Monthly Archives: August 2012

Florida 3rd District Court of Appeal affirms that lawyer’s receipt and “skimming” of confidential mediation statement does not require disqualification

Hello everyone and welcome to this Ethics Alert which will discuss the recent opinion of the Third District Court of Appeal in which it held that a lawyer’s receipt and “skimming” of confidential mediation statement of the opposing party does not require the disqualification of the party’s lawyer.  The opinion is Maribor v. Dreiling, Fla. Dist. Ct. App. 3d Dist., No. 3D12-300 (8/22/12) and is attached.

During extensive litigation between siblings over their mother’s estate, the plaintiff’s lawyer asked an assistant to serve a summary judgment motion by e-mailing a copy to defendants’ lawyers at the Heller Waldman law firm and mailing a hard copy.  After e-mailing the motion, the assistant realized that the e-mail did not mention that a copy would also be mailed and she sent a follow-up e-mail noting that she had sent a hard copy.  The assistant inadvertently attached a confidential mediation statement to the e-mail instead of the summary judgment motion.  The e-mails were sent to two Heller Waldman partners, Glen Waldman and Eleanor Barnett, and their assistant.  Waldman and the assistant never reviewed the statement.

According to the opinion, Barnett was out of the office when she received the e-mails on her mobile telephone and did not open them.  When she returned to the office, she instructed her assistant to print out the summary judgment motion and “whatever came in while I was out related to this cause.”  The assistant printed out a copy of the motion and the mediation statement, and forwarded the e-mails and their attachments to the clients.

The lawyer read the summary judgment motion and began to “skim” the mediation statement after checking to confirm that it did not contain a prominent confidentiality notice and assumed it was sent intentionally.  Later the same day, the lawyer sent opposing counsel an e-mail about a scheduling issue mentioned in the mediation statement.  After receiving the e-mail, the opposing lawyer realized the inadvertent disclosure and requested that all copies of the mediation statement be destroyed and the lawyer immediately complied.

The opposing party then moved to disqualify, claiming that the receiving lawyers violated Rule 4-4.4(b), Rules Regulating The Florida Bar, which states that “(a) lawyer who receives a document relating to the representation of the lawyer’s client and knows or reasonably should know that the document was inadvertently sent shall promptly notify the sender.”  The trial court appointed a special master, who found that the confidential mediation statement was essentially a position paper stating obvious and well-established positions of each side in the litigation.

According to the special master’s report, the mediation statement outlined uncontested facts, “(made) passing comments on the obvious motivations of the parties”, and tracked the legal issues without revealing any weakness in the plaintiff’s case or providing any information that would give the defendants a tactical, strategic, or legal advantage.  The trial court issued an order adopting the special master’s recommendation and denied the motion to disqualify.  The opposing party appealed and the opinion affirmed the trial court’s order refusing to disqualify the lawyer or firm.

In affirming, the opinion pointed to the lawyer’s assertion that she did not realize the statement was confidential before skimming it and the fact that she had all copies destroyed immediately after she learned that it had been sent in error.  In addition, affidavits in the record documented the minimal review of the statement and eliminated any possibility that the lawyer or the firm obtained an unfair informational advantage in the case.  According to the opinion, “the events that transpired in this case are not attributable to unethical conduct…(but) illustrate some of the adverse consequences resulting from the injection of technology into today’s modern and busy law practice.”  (emphasis added).

The opinion also cited Florida case law and provided the following elements for review in determining whether a lawyer should be disqualified based on inadvertent disclosure of confidential information:

The receipt of an inadvertent disclosure warrants disqualification when the movant establishes that: (1) the inadvertently disclosed information is protected, either by privilege or confidentiality; and (2) there is a “possibility” that the receiving party has obtained an “unfair” “informational advantage” as a result of the inadvertent disclosure.

The opinion stated that the above two elements must be considered together since only an inadvertent disclosure of privileged or confidential information can yield an “unfair” informational advantage and the fact that inadvertently disclosed information is privileged or confidential, standing alone, does not automatically require disqualification.  The second element is also broader than the first and, in determining whether to disqualify a lawyer, courts should look not only to the content of the inadvertent disclosure, but also to the actions the receiving lawyers took upon receiving the inadvertent disclosure.

The opinion listed two reasons why courts should focus on the actions of the receiving lawyer/law firm:

First, it would be impossible to evaluate the possibility of an unfair advantage without knowing how and to what extent the lawyers reviewed, copied, or disseminated the inadvertently disclosed information.  The opinion noted that, in Atlas Air v. Greenberg Traurig P.A., 997 So. 2d 1117 (Fla. 3rd DCA 2008), the lawyer asserted attorney-client privilege and work product protection when asked during deposition whether privileged materials were provided to other attorneys in the firm and the lawyer’s refusal to answer made it impossible to determine the extent of the tactical advantage that the lawyer/law firm may have gained.

Second, the actions of the receiving lawyers may assist in determining whether any informational advantage was received “unfairly,” as in Abamar Housing & Dev. Inc. v. Lisa Daly Lady Decor Inc., 724 So. 2d 572 (Fla. 3rd DCA 1998).  The Abamar opinion focused on the receiving lawyer’s failure to take steps to mitigate the inadvertent disclosure and found that a lawyer who complies with the Rules of Professional Conduct upon receiving an inadvertent disclosure will not be subject to disqualification.

After conducting the above analysis, the opinion agreed with the special master that nothing within the mediation statement created a possibility that the defendants gained an informational advantage and that the brief and cursory nature of the receiving lawyers’ exposure to the statement and the minimal way in which they handled, reviewed, and disseminated it, showed there was no possibility that the firm gained an unfair informational advantage.  The opinion also found that the trial court correctly rejected the plaintiff’s argument that the lawyers violated Florida Bar Rule 4-4.4(b) since the record supported the findings that the receiving lawyer did not know that the mediation statement was confidential and that this lack of knowledge was reasonable under the circumstances.

With regard to the mediation statement, the opinion stated that nothing in a mediation statement automatically alerts a person that it is confidential since  it is not uncommon for a party to send a mediation statement to opposing counsel and trial judges sometimes require it to be sent.  The opinion also stated that the mediation statement did not prominently indicate that it was confidential.  Although the first paragraph contained statement about the confidentiality of the statement, the receiving lawyer stated that she did not read that portion and, “(b)ecause the admonition was not placed in bold, underlined, italicized, capitalized, or otherwise designed to stand out to a reader who was merely skimming the document, it was reasonable for the trial court to conclude that (the lawyer) overlooked the admonition.”  Finally, the opinion noted that the lawyers mitigated the inadvertent disclosure since the receiving lawyer immediately had all copies of the mediation statement destroyed when she was notified that it was confidential.

Bottom line:  As the opinion said, “the events that transpired in this case are not attributable to unethical conduct… (but) illustrate some of the adverse consequences resulting from the injection of technology into today’s modern and busy law practice.”  Lawyers (and their assistants) must be extremely careful when sending documents as attachments to e-mails, particularly to opposing counsel!  Of course, the receiving lawyer should be very wary as well since there are certainly cases wherein a lawyer who inadvertently received and reviewed a confidential and/or privileged document or information was disqualified…or worse.

Be careful out there!

As always, if you have any questions about this Ethics Alert or need assistance, analysis, and guidance regarding these or any other ethics, risk management, or other issues, please do not hesitate to contact me.

Disclaimer: this e-mail does not contain any legal advice and the comments herein should not be relied upon by anyone who reads it.

Joseph A. Corsmeier, Esquire

Law Office of Joseph A. Corsmeier, P.A.

2454 McMullen Booth Road, Suite 431

Clearwater, Florida 33759

Office (727) 799-1688

Fax (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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New York lawyer is indicted for stealing client funds and falsifying documents submitted to grievance committee purportedly from clients asking that Bar complaints be withdrawn

Hello everyone and welcome to this Ethics Alert which will discuss the recent press release by the New York County District Attorney regarding a New York lawyer who was recently indicted for stealing personal injury settlement funds from numerous clients and then sending fraudulent letters to a New York disciplinary committee purportedly from clients requesting that their complaints be dismissed.  The New York County District Attorney’s (Cyrus Vance, Jr.) press release is here:  http://manhattanda.org/press-release/attorney-indicted-years-long-scheme-defraud-clients-0.

The lawyer, John M. Ioannou, who practices in Manhattan, was indicted on charges of misappropriating clients’ personal injury settlement funds and forging documents submitted to a disciplinary committee.  The charges include allegations that the lawyer stole “hundreds of thousands of dollars” from clients by having them sign documents authorizing the payments and then taking the money himself, according to the indictment filed by the New York County District Attorney’s Office.

According to the press release, the lawyer misappropriated the funds and then did not communicate with the clients.  After the clients filed complaints with the entity that investigates lawyer disciplinary complaints, the lawyer allegedly tried to make an agreement with the clients to turn over the money if they withdrew the Bar complaints.  When clients subsequently refused, the lawyer sent false letters to the disciplinary committee in their names purportedly requesting that the complaints be withdrawn. The lawyer also allegedly threatened to report other clients to law enforcement if they did not withdraw their complaints.

According to media reports, the lawyer pleaded not guilty on August 22, 2012 to all charges in the 19 count indictment, which include second and third degree grand larceny and second degree forgery, at his arraignment before an acting supreme court justice who set bail at either a $50,000.00 cash bond or a $100,000.00 secured bond.  Also according to the media reports, the lawyer was admitted in New York in 1983 and was suspended from practice for three months in 2011.  He also received a public censure in 2007 and two admonitions for misconduct in 2003 and 2004.

Bottom line:  Not much to say except for “don’t lie, cheat, and/or steal” and also the cover-up may be as bad as the crime.  Of course, this lawyer is presumed innocent unless and until he is proven guilty.

Be careful out there!

As always, if you have any questions about this Ethics Alert or need assistance, analysis, and guidance regarding these or any other ethics, risk management, or other issues, please do not hesitate to contact me.

THE LAW OFFICE OF JOSEPH A. CORSMEIER, P.A.

PROVIDES ETHICS ADVICE AND EXPERT OPINIONS TO LAWYERS AND LAW FIRMS

DEFENDS LAWYERS IN BAR MISSION AND DISCIPLINE CASES

(AND MUCH MORE!)

Disclaimer: this e-mail does not contain any legal advice and the comments herein should not be relied upon by anyone who reads it.

Joseph A. Corsmeier, Esquire

Law Office of Joseph A. Corsmeier, P.A.

2454 McMullen Booth Road, Suite 431

Clearwater, Florida 33759

Office (727) 799-1688

Fax (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

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Florida Bar Ethics Opinion 93-3 states that fees designated as “non-refundable” may be excessive and prohibited under certain circumstances

Hello and welcome to this Ethics Alert blog which will discuss Florida Bar Ethics Opinion 93-2, which discusses, inter alia, the propriety and effect of the designation of a fee as “non-refundable”.  As I reported in a recent Ethics Alert, the Rules Committee of the Florida Bar’s Board of Governors voted not to move forward with a proposed Bar rule amendment which would have prohibited lawyers from charging non-refundable fees.  The proposed rule amendment was opposed by, among others, the Florida Association of Criminal Defense Lawyers (FACDL).  If it had been pursued, the proposed revision would have reversed the very long standing practice of permitting non-refundable fees and Florida Bar Ethics Opinion 93-2, which opines that non-refundable fees are arguably permitted, with certain caveats.

Florida Bar Ethics Opinion 93-2 was finalized on October 1, 1993, addressed 6 questions related to attorney’s fees, including non-refundable fees.  Question 5 is below:

“If a substantial nonrefundable fee is paid to the attorney and, before any services are performed by the attorney, the client dies, or discharges the attorney, or the services called for by the attorney-client employment agreement are no longer needed for some other reason, could the attorney be subject to discipline for charging a clearly excessive fee in violation of Rule 4-1.5(a) in the event of a refusal to refund any of the ‘nonrefundable fee?'”

The Professional Ethics Committee’s response and opinion is below:

“As we stated in Opinion 76-27 [since withdrawn], the lawyer might but would not necessarily be guilty of charging an excessive fee. Again, we get into definitions of terms. We interpret the question as referring to a payment by a client to a lawyer of a sum of money designated as “nonrefundable fee,” part of which is intended to compensate the lawyer for being available but not for specific services, and part of which is intended as a present payment for legal services to be performed in the future. If the lawyer performs no legal services, obtains no benefits for the client, and has not lost other employment opportunities as a result of agreeing to represent the client, we believe the lawyer might well be guilty of charging an excessive fee if no part of it was refunded.  Dealing with an abstract situation, we cannot be more precise.

On the other hand, an attorney of towering reputation just by agreeing to represent a client may cause a threatened lawsuit to vanish and thereby obtain a substantial benefit for the client and be entitled to keep the entire amount paid, particularly if other employment had been lost or declined in order to represent that particular client.

The Committee does not believe that, by designating a retainer as nonrefundable, a lawyer is automatically insulated from a claim that the fee is excessive. Whether or not the fee is excessive under the circumstances is governed by Rule 4-1.5 rather than use of the description ‘nonrefundable.'”

Bottom line:  Lawyers in Florida must be aware that the designation of a fee as “non-refundable” does not necessarily make it so.  According to Ethics Opinions 93-3, which is not binding or precedential, but may be persuasive, a lawyer who “performs no legal services, obtains no benefits for the client, and has not lost other employment opportunities as a result of agreeing to represent the client…might well be guilty of charging an excessive fee if no part of it was refunded.”

Be careful out there!

As always, if you have any questions about this Ethics Alert or need assistance, analysis, and guidance regarding these or any other ethics, risk management, or other issues, please do not hesitate to contact me.

Disclaimer: this e-mail does not contain any legal advice and the comments herein should not be relied upon by anyone who reads it.

Joseph A. Corsmeier, Esquire

Law Office of Joseph A. Corsmeier, P.A.

2454 McMullen Booth Road, Suite 431

Clearwater, Florida 33759

Office (727) 799-1688

Fax (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

 

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Update: Florida Bar’s Board of Governors directs Professional Ethics Committee to prepare opinion on cloud computing

Hello and welcome to this Ethics Alert which will provide an update on the status of the potential ethics advisory opinion on cloud computing and the recent decision of the Board of Governors of The Florida Bar (BOG) to direct Professional Ethics Committee (PEC) to prepare an ethics opinion on protecting client confidences when lawyers wish to store records via digital “cloud” computing using third party vendors.

As I previously advised, the PEC met in Orlando on June 22, 2012 and one of the agenda items for the meeting was a discussion of out-of-state ethics opinions on cloud computing and consideration of whether the committee should ask the Bar’s Board of Governors to direct the committee to adopt an opinion addressing the issue.  This discussion had been deferred at the February 3, 2012 PEC meeting due to time constraints.

According to the recent report of BOG members Andy Sasso and Sandra Diamond, the BOG met on July 27, 2012 and voted to direct the Professional Ethics Committee to prepare two ethics advisory opinions.  One ethics opinion will address the issue of lawyers allowing non-lawyer staff to use lawyers’ IDs and passwords when electronically filing documents with the state court system.  The second ethics opinion will address the important issue of protecting confidential client information when lawyers store records via digital cloud computing using third party vendors.

In addition to these opinions, the Standing Committee on Advertising will prepare an advisory opinion on another important issue in our digital age: the use of “metatags”, which are words or phrases that are invisible to the typical website viewer but which are designed to make the site score highly with Internet search engines – on lawyer websites. The standing committee requested that it be directed to write the opinion in the wake of complaints and reports that some law firms have used the names of non-firm lawyers, other firm names, and even the domain names of other lawyers and firms as “metatags” to enhance the likelihood they will be listed high by search engines.

If the PEC advisory opinion determines that digital cloud computing using third party vendors is ethical, Florida will join the 11 other states which have issued ethics opinions finding that such cloud computing is ethical and providing guidelines for its use.  The other opinions are here: Massachusetts Ethics Opinion 12-03, North Carolina 2011 Formal Ethics Opinion 6, Pennsylvania Formal Opinion 2011-200, California Formal Opinion No. 2010-179, Alabama State Bar Ethics Opinion 2010-02, Arizona State Bar Formal Opinion 09-04, Nevada State Bar Formal Opinion No. 33, New York State Bar Association Opinion 842 of 2010, Iowa Op. 11-01, Oregon Formal Op. 2011-188, Vermont Advisory Ethics Op. 2010-6.

As I previously advised, since no jurisdiction has previously opined that cloud computing is unethical, the advisory opinion will most likely set forth guidelines cloud computing for lawyers and will not recommend that the use of cloud computing be prohibited.  Florida Bar Ethics Opinion 10-2 (which is attached), provides guidance to lawyers to insure that client information on hard drives of discarded copiers, computers, scanners, and other electronic equipment is protected but does not address digital cloud computing.

Bottom line:  The PEC will be soliciting comments on the proposed cloud computing ethics opinion and debating the language of the opinion.  After the ethics advisory opinion is finalized and issued, it will provide Florida lawyers with more specific guidance in this area.  Stay tuned for further updates…

…and be careful out there!

As always, if you have any questions about this Ethics Alert or need assistance, analysis, and guidance regarding these or any other ethics, risk management, or other issues, please do not hesitate to contact me.

THE LAW OFFICE OF JOSEPH A. CORSMEIER, P.A.

Disclaimer:  this e-mail does not contain any legal advice and the comments herein should not be relied upon by anyone who reads it.

Joseph A. Corsmeier, Esquire

Law Office of Joseph A. Corsmeier, P.A.

2454 McMullen Booth Road, Suite 431

Clearwater, Florida 33759

Office (727) 799-1688

Fax     (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

 

 

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Florida Bar’s Professional Ethics Committee requests Board of Governors to direct it to prepare ethics opinion on cloud computing

Hello and welcome to this Ethics Alert blog which will discuss the recent request of the Professional Ethics Committee of The Florida Bar (PEC) to request that the Board of Governors of The Florida Bar (BOG) direct it to prepare an ethics opinion on protecting client confidences when lawyers want to store records via third party digital “cloud” computing.

The PEC met in Orlando on June 22, 2012 and one of the agenda items for the meeting was a discussion of out-of-state ethics opinions on cloud computing and consideration of whether the committee should ask the Bar’s Board of Governors to direct the committee to adopt an opinion addressing the issue. This discussion had been deferred at the February 3, 2012 PEC meeting due to time constraints. During the June meeting, PEC members discussed concerns with placing confidential client information in the custody of third parties on digital platforms since there are issues related to maintaining the security and confidentiality of (and access to) client records. There are no guidelines for Florida lawyers since there are no prior ethics opinions on the topic. The PEC ultimately voted unanimously to ask the Board of Governors to direct it to prepare the opinion.

If the BOG agrees and instructs the PEC to prepare the opinion, it will most likely set forth guidelines cloud computing for lawyers and will not recommend that the use of cloud computing be prohibited. Florida Bar Ethics Opinion 10-2 (which is attached), provides guidance to lawyers to insure that client information on hard drives of discarded copiers, computers, scanners, and other electronic equipment is protected but does not address digital cloud computing.

Bottom line: As I previously stated, there are no Florida Ethics Opinions which provide specific guidance to Florida lawyers to comply with Bar Rules when placing confidential client information on digital platforms outside of the lawyer’s office. Under the Bar Rules, the PEC is not permitted to prepare Ethics Opinions unless requested by the BOG (and under other limited circumstances). If the Board of Governors authorizes the Ethics Opinion (and the PEC prepares and finalizes the opinion), Florida lawyers will have more specific guidance in this area.

Be careful out there!

As always, if you have any questions about this Ethics Alert or need assistance, analysis, and guidance regarding these or any other ethics, risk management, or other issues, please do not hesitate to contact me.

Disclaimer: this e-mail does not contain any legal advice and the comments herein should not be relied upon by anyone who reads it.

Joseph A. Corsmeier, Esquire

Law Office of Joseph A. Corsmeier, P.A.

2454 McMullen Booth Road, Suite 431

Clearwater, Florida 33759

Office (727) 799-1688

Fax (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

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Florida Supreme Court imposes one year suspension on lawyer for disparaging client and revealing client’s confidences in court documents

Hello and welcome to this Ethics Alert blog which will discuss the recent disciplinary opinion of the Supreme Court of Florida which imposed a one (1) year suspension on a Florida lawyer who made disparaging comments about a client and revealed confidences in court pleadings.  The opinion increased the discipline from the 90 day suspension recommended by the referee and rejected the 91 day suspension requested by the Bar on review.  The case is The Florida Bar v. Petia Dimitrova Knowles, SC10-1019.  The opinion is here: TFB v. Knowles 7-12-12 one year suspension for disparaging client in court documents.

According to the Court’s opinion, the lawyer represented a client in an extensive immigration matter.  A few days before a 2009 hearing, the lawyer filed a motion to withdraw, stating that the client had given her a check for $1,000.00 that had been returned for insufficient funds.  The motion also implied the check was payment related to the immigration case; however, the check was actually related to an automobile accident matter in which the lawyer also represented the client.  The opinion states that “(the lawyer) also stated in the motion that she regretted helping her client, who had been rightly convicted of grand theft, and that (the lawyer’s) office had received reports from the Romanian community that her client had robbed them….(the lawyer) asserted in the motion that her client would not be prejudiced by her withdrawal as attorney.”

The client later agreed to pay the additional fees and the lawyer withdrew the motion.  The client then retained new counsel and the lawyer again filed a motion to withdraw and “asserted in her motion that she had received more reports that her client had intentionally failed to honor her contractual promises and had refused to pay for fulfilled work assignments.”  The lawyer also told a criminal prosecutor assigned to her client’s criminal case that “she had reason to believe her client would lie to the immigration court at an upcoming hearing.”  The prosecutor also anonymously received confidential paperwork from that immigration case, which the lawyer was the only person known to possess.

The referee recommended that the lawyer be found guilty of violating Bar Rule 4-8.4(d) (conduct prejudicial to the administration of justice) but recommended that the lawyer be found not guilty of any other rule violations, including Rule 4-1.6 (confidentiality of information).  The referee also recommended that the lawyer receive a 90 day suspension.  The Bar petitioned for review of the referee’s findings and recommendation that the lawyer be found not guilty of violating Bar Rule 4-1.6 and requested that the Court impose a ninety-one (91) day rehabilitative suspension.

The opinion rejected the lawyer’s assertion that the disclosures were permitted under Florida Bar Rule 4-1.6(b)(1) to prevent the client from committing a crime and stated that it was not clear a crime was going to be committed and, even if it was clear,  the proper entity for disclosure was the immigration court, not the criminal prosecutor.  The opinion also noted the lawyer did not contest the finding of a violation of Rule 4-8.4(d), which, inter alia, prohibits disparaging or humiliating litigants.  The opinion also stated that “we write to emphasize the inappropriateness of (the lawyer’s) actions in violating her client’s sacred trust” and noted that the lawyer claimed the client did not honor checks of contracts, had robbed members of the Romanian community, and “most egregiously . . . brazenly asserted” the client had rightfully been convicted of grand theft and that the lawyer regretted helping the client.

The lawyer was found guilty of violating Florida Bar Rules 4-1.6 and 4-8.4(d) and the opinion imposed a one (1) year suspension stating that the suspension was appropriate since the lawyer had received a public reprimand for similar conduct in a prior disciplinary matter and because of the nature of the lawyer’s actions and the “apparent escalating pattern of misbehavior”.  “Such disparaging language is needless and has no place in a public court pleading, especially when the statements are made by an attorney and are directed at the attorney’s own client.  Unbridled language of this sort harms the client and causes the public to lose faith in the legal profession.  (The lawyer’s) conduct was highly prejudicial to the administration of justice and cannot be tolerated.”

Bottom line:  The lesson here appears to be that lawyers must be very careful in considering what language to include in court pleadings and documents…and the Florida Supreme Court will not hesitate to dramatically increase the discipline recommended by the referee (and to increase the discipline recommended by the Bar).

…and be careful out there!

As always, if you have any questions about this Ethics Alert or need assistance, analysis, and guidance regarding these or any other ethics, risk management, or other issues, please do not hesitate to contact me.

Disclaimer:  this e-mail does not contain any legal advice and the comments herein should not be relied upon by anyone who reads it.

Joseph A. Corsmeier, Esquire

Law Office of Joseph A. Corsmeier, P.A.

2454 McMullen Booth Road, Suite 431

Clearwater, Florida 33759

Office (727) 799-1688

Fax     (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

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Filed under Attorney discipline, Attorney Ethics, Attorney/client privilege and confidentiality, Florida Lawyer Ethics and Professionalism, joe corsmeier, Lawyer conduct prejudicial to the administration of justice, Lawyer discipline, Lawyer ethics, Lawyer Ethics and Professionalism, Lawyer sanctions