committee on Professional Conduct for investigation and appropriate
                                  20   sanctions pursuant to Criminal Local Rule 2-1 and Civil Local Rule 11-6(e). The Court
                                  21   also refers Ross and D’Ambrosio to the State Bar of California for appropriate discipline.
                                  22   Accordingly, Ross and D’Ambrosio must self-report to the State Bar regarding the issues
                                  23   outlined in this Order by no later than September 15, 2026. Ross and D’Ambrosio shall
                                  24   certify to this Court by no later than September 21, 2026, that they have complied with this
                                  25   Order.
                                  26            IT IS SO ORDERED.
                                  27            Dated: September 8, 2026
                                                                                           CHARLES R. BREYER
                                  28                                                       United States District Judge
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