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Everything California Family Lawyers Never Wanted To Know About Ethics But Were Afraid To Ask?
By: Phillip Feldman, B.S., M.B.A., J.D., AV 2007. |
• ANTI-NUPTIAL, PRE-NUPTIAL, PREMARITAL AGREEMENTS
Baseball�s all time national home run champ (no author is not old enough to have watched Ruth or Gherig)is not only a bombastic batsman but is lucky in other ways. In Marriage of Bonds 24 Cal 4th 1 (2000). The CA Supreme Court held that the premarital agreement entered into a day before marriage was valid even though the future Mrs. Bonds didn�t have independent counsel because she couldn�t prove her unrepresented signature was uninformed and not voluntary.
FC (Family Code) � 1612's present terms appear unambiguous: Absence of independent counsel or unconscionability are both grounds to set aside provisions of either. Since unconscionability is determined by the court as a matter of "law" and since family law commissioners and judges function without juries, is it more likely than not that the determination will be made as a matter of EQUITY?
Failing to insure "independent counsel" or including "unconscionable provisions" OR getting an insufficient waiver can subject the family lawyer to both Legal Malpractice (by the lawyer�s client) and conceivably state bar discipline (when the client�s spouse complains).
Legal malpractice because failing to read, know and apply a statute is almost always "below the standard of care.
State bar complaints because it may be "reckless" failure to perform legal services with competence. (CA RPC [Rule of Professional Conduct] 3-110.)
• CONFLICTS OF INTEREST
Once upon a time, lawyers did represent both parties in divorces. That was long before divorces became dissolutions. That was when "fault" was a requisite element. That was when matrimonial lawyers or divorce lawyers weren�t called "family lawyers". In those prehistoric times, CA didn�t even have a "Family Code".
Footnote 11 of the still frequently cited Ishmael v Millington (1966) 241 Cal. App. 2d 520 says it all: "Divorces are frequently uncontested; the parties make their financial arrangements peaceably and honestly; vetigal chivalry may impel them to display the wife as the injured plaintiff; the husband may then seek out and pay an attorney to escort the wife through the formalities of adjudication. We describe these facts of life without necessarily approving them. Even in that situation the attorney�s professional obligations do not permit his descent to the level of scrivener. The edge of danger gleams if the attorney had previously represented the husband. A husband and wife at the brink of division of their marital assets have an obvious divergence of interests. Representing the wife in an arm�s length divorce, an attorney of ordinary professional skill would demand some verification of the husband�s financial statement; or, at the minimum inform the wife that the husband�s statement was unconfirmed, that wives may be cheated, that prudence called for investigation and verification. Deprived of such disclosure, the wife cannot make a free and intelligent choice. Representing both spouses in an uncontested divorce situation (whatever the ethical implications), the attorney�s professional obligations demand no less. He may not set a shallow limit on the depth to which he will represent the wife."
In the not yet dead world of male chauvinism, the sole breadwinner was the husband, who, you may recall, was given full charge of the community subject to fiduciary duties to his spouse. In today�s environment, there are still principal "breadwinners" irrespective of sex, and shortly, irrespective of differential sex. Unlike the "friendly"(tongue in cheek) divorce noted in Ishmael, dissolutions were traditionally very one sided. The breadwinner would frequently be involved in a (then corporate, now LLC, LLP, LP) entity in which the breadwinner�s colleagues insisted that all members of their entities and spouses pre-sign confidential agreements triggering buy-sells or other divestment techniques designed to avoid the vagaries and disruptions of spousal disruption.
It is still common for California lawyers to represent non-marital, non-intimate business associates long after their initial partnership, LLP, LLC, corporation or other venture is initially formed. (RPC 3-600) Such dual representation gives legal malpractice lawyers a lot of business so family lawyers are fortunate they stopped several decades ago.
There are three policy concerns which interplay:
1. Attorney Client Privilege whose policy is to encourage free communication between a client and counsel and discourage loss of confidence in the legal profession by laypersons. (Evidence Code (EC) � 954 subject to the crime-fraud exception. (� 956).
2. Confidentiality. Lawyers have a duty "to maintain inviolate the confidence and at every peril to himself or herself to preserve the secrets of his or her client." (B&P �6068 (d) (1). (In CA lawyers may only use their judgement as to whether or not to reveal confidential information needed to prevent a criminal act likely to result in substantial bodily harm to an individual. In most of the U.S. ABA RPC 1.6 adds preventing, mitigating or rectifying "substantial injury to the financial interests or property of another that is reasonably certain to result or has resulted from the client�s commission of a crime or fraud in the furtherance of which the client has used the lawyer�s services". ABA also permits getting legal advice about the lawyer�s own compliance with the ethical rules or to comply with other law or a court order. CA and sister states recognize that lawyers may defend themselves against claims made civilly or otherwise by the client and most US states, but not CA permits a lawyer to respond to allegations in any proceeding concerning the lawyer�s representation of the client. The policy rationale is identical to the evidentiary privilege and substantively the only difference between the two are the mandate of a communication not participated in by a third person for the privilege and essentially any non public source of information derived out of the lawyer�s representation for confidentiality.
3. Loyalty. This has the identical rationale of public confidence.
It isn�t even mentioned in the State Bar Act (B&P Code 6000 et seq) or CA�s rules of professional conduct. It is often the most important in legal malpractice. Flatt v Superior Court, Sonoma County (1994) 9 Cal. 4th 275.
There are basically two "no-no�s" in this area.
1. Thou shalt not serve two masters. (RPC 3-310) (caveat: the informed written consent exception often turns on whether the conflict is only foreseeable as a possibility or a probability). (see INDEPENDENT PROFESSIONAL JUDGMENT below for another aspect of this rule dealing with getting paid by someone other than the client). FC � 8800 expressly prohibits representing prospective adoptive and natural parents. (Writer represented parties against David K. L. for professional negligence many years ago). Unaware of any cases on informed written consent waiver in this area.
IN FAMILY LAW WHERE BOTH HUSBAND AND WIFE HAVE LONG USED THE SERVICES OF A SINGLE LAW FIRM, WHAT ARE THE POTENTIALS FOR CONFLICT OF INTEREST? OUGHT THE DISSOLUTION ET AL BE REFERRED TO LAWYERS WITHOUT A TRACK RECORD WITH BOTH PARTIES?
2. Thou shalt not self-deal! There are different types of self-dealing, that is putting one�s one interests above the client:
a. FC � 2033 created a statutory means of avoiding the standard prohibition against encumbering community real property in order to "retain or maintain" a dissolving party�s counsel by enabling "family law attorney�s real property lien". It consists of notice, and adversary�s right to object. The statute expressly mandates compliance with RPC 3-300.
b. RPC 3-300, among other things says that a lawyer "shall not - - -knowingly acquire (any) pecuniary interest adverse to the client unless:"
Terms are fair and reasonable to the client; and
Fully & understandably disclosed in writing to the client;
and
The client is advised in writing of right to independent counsel;
and
The client is given reasonable opportunity to get such advice;
and
Thereafter the client consents in writing.IS ON THE SPOT ADVISEMENT (ie/ break at a hearing or conference) EVER REALLY ADEQUATE? Ought the 15 day notice of FC 2033 apply?
Whenever there�s a need for independent counsel: WHAT CONSTITUTES "INDEPENDENT COUNSEL" and do we wait till in becomes an issue to be decided by a family law court, civil jury or the state bar court to find out?
c. There are other ways to self deal. Way back when, in an era when discarded, homemakers were being exchanged for trophy friends, many empathetic counsel tendered T.L.C. It wasn�t all that unusual for prospective clients to suggest they had no funds but they could "do anything and when they said anything, they meant anything." (The author�s reply was how can I give my partner half of "anything" and then take my half home to my wife to share?" It worked.) Sometimes the TLC looked like it was at least a mini-relationship that transcended the attorney client relationship. CA belatedly followed other states and the present rule prohibits "undue influence" by the lawyer in having/getting sex from a client. RPC-3-120. Since lawyers are always the beneficiaries of trust and confidence isn�t it likely that any intimacy between lawyer and client who is not the spouse or prior paramour of the lawyer will look like undue influence in a fee dispute or legal malpractice case or state bar proceeding? The relationship constitutes a two edged sword cutting one way against the attorney. Climbing out of a warm bed on the way to the court-house is generally believed to interfere with a lawyer�s independent judgment. The rule references 3-110 (incompetence, supra).
• DEALING WITH UNREPRESENTED PARTIES
Due to the commonplace practice of parties changing counsel multiple times in acrimonious dissolutions this is a lot more common in family law than civil law generally. Civil lawyers tend to think of themselves as either "transactional lawyers" or "litigators". Family law practitioners are almost always both. Acceptance of the necessity of dealing with unrepresented parties by the courts is now common-place enough in family law so that the risk of downside is much less for family practitioners than others. Look downstream to tomorrow!
California�s rules revision commission is presently sending proposed revisions to its Rules of Professional Conduct out for public comment. Both the legislature and supreme court chartered them to try to adopt the national rules as set out in American Bar Association�s Rules of Professional Conduct (which guides professional responsibility for all but a few states) and/or Restatement of the Law, The Law Governing Lawyers (which sets forth the majority rules for professional negligence). In addition California courts cite ABA rules. Here�s why it�s relevant to antenuptials:
ABA Rule 4.3 mandates that a lawyer shall not imply he or she is disinterested and insure unrepresented people understand the lawyer is an advocate for others nor may a lawyer give any advice "other than the advice to secure counsel if the lawyer- - -reasonably should know that the interests of such person - -have a reasonable possibility of being in conflict with the interests of the client."
The problem is that beside the adverse, pro per, complaining to the bar, there is always the threat that the client, beneficiary will blame the lawyer if the "deal", MSA etc. goes south on that basis.
Lawyers who don�t like poker and crap-shoots are well advised to limit all substantive communications with adverse pro pers to writings. When, as, and if, courts or clients insist on deals being done on the spur of the moment, at breaks etc., the same wise counsel will engage a lawyer cooling heels as a witness to sign off only as a witness after the pro per is told that the lawyer is associate being paid by the pro per�s adversary as well.
• LEGAL INCOMPETENCE
RPC 3-110 defines competence as "the 1) diligence, 2) learning and skill, and 3) mental, emotional and physical ability reasonably necessary for the performance of such service." To avoid reckless failure to perform legal services with competence, the rule permits an attorney who lacks sufficient learning and skill at the time of undertaking to associate with or consult with lawyers who are up to speed or by getting up to speed "before performance is required." The obvious alternative is to turn a matter down and perhaps refer to others. Incompetence comes up in both state bar discipline and legal malpractice.
Any CA MD is a physician who can legally function as a psychiatrist in the morningnd thoracic surgeon in the afternoon. Of course the innovative profession in developing specialties and subspecialties has means of dealing with such a foolhardy approach to medicine in addition to the Medical Board. In order to practice at a particular hospital/facility the individual physician needs to get privileges at each one. Privileges aren�t given lightly and the physician needs to fully qualify before the hospital lets him or her at any patient. There is no counterpart in law. Other than the specialty of patent law the court have no jurisdiction or purview to limit a lawyer�s practice. Until determined to be incompetent or a risk to the public (rare for unconvicted, sober, mentally healthy lawyers) neither does the state bar.
There is no question that one need not be a board certified specialist to practice any law, including family law, or for that matter, the author�s certification, professional negligence-legal in CA. ABA is attempting to determine if board certified specialists earn more money, get more business etc. than their uncertified peers. California will soon be releasing a study showing that indeed in CA they seem to earn more money. The national consensus is that the relationship between business/money and certification has more to do with the fact that certified specialists tend to have more experience than the fact of their certification. On the other hand, let�s face it, board certification looks great on letterheads and the author can vouch for its tremendous effect as a marketing tool. In spite of that until the general public declines to tolerate attorneys who emphasize an area of law (since they can�t call themselves "specialists" in most states) there need not be a rush to taking tests and dotting all the i�s and t�s needed to get and stay certified.
Merely possessing sufficient "legal knowledge (and) skill" is not enough since the "lawyer shall provide" such skill to the client. Comment [5] to the rule from which California�s rule emanated (ABA 1.1), reads, in part: "Competent handling of a particular matter includes inquiry into and analysis of the factual - - -elements of the problem, and use of methods and procedures meeting the standards of competent practitioners." Comment [2] notes that "A lawyer need not necessarily have special training or prior experience to handle legal problems of a type with which the lawyer is unfamiliary. A newly admitted lawyer can be as competent as a practitioner with long experience. Some important skills, such as the analysis of precedent, the evaluation of evidence and legal drafting are required in all legal problems. Perhaps the most fundamental skill consists of determining what kind of legal problems a situation may involve, a skill that necessarily transcends any particular specialized knowledge. A lawyer can provide adequate representation in a wholly novel field through necessary study. Competent representation can also be provided through the association of a lawyer of established competence in the field in question."
In emergencies lawyers may give minimal, reasonably necessary advise, at least in ABA states.
Lawyers who hold themselves out as specialists "must exercise the skill, prudence, and diligence exercised by other specialists of ordinary skill and capacity specializing in the same field." Wright v Williams (1975) 47 Cal. App. 3d 802, 810. Generally, any attorney who practices any aspect of family law is held to the same standard as a specialist because the field has long been considered a specialty.
• ENGAGEMENT, RETAINERS, GETTING PAID, NOT GETTING SUED AND KEEPING THE FAITH WITH THE BAR
Since fees are always going to exceed $1,000 and are not contingent, all family law agreements must be in writing. B&P � 6148 requires setting out the basis of compensation whether hourly flat fees or other. Any absence of a fully executed written retainer or failure to comply with the requirements for the retainer itself or statements within ten days of request unless provided within the last 31 days does not void the attorney client relationship but gives the client the unilateral right to rescind theretainer. When that happens the lawyer doesn�t get quantum meruit since the value of service may be the same as the hourly or other fee. Instead the lawyer gets a "reasonable fee" which means whatever the court (or jury) decides. (Although a client can waive the writing, the odds of proving and selling the notion that the waiver was based on full disclosure suggest waiver is seldom appropriate).
An even stronger reason than the statute for having a written retainer is because that�s really the only time an attorney can articulate the scope of engagement. Another important factor is that proving what the agreement was and is without an express, written contract is seldom going to benefit the lawyer.
If the work is completed and the client is a happy camper, there�s no one to complain to any court. If the service is arguably completed but the client disagrees whether the client goes to a legal malpractice lawyer or retains a new family law practitioner who needs to get the funds back to get paid, there�s always and issue.
A so called "true retainer" is one to insure the lawyer�s availability to perform services for the client at a particular time or timespan. In family law, there are attorneys whose reputation and calendar are so over-booked that, in fact, they can�t guarantee their personal availability for specific matters unless they "book" their schedule in such a manner. They are entitled to replicate the old "family retainers" (not family law, just family lawyers who were all things to all members at all times. In the real world of family law there are truly very few lawyers whose reputation, calendar and open market demand, justifies or rationalizes the true retainer.
When hourly fees are agreed, there is seldom much dispute that any sums handed the lawyer before services are performed are not earned. For that reason sums paid are only a deposit. All deposits or advances are still the property of the client and must be placed in the attorney trust account until earned. (RPC 4-100 (A). When the sums are very substantial and will take some time to be earned giving IOLTA the benefit of interest on the client�s funds can sometimes lead the lawyer to be responsible to repay the interest. For that reason in such circumstance the substantial, long range fund ought be placed in a special, interest bearing trust account.
Most family law "issues" in this regard arise in the setting of "flat" or "fixed fees". If the fees are an advance or deposit they must be in the trust account. Whether or not they are a mere "advance" is an after the fact determination made by the court or State Bar Court, often irrespective of the parties intent. See S.E.C. v Intelink Data Network of Los Angeles, Inc. (9th Cir 1996) 77 F. 2d 1201. A Superior Court Appellate Department case in Los Angeles County concurred with the determination. In In re Jackie don White on Habeus Corpus et al, (2004) 121 Cal. App. 4th 1453 , a court dealing a lawyer who ran a "writ mill", hired suspended lawyers, used unsupervised law students and had a track record of succeeding in one of 53 attempts, after being branded incompetent and ordered to show cause why he shouldn�t be sanctioned and held in contempt for frivolous filings, the court ordered disgorgement of attorney fees for the three matters before it.
Although the court cited the LA Superior Court opinion view that such fees are always advances which must be placed in the trust account or else violate Rule 4-100 (A) which would also be a breach of fiduciary duty and constitute legal malpractice, the court relied on Rutter group for the proposition "the issue remains unsettled".
In state bar proceedings, cases tend to be less lenient than the civil courts. In the Matter of Brockway (2006) the Review Department of the state bar stated that "Even though the fee was designated in the contract as a true retainer fee, we look beyond the characterization to determine the obligations of the parties. It cited cases noting that in the absence of a provision to set aside available blocks of time there could be no true retainer and failure to state that the fee was due and payable regardless of whether any professional services were actually rendered would deprive it of its status as fully earned. On the other hand in Matter of Respondent H (1992) 2 Cal. State Bar Ct. Rptr. 234 the court "can and should look to label and treatment of funds by attorney and client when considering whether they are trust or non-trust funds. However it is the character and nature of the funds, not their label by either attorney or client, which ultimately determines their status." The straw leaning in favor of one family lawyer was his reliance on ethics counsel for treating the fund as earned.
Criminal attorneys have always charged "flat" or "fixed fees" as a matter of course, custom and practice. The scope of engagement is usually conditioned short of going to the Supreme Court of the United States on appeal or writ. The wording of the scope of engagement is mandated by B&P 6148 only to show "the general nature of the legal services to be provided to the client". A wise lawyer articulates what is going to be done for the client in sufficiently exquisite detail to expressly eliminate anything an uninformed client might have on their "wish list" so that no reasonable expectations are aroused. In addition, by breaking the engagement into specific tasks the attorney can, in effect, cost account the fee into segments. In addition to replicating the criminal lawyer�s custom, however, the compartmentalizing or "task basis" attempt to get a fully earned retainer does tend to replicate the hourly fee. Substituting specific chores or milestones for hours expended, still leaves the client short if performance is not completed. Whenever, for any reason, the work isn�t done, whether firm, fixed price, flat-fee, or otherwise, the lawyer is at risk for pocketing funds instead of putting them in his trust account.
The risk is that the lawyer�s violation of RPC 4-100 (A) may be proven by clear and convincing evidence if the work isn�t done and the"unearned" portion of the payment isn�t refunded. The threat of defending a claim of misappropriation, even without the automated onus of "moral turpitude" and ultimate licensing sanctions does not seem to make it worthwhile to keep the fund anywhere but in the trust account.
While it may seem that the only difference between criminal defense and family law is the former�s long standing practice of having flat fee retainers, there are other differences. The milestones in most misdemeanors are reasonably foreseeable since instead of two lay clients there are only experienced advocates on each side. Even so the criminal lawyer faces motions and may need to make unplanned motions which are just included in the flat fee. In family law, the attempt to articulate milestones could result in a laundry list which would convince a client that he or she overpaid since less than 100% of he milestones ever came to pass.
The jury is still out on the extent to which credit cards can be used for ongoing work in the same manner as a replenishable deposit into a trust account. For the time being it is probably high risk for the following reason. A client writing a fresh check to counsel is a concession of awareness, need and desire to continue the relationship. A lawyer unilaterally charging against a client�s credit card, even for monies owed will likely result in windfalls for disgruntled clients and heartaches for expedient lawyers.
RPC 3-310 (F) states that a lawyer can�t get paid by a non-client unless the client�s confidentiality is kept intact, the client�s informed, written consent is provided in advance, and there�s no interference with the lawyers independence of professional judgment or the client-lawyer relationship.
• WHEN ARE FEES UNCONSCIONABLE?
RPC 4-200 is cited by the courts. It�s close to the ABA rules as well. It lists eleven factors that a court is supposed to consider in determining whether or not a fee is unreasonable (which is called unconscionable in CA). The fee vs. value and amount involved and results obtained are often important to juries. Time and labor required always gets back to the hourly valuation. Relative sophistication and prior relationship of the parties is usually a pro-client perk before juries. Time limitations, novelty are factors. If the client knows the lawyer is giving up other work (true retainer) is a factor. The experience, repuation and ability of the lawyers performing are factors which favor their right to a fully earned retainer. As with many aspects of legal malpractice and state bar discipline avoidance, the client�s informed consent is also a factor. Author reviewed Marvin M.�s retainers over many years (as an advocate, not as his counsel). Fifteen thousand became Fifty Thousand and was fully earned on retention. The fact was and is that there are lawyers whose reputation justifies a "take it or leave it" fully earned retainer the day they�re hired. It doesn�t work for most of us.
• THE SURE FIRE TESTS OF COST -EFFECTIVE VS. COST-INEFFECTIVE LAWYERING
Comment [5] to ABA 1.1 states simply that "The required attention and preparation are determined in part by what is at stake; major litigation and complex transactions ordinarily require more extensive treatment than matters of lesser complexity and consequence."
PI and med mal attorneys have no problem determining whether or not a contingency case is worth taking by working backwards! If the injury is great enough (ie/ a life-long disabling birth injury) less attention is paid to liability even though the lawyer gets no fee in the absence of a recovery, so long as the claim is tenable and at least one reasonable lawyer would pursue or defend it.
In its simplest context if the legitimate economic dispute of the value of the marital community, status as community property is an awful lot of money, generally both sides as zealous advocates leave no stone unturned.
Appraisers, economists, accountants and the whole armamentarium of family law litigators as well as investigation and discovery is the rule and not the exception as well as whatever legal and paralegal support is needed.
In recent times, although there are no stats published, empirically, perhaps the greatest number of serious family law legal malpractice cases arise because: counsel�s fees showed a tendency to spend a dollar to win a dime; or counsel engaged experts who arguably gilded the lilly; or the "legitimate" battle of the experts was less than the fees to dispute the de minimus difference; or the client simply stopped paying statements and assumed that the best defense would be a good offense; or having rejected a better offer on counsel�s recommendation the matter went on forever and both parties ended up poorer.
Where the acknowledged dispute is primarily a patent emotional or fictional sublimation for real or imagined hurts, the water gets murkier. Because of the attorney-client privilege, many clients are quite candid about their "real" goals. Because many clients are sophisticated attorneys may often suspect their client�s hidden agenda. Case law in malicious prosecution makes it clear that lawyers need not cross-examine their clients and lawyers do not generally have a duty to superimpose their value structure, or even society�s preferred value structure on their clients. California�s Rule 3-200 follows the majority rule. A lawyer can�t continue employment if its objective is "to bring an action, conduct a defense, assert a position in litigation, or take an appeal without probable cause and for the purpose of harassing or maliciously injuring any person." The acid test is not whether the average reasonable lawyer would go along with the client�s position but whether any reasonable lawyer would do so.
The rule adds to the essential elements of the tort of malicious prosecution the notion that a lawyer may not take a position "that is not warranted under existing law, unless it can be supported by a good faith argument for an extension, modification, or reversal of such existing law".
In the real world it is almost unheard of for family law practitioners to face the second test because family doesn�t have juries for a reason. Only courts may sit as chancellors in equity. There are almost always many reasons why an otherwise untenable legal position may still be justifiable for equitable considerations.
Custody disputes from the standpoint of parents is different enough from the court�s charter of best interests of the child to mandate full and fair informed consent before the false claims of molestation, abuse, mental illness etc. become illegitimate issues.
Lawyers are not priests, ministers, rabbis, monks, elders or other providers of ecclesiastical services (even if they hold such licenses). Lawyers and their staff are not generally competent in psychotherapy, remotely qualified, nor are they engaged for such purpose. �Handholding", TLC, may truly satisfy patient�s/client�s needs. In many instances it may be malpractice per se to fail to refer a client to appropriate counseling. (Appropriate counseling is seldom synonymous with adversarial posturing). It is important that the entire legal staff refrain from empathetic but inappropriate attempts to resolve issues which are beyond the scope of representation and beyond the purview of the family law court. The above is not intended to suggest that adversarial posturing may not be essential to appropriate advocacy, only to insure that counsel, at least, know and appreciate the difference.
• DISENGAGEMENT
Only family lawyers can file a form and disengage post judgment. Quitting prior to that time whether paid or unpaid can only be done in two ways: 1) A fully executed substitution of attorney, properly filed and served; or 2) A granted motion to withdraw.
Neither gets the lawyer off the hook for abandonment since the lawyer has to take reasonable steps to insure he or she has avoided reasonably foreseeable prejudice to the client which includes fair notice and an opportunity to find other counsel along with timely surrender of 100% of the original file (whether depositions are paid for or not).
Phillip Feldman, B.S., M.B.A., J.D., AV 2007, consults and testifies on STANDARD OF CARE, STANDARD OF CONDUCT (rules of professional conduct, ethics, conflicts, competent lawyering, lawyer duties), CAUSATION, informed consent, fiduciary duties, reasonableness of fees etc. He is Board Certified in Legal & Medical Malpractice by CA, ABA and APBLA.
Board Certified Professional Negligence-Legal (CA, ABA, APBLA)
Former Judge Pro Tem, Former State Bar Prosecutor
Fee dispute arbitrator 30 years, LA Super Lawyer 2005
Practice limited to Attorneys (State Bar Defense, Expert Witness, E&O Coverage, Risk Management & Preventative Law)
See his Listing on Experts.com.
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