In JJJJ Walker, LLC v. Yollick, 447 S.W.3d 453 (Tex. App.--Houston 14th Dist. 2014, pet. filed), the Fourteenth Court of Appeals held that "an attorney can be held liable for his own fraudulent conduct even though it was performed on a client's behalf." In Yollick, after a hospital system filed for bankruptcy relief, a group of investors sought to purchase its assets, namely, three hospitals, from the creditor bank. Id. at 455. The bank's attorney, Yollick, negotiated with the investors, created a company to hold the assets, and provided the purchase money and funds for initial working capital. Id. at 455-56. When the investors needed additional working capital, they executed a letter agreement, assigning their membership interests in the company that was holding the hospitals to a new entity under the bank's control. Id. at 456. Yollick then appointed his wife, using a fictitious name, and two of his friends to act as the board of directors of the new entity. Id. And he executed an elaborate scheme to take over the company that was holding the hospitals. Id. at 457. He removed each of the investors as officers and replaced them with himself as sole officer, manager, president, secretary, and chief executive officer. Id. He then sold the hospitals for $55 million and paid the investors nothing. Id. at 458. In the investors' appeal from the trial court's judgment in favor of Yollick on their fraud claim, Yollick argued that he was entitled to immunity as a matter of law because an attorney is not liable for statements made in the course of representing his client in adversarial proceedings. See id. at 468-69. The Fourteenth Court explained that Yollick, in signing the letter agreement "as the Bank's agent," was "not relying on his professional knowledge and training as an attorney to make a statement in the course of representing his client in an adversarial context." Id. at 469-70. Rather, "he was simply signing his name, acting as the Bank's agent with actual authority to bind his principal to a promise of future performance." Id. at 470. And because he did so "knowing that the Bank did not intend to perform as promised, he can be held liable for his conduct just as any other agent or corporate representative would be." Id. The court noted that Yollick was "not to be held to a lower standard" simply because he happened to also be the principal's attorney. Id.