Tag Archives: Lawyer ethics opinions

Florida Bar’s Board of Governors considers rule revisions prohibiting misleading Google ad words and permitting credit charges to clients

Hello everyone and welcome to this Ethics Alert, which will discuss the Board of Governor’s review of potential revisions to Florida Bar Rules 4-7.13, which would prohibit misleading words and phrases in Google ad words, and revisions to Florida Bar Rule 4-1.5(h), which would permit lawyers to charge a client the actual cost of accepting a credit payment.

The Bar Board of Governor’s backup materials regarding proposed revised Bar Rule 4-1.5(h) indicate that the basis for the proposed rule change is a potential allegation of an improper restraint of trade in violation of the Sherman Antitrust Act.

The Bar’s recent summaries of the proposed rule revisions and their status in the BOG review process are below.

PROPOSED ADVERTISING RULE CHANGES 

The Board Review Committee on Professional Ethics will be considering a request for a rule amendment (to Rule 4-7.13) that would state it is inherently misleading or deceptive for a lawyer to intentionally use, or arrange for the use of, the name of a lawyer not in the same firm or the name of another law firm as words or phrases that trigger the display of the lawyer’s advertising on the Internet or other media, including directly or through a group advertising program. For example, the proposal would ban the purchase of another lawyer’s name in Google ad words. The Board’s Citizens Advisory Committee also supports the amendment, stating that the practice is misleading, particularly to vulnerable consumers. 

FINAL ACTION ON CREDIT SERVICE CHARGES 

The Board will be taking final action on a proposed rule change that would delete the current prohibition against charging a service charge for client’s use of a credit plan and allow lawyers to charge the actual charge imposed on the lawyer by the credit plan. Rule 4-1.5(h) currently permits lawyers to accept credit cards to pay for fees and costs, but prohibits lawyers from charging the client the credit card fee charged to the lawyer as a vendor.

Bottom line:  Proposed revised Rule 4-7.13, which would prohibit misleading Google ad words, would be consistent with other jurisdictions that have considered the issue.  Proposed revised Rule 4-1.5(h), which would permit a lawyer to require the client to pay the actual credit card charges would reverse the prior rule, which specifically prohibited requiring the client to pay such merchant charges.

Stay tuned and be careful out there.

Disclaimer:  this e-mail is not an advertisement, does not contain any legal advice, and does not create an attorney/client relationship 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.

29605 U.S. Highway 19 N. Suite 150

Clearwater, Florida 33761

Office (727) 799-1688

Fax     (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

Joseph Corsmeier

about.me/corsmeierethicsblogs

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Filed under Attorney Ethics, Bar antitrust, Bar regulation and antitrust, Florida Bar, Florida Bar rule permitting lawyers to charge credit card fees to clients, Florida Bar rule using GoogleAds words to misdirect to another firm, Florida Lawyer Ethics and Professionalism, Florida Supreme Court, joe corsmeier, Joseph Corsmeier, Lawyer antitrust, Lawyer charging credit card fees to client, Lawyer ethics, Lawyer Ethics and Professionalism, Lawyer using GoogleAd words to misdirect users

ABA Formal Opinion 481 states that lawyers have an obligation to inform current clients of material errors

Hello everyone and welcome to this Ethics Alert which will discuss ABA Formal Opinion 481, which addresses a lawyer’s obligation to promptly inform a current client if the lawyer believes that he or she has made a material error.  ABA Formal 481 Opinion is here: http://www.abajournal.com/files/Formal_Opinion_481_FINAL_formatted_04_16_2018(2).pdf

The formal opinion states ABA Model Rules of Professional Conduct Rule 1.4 governs a lawyer’s duty of communication and requires lawyers to promptly inform clients of any decision or circumstance for which a client’s informed consent is needed and also requires a lawyer to “reasonably consult” with the client about the means of achieving the client’s goals during representation and keep the client “reasonably informed” about the progress of the case.

The formal opinion further states that an error is material if “a disinterested lawyer would conclude that it is (a) reasonably likely to harm or prejudice a client; or (b) of such a nature that it would reasonably cause a client to consider terminating the representation even in the absence of harm or prejudice” and if there has been such a material error, the attorney must inform the client promptly. Whether an attorney can correct the error before telling the client depends on the individual facts.

According to the opinion, there is no duty to inform former clients since “(n)owhere does Model Rule 1.4 impose on lawyers a duty to communicate with former clients (and)  (h)ad the drafters of the Model Rule intended Rule 1.4 to apply to former clients, they presumably would have referred to former clients in the language of the rule or in the comments to the rule.”

The formal opinion concludes:

“The Model Rules require a lawyer to inform a current client if the lawyer believes that he or she may have materially erred in the client’s representation. Recognizing that errors occur along a continuum, an error is material if a disinterested lawyer would conclude that it is (a) reasonably likely to harm or prejudice a client; or (b) of such a nature that it would reasonably cause a client to consider terminating the representation even in the absence of harm or prejudice. The lawyer must so inform the client promptly under the circumstances. Whether notification is prompt is a case and fact specific inquiry.

No similar duty of disclosure exists under the Model Rules where the lawyer discovers after the termination of the attorney-client relationship that the lawyer made a material error in the former client’s representation.”

Bottom line:  This ABA opinion may be the first to address a lawyer’s affirmative obligation to tell a current client when he or she has made a material error, which the opinion states is one which is “(a) reasonably likely to harm or prejudice a client; or (b) of such a nature that it would reasonably cause a client to consider terminating the representation even in the absence of harm or prejudice.”

Be careful out there.

Disclaimer:  this Ethics Alert blog is not an advertisement, does not contain any legal advice, and does not create an attorney/client relationship 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.

29605 U.S. Highway 19 N. Suite 150

Clearwater, Florida 33761

Office (727) 799-1688

Fax     (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

Joseph Corsmeier

about.me/corsmeierethicsblogs

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Filed under ABA Formal Ethics Opinion 481- advising clients of material errors, ABA formal opinions, Attorney Ethics, joe corsmeier, Joseph Corsmeier, Lawyer ethics, Lawyer Ethics and Professionalism, Lawyer required to advise client of material errors

Florida Bar’s Board of Governors will consider ethics opinion addressing fee arrangements of qualifying providers and participating lawyers

Hello everyone and welcome to this Ethics Alert which will discuss the Florida Bar Board of Governor’s (BOG) direction to its ethics committee to prepare a draft advisory opinion addressing fee arrangements between qualifying providers and participating lawyers which comply with amended Florida Bar Rule 4-7.22, which substantially revises the requirements for qualifying providers.  The amended rule becomes effective on April 30, 2018.  The Supreme Court opinion implementing the amended rule (and others) is here: http://www.floridasupremecourt.org/decisions/2018/sc16-1470.pdf

The BOG directed its Review Committee on Professional Ethics to consider a proposed advisory opinion after receiving an inquiry by a Florida Bar member.  The BOG committee will consider the opinion at a meeting scheduled for May 18, 2018, from 1-3 p.m. at the Westin hotel in Key West and the draft opinion will be Proposed Advisory Opinion 17-2.

There is currently no draft opinion; however, the proposed advisory opinion will address different types of fee arrangements between for-profit qualifying providers and lawyer referral services who are otherwise in compliance with Rules Regulating The Florida Bar and participating lawyers. The Florida Bar rules prohibit lawyers from sharing fees with private for-profit qualifying providers.

The draft advisory opinion may address various fee arrangements, including:

  1. set fees paid to the qualifying provider on a weekly, monthly, or annual basis;
  2. set fees paid to the qualifying provider for each case referred to the participating lawyer;
  3. set fees paid to the qualifying provider for each case referred to a participating lawyer depending upon the type of matter (e.g., personal injury, family law);
  4. set fees paid to the qualifying provider for each case accepted by the participating lawyer;
  5. set fees paid to the qualifying provider for each case accepted by the participating lawyer depending on the type of matter (e.g., personal injury, family law);
  6. fees paid to the qualifying provider based upon the perceived value of the case referred to the participating lawyer;
  7. set fees paid to the qualifying provider depending upon the perceived value of a type of matter referred to participating lawyers; and
  8. fees paid to the qualifying provider which are a percentage of the recovery or percentage of the fee charged by the participating lawyer.

Pursuant to Florida Bar Procedures, Florida Bar members may comment on the proposed opinion.  Any comments must contain Proposed Advisory Opinion number 17-2, must clearly state the issues for the committee to consider, may offer suggestions for additional fee arrangements to be addressed by the proposed advisory opinion, and may include a proposed conclusion. Comments should be submitted to Elizabeth Clark Tarbert, Ethics Counsel, The Florida Bar, 651 E. Jefferson Street, Tallahassee 32399-2300, and must be postmarked no later than 30 days from the notice in the April 15, 2018 issue of The Florida Bar News.

Bottom line:  The amended rule substantially change the current rules related to lawyer referrals and the Board of Governors has now initiated the process of identifying various fee arrangements between lawyers and qualifying providers which may or may not comply with the new rules.  Any lawyers who participate in (or are considering participating in) referrals from a private entity should carefully review the new rules, since lawyers can be prosecuted if the referral service (qualifying provider) fails to comply with the amended Bar rule(s).

Be careful out there.

Disclaimer:  this e-mail is not an advertisement, does not contain any legal advice, and does not create an attorney/client relationship 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.

29605 U.S. Highway 19, N., Suite 150

Clearwater, Florida 33761

Office (727) 799-1688

Fax     (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

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Filed under 2018 Florida lawyer referral qualifying provider rule revisions, 2018 Florida lawyer referral service matching service rule revisions, Attorney Ethics, Florida Bar, Florida Bar ethics opinion qualifying provider- lawyer fees, Florida Bar matching services, Florida ethics opinion 17-2- lawyer referrals by private referral matching services, joe corsmeier, Joseph Corsmeier, Lawyer ethics, Lawyer Ethics and Professionalism, Lawyer independent professional judgment- AVVO and matching services, Lawyer matching services Avvo, Lawyer referral fees, Lawyer Referral Services, Lawyer responsibilities AVVO and Linkedin

Texas Ethics Opinion 671 prohibits anonymous contact with unnamed internet defamer to obtain information for deposition

Hello everyone and welcome to this Ethics Alert, which will discuss recent Texas Ethics Opinion 671 which states that lawyers, and their agents, may not anonymously contact an unnamed online alleged defamer in order to obtain jurisdictional or identifying information sufficient for obtaining a deposition pursuant to Rule 202, Texas Rules of Civil Procedure.  The ethics opinion was issued in March 2018 and is here:  https://www.legalethicstexas.com/Ethics-Resources/Opinions/Opinion-671 

The ethics opinion responds to an inquiry from a lawyer which asked the following question:  “Whether an attorney or attorney’s agent may anonymously contact an anonymous online defamer in order to obtain jurisdictional information sufficient for obtaining a Rule 202 deposition”

The opinion states that under Texas Rules of Civil Procedure 202, a party may petition the court for an order authorizing the taking of a deposition to obtain the testimony of any person for use in an anticipated lawsuit or to investigate a potential claim or lawsuit.  Lawyers had previously relied on Rule 202 to discover both jurisdictional and identifying information regarding otherwise anonymous individuals online.

In August 2014, the Texas Supreme Court issued an opinion holding that a Texas court could not order a pre-suit deposition to identify an anonymous online defamer unless the petitioner showed that the individual had sufficient contacts with Texas for personal jurisdiction.  That decision raised the issue of how a lawyer could establish jurisdictional facts about an anonymous individual such as a cyber-stalker or an online defamer.

The opinion discusses the rules related to the lawyer’s duty not to make material misrepresentations to third parties and/or engage in conduct involving dishonesty, fraud, deceit, or misrepresentation as well as other state ethics opinions which address the use social media to obtain information, such as sending a “friend” request on Facebook.

The opinion extends the rationale in those state opinions and concludes that:

“(I)t is the opinion of this Committee that the failure by attorneys and those acting as their agents to reveal their identities when engaging in online investigations, even for the limited purpose of obtaining identifying or jurisdictional information, can constitute misrepresentation, dishonesty, deceit, or the omission of a material fact. Accordingly, lawyers may be subject to discipline under the Rules if they, or their agents, anonymously contact an anonymous online individual in order to obtain jurisdictional or identifying information sufficient for obtaining a Rule 202 deposition. In order to comply with the Rules, attorneys, and agents of attorneys, must identify themselves and their role in the matter in question.”

The opinion does not address or discuss the use of technology to attempt to determine the location and name of the individual without direct contact.

Bottom line:  As I have said (and blogged) in the past, the ethics opinions (and the Bar rules) prohibit using surreptitious means to contact an individual to conduct an investigation and attempt to gain information, such as sending an anonymous or disguised Facebook “friend” request.  This Texas ethics opinion extends this analogy and states that lawyers (and their agents) are prohibited from anonymously contacting an unnamed online individual  to obtain jurisdictional or identifying information sufficient for a deposition (and ultimately a lawsuit).

Be careful out there.

Disclaimer:  this e-mail is not an advertisement, does not contain any legal advice, and does not create an attorney/client relationship 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.

29605 U.S. Highway 19 N. Suite 150

Clearwater, Florida 33761

Office (727) 799-1688

Fax     (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

Joseph Corsmeier

about.me/corsmeierethicsblogs

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Filed under Attorney Ethics, Ethics Opinion anonymous conduct over internet o obtain information, joe corsmeier, Joseph Corsmeier, Lawyer ethics, Lawyer Ethics and Professionalism, Lawyer misconduct improper Facebook access, Lawyer misconduct improper social media access, Texas Ethics Opinion anonymous contact with unnamed internet defamer

ABA Formal Opinion 479 addresses when lawyers may use “generally known” information related to a former client

Hello everyone and welcome to this Ethics Alert which will discuss ABA Formal Opinion 479, which was published on December 15, 2017 and addresses when a lawyer may use information related to the representation of a former client which is to the actual or potential disadvantage of the former client when the information has become “generally known”.  The ABA opinion is here: ABA Formal Opinion 479

ABA Model Rule 1.9(c)(1) provides that a lawyer “shall not use information relating to former client’s representation to the disadvantage of the former client except as (the Model) Rule would permit or require with respect to a [current] client, or when the information has become generally known.”

The opinion also states that the “generally-known” exception to Rule 1.9 was first included in the 1983 ABA Model Rules; however, there is no consensus regarding when information is “generally known.” New York, Massachusetts, and Illinois Bar opinions and ethics commentators agree that “generally known” means “more than publicly available or accessible. It means that the information has already received widespread publicity.”

According to the opinion, the “generally known” exception to the obligations related to former-client confidentiality is limited to the following:

(1) use of the former client information, not the disclosure or revelation of the information,

(2) use of the information only if the information has become widely recognized by the public in the relevant geographic area or widely recognized in the former client’s industry.

The opinion quotes an ethics commentator:

“[T]he phrase “generally known” means much more than publicly available or accessible. It means that the information has already received widespread publicity. For example, a lawyer working on a merger with a Fortune 500 company could not whisper a word about it during the pre-offer stages, but once the offer is made—for example, once AOL and Time Warner have announced their merger, and the Wall Street Journal has reported it on the front page, and the client has become a former client—then the lawyer may tell the world. After all, most of the world already knows. . ..[O]nly if an event gained considerable public notoriety should information about it ordinarily be considered “generally known.”

The fact that information has been discussed in court or may be accessible in public records does not necessarily make the information widely recognized (and “generally known”) under Model Rule 1.9(c) since information that is publicly available is not necessarily widely recognized and, if a search of court records or library shelves is required to find the information, it would not be  widely recognized.

Bottom line: This ABA opinion provides guidance on important ethics issues related to when a lawyer is permitted to use information that is detrimental to a former client when it has become “generally known” and provides guidance.  Although the opinion (and most state Bar rules) permit lawyers to use, but not disclose, “generally known” information even if it disadvantages a former client, lawyers should always carefully consider whether this would be prudent and, if the lawyer decides to do so, obtain the client’s consent in advance.

This ABA opinion is not binding and the analysis is applicable in most, if not all jurisdictions, including Florida; however, lawyers should consult the rules and ethics opinions of their jurisdiction for further guidance.

Be careful out there.

Disclaimer:  this e-mail is not an advertisement, does not contain any legal advice, and does not create an attorney/client relationship 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.

29605 U.S. Highway 19 N. Suite 150

Clearwater, Florida 33761

Office (727) 799-1688

Fax     (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

Joseph Corsmeier

about.me/corsmeierethicsblogs

 

 

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Filed under ABA Formal Opinion 479 former client confidentiality, ABA Formal Opinion former client confidentiality information that is generally known, ABA formal opinions, Attorney Ethics, Confidentiality, Confidentiality and privilege, Former client confidentiality, joe corsmeier, Joseph Corsmeier, lawyer confidentiality, Lawyer ethics, Lawyer Ethics and Professionalism, Lawyer ethics opinions

The Florida Bar’s Board of Governors votes to approve charge of “litigation cost protection insurance” premium to clients

Hello everyone and welcome to this Ethics Alert will discuss the recent decision of the Florida Bar’s Board of Governors to allow lawyers to pass-through the costs of “litigation cost protection” insurance to the client.

According to a recent article in the February 15, 2018 Florida Bar News, the Board of Governors (BOG) voted at its meeting on January 26, 2018 in Tallahassee to permit lawyers to charge the client with the cost of the “litigation cost protection” premium; however, the lawyer must obtain informed consent and make extensive disclosures.  The Bar News article is here:  https://www.floridabar.org/news/tfb-news/?durl=%2Fdivcom%2Fjn%2Fjnnews01.nsf%2F8c9f13012b96736985256aa900624829%2Fba78355e43f4e50085258228004a94da

The insurance product, called “litigation cost protection” insurance, reimburses up to the insured amount of costs advanced by the lawyer to the client only if the case goes to trial and there is no recovery.  Supporters of the insurance state that it provides sole practitioners and smaller firms with the ability to go after deep pocket defendants.  Under the terms of the insurance policy that was considered by the BOG, the premiums would be 7 percent of the dollar amount of coverage, or $17,500.00 if the lawyer obtains the maximum coverage of $250,000.

After an intense debate, the BOG voted 23-17 to permit the lawyer to require the client to reimburse the cost of the insurance premium.  The BOG’s decision reversed a Florida Bar Professional Ethics Committee (PEC) decision in 2017 which opined that a lawyer would be prohibited from charging the client for the cost of the policy.  The BOG directed Bar staff to issue an advisory opinion and the final proposed opinion states that the insurance premium pass through to the client is “a close question because the circumstances described create potential conflicts of interest between the lawyer and client throughout litigation.

The final BOG opinion listed eight conditions, including that the lawyer must: make “an objectively reasonable determination that the litigation cost protection insurance serves the client’s best interest”; inform the client that other attorneys may offer contingency fee arrangements without passing along the expense of the litigation cost insurance; fully explain the insurance and why it is in the client’s best interest; give the client a copy of the policy and advise him or her to have another lawyer to review it; and not allow the terms or availability of coverage to “adversely affect (the lawyer’s) independent, professional judgment, the client-lawyer relationship, or the client’s best interest.”

Bottom line:  Notwithstanding the BOG’s close vote, this decision will now permit lawyers to pass through the cost of the premium for litigation cost protection insurance to their clients without violating the Florida Bar Rules related to litigation expenses.

Be careful out there.

Disclaimer:  this Ethics Alert is not an advertisement and 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.

29605 U.S. Highway 19 N., Suite 150,

Clearwater, Florida 33761

Office (727) 799-1688

Fax     (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

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Filed under Attorney Ethics, Florida Bar, Florida Bar Board of Governors opinion approving pass through of litigation cost protection insurance premium, joe corsmeier, Joseph Corsmeier, Lawyer costs charging client for litigation cost protection insurance

Florida Bar’s Board of Governors finds that AVVO Advisor is a for-profit lawyer referral service and must comply with Bar Rules

Hello everyone and welcome to this Ethics Alert which will discuss the recent decision by the Florida Bar’s Board of Governors to approve a BOG committee’s conclusion that AVVO Advisor is a for-profit lawyer referral service and must comply with the Florida Bar Rules related to those referral services.

According to a recent Bar Board of Governors informational release and the January 1, 2018 issue of the Florida Bar News, the BOG Review Committee on Professional Ethics responded to a lawyer inquiry regarding the status of AVVO Advisor and unanimously recommended that the lawyer be advised that Avvo Advisor, which is described as “a private for-profit company’s online system for connecting potential clients to lawyers for 15-minute consultations for $39”, is a lawyer referral service under Florida’s rules.  The Board of Governors voted unanimously at its December 8, 2018 meeting to approve the committee’s recommendation and opinion. The January 1, 2018 Florida Bar News article is here: https://www.floridabar.org/news/tfb-news/?durl=%2Fdivcom%2Fjn%2Fjnnews01.nsf%2F8c9f13012b96736985256aa900624829%2F3a1cd1f9be52b1f1852581fe004ede22.

As a for-profit lawyer referral service, AVVO Advisor will now be required to comply with Florida Bar Rule 4-7.22 or Florida lawyers will not be permitted to participate in the service.  Florida Bar Rule 4-7.22 requires that the services receive no payment that constitutes a division of fees, it must furnish or require lawyers to have professional liability insurance, it must affirmatively state in advertisements that the system is a lawyer referral service, and comply with the other requirements in the rule.   According to the BOG release, there are twenty-eight lawyer referral services which are current in their quarterly reports to The Florida Bar.

Florida Bar President-elect Designate John Stewart is quoted as stating: “This is a difficult question for this board, it’s going to set a lot of precedent for issues we are going to have to deal with that are related…The decision could affect a large number of our constituents. There are at least, anecdotally, a fair number of our constituents who participate in this program.”

The Florida Bar will provide a 90-day grace period on discipline under Rule 4-7.22 for lawyers who may be currently associated with Avvo Advisor. This would allow Avvo Advisor to file its first quarterly report and comply with Rule 4-7.22 or for the Florida lawyers to exercise other options if Avvo Advisor chooses not to follow Rule 4-7.22, Rules Regulating The Florida Bar.

The January 1, 2018 Florida Bar News, which went online on December 26, provides more information for Bar members about participating in Avvo Advisor.  The webpage “What you need to know about the Bar and AVVO Advisor” is here: https://www.floridabar.org/news/tfb-news/?durl=%2Fdivcom%2Fjn%2Fjnnews01.nsf%2F8c9f13012b96736985256aa900624829%2Fb5f5fefbce7ee680852581fe004f7f92.

Bottom line:  This decision by the BOG addresses only the Avvo Advisor service and it triggers the requirement that AVVO Advisor comply with Florida Bar Rule 4-7.22.  Those requirements include, inter alia, that there is no division of fees, that AVVO either have, or ensure that lawyers have, professional liability insurance, and that AVVO affirmatively state in any advertisements that it is a lawyer referral service.  If a lawyer is currently participating in this service, or is considering participating, he or she should act accordingly.

Be careful out there…

Disclaimer:  this e-mail is not an advertisement, does not contain any legal advice, and does not create an attorney/client relationship 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.

29605 U.S. Highway 19 N. Suite 150

Clearwater, Florida 33761

Office (727) 799-1688

Fax     (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

Joseph Corsmeier

about.me/corsmeierethicsblogs

 

 

 

 

 

 

 

 

 

 

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Filed under Attorney Ethics, AVVO Advisor- BOG opinion re lawyer referral service, AVVO fee sharing and referral fee plans, Avvo legal services, fee sharing, Florida Bar, Florida Bar lawyer referral rule revisions, joe corsmeier, Joseph Corsmeier, Lawyer ethics, Lawyer Ethics and Professionalism, Lawyer referral fees, Lawyer Referral Services, Lawyer responsibilities AVVO and Linkedin