


OAKLAND COUNTY BAR ASSOCIATION
1760 S. Telegraph Road, Suite 100
Bloomfield Hills, Michigan 48302-0181 (248) 334-3400 • FAX (248) 334-7757 www.ocba.org
PRESIDENT
Dean M. Googasian
PRESIDENT-ELECT
Sarah E. Kuchon
VICE PRESIDENT
Aaron V. Burrell
TREASURER
Kari L. Melkonian
SECRETARY
Victoria B. King
EXECUTIVE DIRECTOR
DIRECTORS
Syeda F. Davidson
Julie L. Kosovec
Emily E. Long
Jennifer L. Lord
Moheeb H. Murray
Kimberley Ann Ward
Kenneth F. Neuman
Layne A. Sakwa
Silvia A. Mansoor
Jennifer Quick ABA DELEGATE
LACHES EDITORIAL BOARD
Victoria B. King
Syeda F. Davidson
Coryelle E. Christie
James W. Low
Lanita Carter
Thamara E. Sordo-Vieira
THE MISSION OF THE OAKLAND COUNTY BAR ASSOCIATION IS TO SERVE THE PROFESSIONAL NEEDS OF OUR MEMBERS,
Articles and letters that appear in LACHES do not necessarily reflect the official position of the Oakland County Bar Association, and their publication does not constitute an endorsement of views that may be expressed. Readers are invited to address their own comments and opinions to:
LACHES | Oakland County Bar Association
1760 S. Telegraph Rd., Ste. 100 Bloomfield Hills, MI 48302-0181
Publicationandeditingareatthediscretionoftheeditor.
LACHES (ISSN 010765) is the monthly (except July and December) publication of the Oakland County Bar Association, a Michigan nonprofit corporation, 1760 S. Telegraph, Ste. 100, Bloomfield Hills, MI 48302-0181. Copyright © 2025 Oakland County Bar Association. The price of an annual subscription ($20) is included in member dues. Periodical postage paid at Bloomfield Hills, MI 48304 and additional entry offices. Postmaster: Send address changes in writing to Oakland County Bar Association, 1760 S. Telegraph, Ste. 100, Bloomfield Hills, MI 48302-0181.
Pondering Opening Your Own Legal Practice? Some Things to Consider
Here’s what you need to know about starting your own law practice.
ByJessicaNotarberardino-HaxhijaandCharityBurke 10
Win-Win Law Firm Management
Two Miller Law attorneys share how their firm aligns its interests with those of its lawyers.
ByE.PowellMillerandBrandonT.Goldstein 14
Always Practice with Integrity: A Guide for New and Solo Practitioners
For those entering the field, the message is clear: Integrity is the foundation of a successful legal career.
Proper Billing of Law Firm Charges
Being aware of correct charging will help ensure fees are sustained and not reduced or eliminated if challenged.
It is tradition for the OCBA president to use the last LACHES column to reflect on the year. While we’ve had a good year, and accomplished much, I’d like to take this opportunity to reflect on our organization a bit and express my gratitude for those who make it work. I’ve had the privilege of being around the OCBA since I was a kid, and I served on committees for years before joining the board. I believe our OCBA continues to play an important role in the practice of law in our community. is is the result of decades of people working together.
So, as this bar year winds down, I extend my thanks and appreciation to all of the folks who have helped make the OCBA what it is: members who get engaged; committee members who take the time to participate; committee chairs and vice chairs willing to step up and take leadership roles; our judges, especially our district, circuit, and probate judges, who are so very generous with their time to attend OCBA events; our intrepid OCBA staff, who make the place run; and my boards, past and present, who have given so much of their time and talents to our organization. ank you, to all of you, for what you do to make our OCBA great. I depart with confidence that our OCBA is in good hands.
Dean M. Googasian is the president of the Oakland County Bar Association.
As the 2024-25 bar year comes to a close, I want to take a moment to express my heartfelt gratitude to a remarkable group of individuals who have provided exceptional leadership throughout the year — our OCBA committee chairs and vice chairs; the chancellor, vice chancellor, and team leaders of our award-winning Inns of Court program; and the co-chairs of the 2025 Circuit-Probate Court Bench/Bar Conference.
Our 30 OCBA committees are led by dedicated volunteers (listed below) who generously contribute their time and expertise to keep our members informed on the latest developments in their respective practice areas. They help shape association policy on key professional issues, develop impactful programming for our members, and organize initiatives that benefit the community. OCBA committees are one of the most valued benefits of membership, and our committee chairs and vice chairs play a
Alternative Dispute Resolution
Business Court and Counsel
Circuit Court
Circuit Court Case Evaluation
Criminal Law
Debtor/Creditor
District Court Case Evaluation
Diversity, Equity and Inclusion
Employee Benefits
Employment Law
Energy, Sustainability and Environmental Law
Family Court
Golf Outing
Juvenile Law
Law Related Education
Lawyer Well-Being
Legislative
LOCA (Lawyers of a Certain Age)
Medical/Legal
Membership
Municipal Law
New Lawyers
PALS (Providing Access to Legal Services)
Paralegal
Michael O’Malley
Derek Howard
Meagan O’Donnell
Tom Charboneau
Marcia Ross
Joseph Grekin
Steven Brock
Shane Kolo and Hon. Adrienne Young
Nicholas Nahat
Richard Lynch
Brian Considine
Jacob Simon
Russ Carniak
Lanita Carter
Alec D’Annunzio
Mary Aretha and
Kristina Bilowus
Klint Kesto and Sheldon Larky
Judith Cunningham
Mary Ann Seibold
Syeda Davidson and Jacob Kahn
Debani Gordon Lehman
Jonathan Ajlouny
Michelle Johnson
Jessica Schefman
pivotal role in ensuring their success. Membership in any of our committees is free of charge and offers countless professional advantages. Participating allows members to deepen their knowledge, advance their careers, and forge meaningful professional connections. We encourage you to explore the full range of opportunities at ocba.org/committees and discover how you can get involved in this vibrant membership benefit, supported by OCBA staff liaisons and led by our members, for our members.
Amanda Kakos
Paige Szymanski
Anisa Allen
Steven Brock
Paul Stablein
Tami Salzbrenner
Gary Remer
Mari Tilashalski
Alexander Sheldon-Smith
Richard Rassel III
Eric Wisniewski
Mark Berke and Elizabeth Hohauser
Katharine Smith
Jordan Fields
Nicole MacMillan
David Sheaffer
Heather Herbert
Alda Gojcaj
COMMITTEE NAME CHAIR
Probate, Estate and Trust
Professional Development
Race Judicata
Real Estate
Tax Law
Veterans Law
Julie McCowan
Linda Kennedy
Michael Steinberger
T. Scott Galloway
Stephen Weisberg
William Lynch
e OCBA’s chapter of the American Inns of Court is a distinctive community of lawyers, judges, and law students dedicated to fostering meaningful mentoring relationships. rough monthly meetings, members have the opportunity to build and strengthen professional connections, engage in thoughtful discussions on core issues of professionalism, and address pressing legal challenges of the day. e program provides a platform for sharing experiences and advice, inspiring passion and dedication to the law, and promoting mentoring opportunities. Above all, it strives to uphold the highest standards of integrity, ethics, and civility in the legal profession. To learn more about this invaluable program, visit ocba.org/inns
ank you to our Inn leaders for guiding our Inn members through another successful year.
Chancellor: Hon. Kameshia Gant
Vice Chancellor: Hon. Cynthia Stephens (ret.)
Team 1 Leader: Hon. Kameshia Gant
Team 2 Leader: Hon. Cynthia Arvant
Team 3 Leader: Hon. Brian Hartwell
Team 4 Leader: Hon. Laura Polizzi
Team 5 Leader: Hon. Cynthia Stephens (ret.)
Team 6 Leader: Hon. Jeremy Bowie
Katie Burke
Paige Szymanski
Poncé Clay
Joe Peterson
Justin Gonzales
e biennial Circuit-Probate Court Bench/Bar Conference was held on Friday, March 7, at the Auburn Hills Marriott Pontiac. Organized by our three co-chairs, the half-day event featured an exceptional program focused on mastering digital tools, including artificial intelligence, in modern legal practice. Attendees gained valuable insights on how to navigate common pitfalls while upholding professionalism and civility. Additionally, our session captains led engaging breakout sessions, offering timely updates and sharing best practices across a range of areas, including business, civil, criminal, family, and probate law. ank you to the following people:
Hon. Jeffery Matis
Hon. Daniel A. O’Brien
Kari Melkonian
Paige Szymanski — Business
Hon. Michael Warren — Business
Laura Alton — Civil
Michael Leib — Civil
Kari Melkonian — Civil
Peter Menna — Criminal
Layne Sakwa — Criminal
Nicole Smithson — Criminal
Hon. Kameshia Gant — Family
Ellen Paynter — Family
Juliet Boyd — Probate
Chiara Mattieson — Probate
Hon. Daniel A. O’Brien — Probate
Jennifer Quick is the executive director of the Oakland County Bar Association.
10 2025 Employment Law Year in Review (9 – 11:30 a.m.)
A seminar from the Employment Law Committee
Presenters: Richard M. Lynch, Esq., Circuit Court Administrator, Sixth Judicial Circuit Court (Moderator); Aimee Guthat, Esq., Jackson Lewis P.C.; TBA
This annual Zoom seminar will provide an overview of exciting new changes in employment law to assist attorneys in better serving their clients. The three topics of focus will be immigration and employment, the evolution of hybrid and remote work, and workplace harassment.
17 Update on the State of Criminal Law 2025 (11:30 a.m. – 1 p.m.)
A seminar for criminal defense appointed counsel
Presenter: Alona Sharon, Esq., Alona Sharon PC
This Zoom seminar will provide an overview of the most recent published Michigan Court of Appeals cases with a focus on sentencing decisions. Join us for an in-depth discussion of hot topics, emerging issues, and practice pointers in criminal law.
Worth 1.5 hours of criminal and juvenile training credit for appointed counsel
19 Addressing Criminal Case Challenges in the District Court (Noon – 1 p.m.)
A seminar for criminal defense appointed counsel
Presenter: TBD from the Oakland County Public Defender’s Office
This virtual seminar provides an in-depth exploration of key issues faced in the defense of criminal cases in district court. Topics include bonds, nonserious misdemeanors, sentencing, probation violations, ability-to-pay hearings, and more. Don’t miss your chance to gain practical insights to enhance courtroom effectiveness and ensure procedural fairness.
Worth 1 hour of criminal and juvenile training credit for appointed counsel
21 Understanding the Attorney Disciplinary Process in Michigan (Noon – 1 p.m.)
Presenter: Martha D. Moore, Professor, Cooley Law School
This virtual seminar offers a concise and informative overview of how attorney discipline is administered in the state, including a primer on the roles and responsibilities of the Michigan Attorney Grievance Commission and the Michigan Attorney Discipline Board. It will also outline the steps involved in the disciplinary process and highlight key procedural considerations for attorneys. Ideal for legal professionals seeking to better understand the system, the session aims to promote ethical practice and awareness of professional responsibility requirements in Michigan.
By Jessica Notarberardino-Haxhija and Charity Burke
Starting a law practice can be an exciting and fulfilling process, but it can also leave an attorney feeling lost and overwhelmed. Attorneys may be unsure of where they want to take their law practice, what steps are needed to get started, and what resources are available to them along the way. Fortunately, there are a plethora of resources and a widespread support network to help attorneys embark on the journey of starting and growing their law practice.
if there is no recovery. MCR 8.121 limits the contingency fee rate to one-third, and under MRPC 1.5(d), contingency fees are prohibited in criminal and most domestic relations cases. e risk of this billing system is that attorneys may dedicate more time to a case than they will recover.
3. Flat fees. is billing system charges clients a flat rate for a specific service or services. is is often preferable to clients because the fees are predictable, but it is also a risk for the attorney because the work put into the service may exceed the flat fee collected.
e fee structure and billing process should be tailored to the needs of the clients. OMC creatively designed a service model that met the needs of those who could not access other legal representation avenues for various reasons and a fee schedule that was based on income and family size. OMC’s fee structures range from fixed-fee arrangements to hourly fees starting as low as $1 to $1.50 per minute with a small retainer due up front. OMC created a service structure of full legal services as well as limited-scope services for our clients. Over the years, it became apparent that clients were more committed to following through with services when charged a $50 intake fee, which is applied to their case if they sign on with OMC.
Hiring quality staff as you are growing your new legal practice can be challenging. In the beginning, referrals can be slow to come in, but quality attorneys and support staff deserve a fair salary. It is important to think about how you will supplement revenue while you are growing; consider at what point you will grow from one attorney to multiple attorneys and/or support staff. e more experienced the skill set one has, the more compensation is expected. What about fringe benefits? What can you afford versus what will attract and retain talent? is can be a stressful time as you experience the growing pains of a successful organization, meet client caseload demands, make time to do outreach, create processes and protocols as you grow, and develop an organizational structure. When growing your practice, you must not only be a skilled and respected attorney but also master management of your staff, HR practices, accounting principles, and how to successfully run a business with all that comes with that — becoming familiar with interview techniques, best practices for onboarding and training new staff, professional development for them, performance reviews and goal setting, discipline approaches for performance issues, results-based management techniques, work environments, best practices for HR, etc. Finding subject matter experts, such as the
American Society of Employers, was instrumental for OMC. Having annual financial audits to support best practices in accounting is critical to ensure and demonstrate that you are leading your business in a financially responsible manner and will develop good accounting practices.
Another way to ensure that a business is led responsibly and efficiently is to implement strong office procedures. An office procedure should be put in place from the beginning so the attorney and staff know how cases will be handled from start to finish. Some items to consider include intake procedures, document organization, client communications, closing case procedures, expenditure management, and document retention policies. Create clear job responsibilities for the attorney and staff to eliminate confusion and to create accountability were a task to be incomplete or not correctly completed. Office procedures will require a lot of trial and error, so once you have created a system you believe works for the practice, create written protocols or procedures along with templates of client letters, agreements, or standard pleadings to assist new hires and to promote consistency.
ere are likely to be bumps on your road to success. You must also develop ways to provide service in a way that is supportive to your client but not empathize so much that their situations impact your own mental health and well-being. We suggest developing relationships with seasoned attorneys who are willing to mentor you as you grow your practice, encounter ethical dilemmas, and experience challenges and situations for the first time. Find out what their successes were, what challenges they faced and how they overcame them, and how they grew their practices. It’s important to realize and accept that we are all human and mistakes will happen along the way
or you will wish you had done things differently in hindsight. Treat these moments as learning opportunities for growth and improvement not only of your practice, but within yourself as the leader of your practice. Continuing education is imperative, not only for legal matters but for business and leadership development as well as self-care techniques. Set boundaries from the beginning with clients. Decide how you will communicate them in a way that ensures clarity and protects you from misunderstandings. How will you manage clients who overcommunicate, undercommunicate, or are nonresponsive? How will you handle nonpayment of a fee for services that is uncollectible?
As you think about growing your practice, consider who your target clients are within the community. Attend networking events to form referral partnerships, ask yourself what other organizations cater to the clientele you are looking to attract and meet with them, attend events within the community to educate others about the service(s) you are offering, offer free public workshops or Q&As online or at other venues for community members, and get savvy with social media! For the introvert, this will require you to step out of your comfort zone. You must either be willing to put yourself out there and mingle or hire someone who will represent your practice with the face and vision you want the community to experience. e best referral is the personal referral, so quality and professional service during which you connect with your clients is an excellent way to build your reputation and increase referrals.
Jessica NotarberardinoHaxhija, J.D., is the supervising attorney at Oakland Mediation Center. She has been a practicing attorney for six years and focuses her practice primarily on family law, landlordtenant law, and general contract disputes. She is a graduate of Michigan State University and Wayne State University Law School.
Charity Burke, MADR, is the executive director of Oakland Mediation Center. Burke holds a master’s degree in alternative dispute resolution as well as nonpro t leadership and management. Burke has been a mediator and ADR practitioner for 28 years.
Resolving issues outside of a courtroom while applying the experience, skill and knowledge of 30+ years on the bench.
Personal Injury • Civil • Business Family • Employment • Other
mark@switalskilaw.com | switalskilaw.com
Sam Morgan & Greg Jones have a team of Employment Lawyers with decades of experience providing advice, counsel and representation to Employees and Employers in a wide variety of occupations, for:
• Wrongful discharge cases, including breach of employment contract, discrimination, harassment and retaliation Non-payment of compensation disputes, including commission, bonus and incentive compensation arrangements, and FLSA violations Enforcement of equity award agreements and minority shareholder rights
• Defending against mobility-killing non-compete and non-solicitation contracts
• Separation agreement reviews and severance negotiations
• Drafting employment contracts
• HR counseling, defending against government investigations
Our team includes Senior Associate, Barbara Urlaub*, and Of counsel attorneys, David Kotzian*, Donald Gasiorek*, Raymond Carey *, and Paul Hines *2024 Michigan Super Lawyers Honorees
Toll Free Phone: 888.421.9704
Local: 248.865.0001
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By E. Powell Miller and Brandon T. Goldstein
Several years ago, one of the partners at our firm experienced a particularly brutal stretch of work: She was under scheduling orders that left her with two back-to-back trials in the middle of August. Throughout the summer, she was often working over 12 hours each day, even on the weekends. The workload was clearly taking its toll — and not just on her, but on her husband and young son as well. Unfortunately, there was not much we could do to alleviate the workload for her. In our view, we needed a win-win: something she and her family could look forward to as a light at the end of the tunnel while we still got the best work we could out of her. She had always talked about going on vacation to Hawaii, so in recognition of all the work she was putting into her cases, the firm decided to sponsor her family vacation. We brought her into my office and told her, “We know this has been a rough few months for you, and we want to recognize your hard work by sending you and your family to Hawaii for two weeks after you wrap up these trials, all expenses paid.”
is anecdote is apt for a number of reasons, not the least of which is how appropriately it summarizes the stress that comes with the practice of law. As attorneys, we have always known and understood that being a lawyer carries with it long hours, hard work, and stress, but quantifying that strain has not been a priority. In recent years, lawyers everywhere have pushed for greater awareness surrounding mental health issues across the profession. Recent studies and surveys have vindicated their concerns.
A 2023 survey conducted by e American Lawyer1 found that about 71% of lawyers experience anxiety, an over 5% increase from 2022. Another 38% of lawyers revealed they struggled with depression, while another 31% admit a different mental health issue. More than half of the lawyers surveyed agreed that they felt a sense of failure or self-doubt, reduced motivation, cynicism, and negativity, as well as a decreased sense of satisfaction and accomplishment. Over one-third of lawyers reported feeling detached and lonely. Nearly two-thirds said they felt overwhelmed, exhausted, and irritable. It is no secret why lawyers feel this way — sandwiched between scheduling orders and client demands, our time is often not our own.
More surprisingly, though, less than one-quarter of those surveyed said their compensation plan had anything to do with their problems. Instead, over 76% of lawyers feel their work environment contributes to these issues. Beyond the pressure of billable hours and client demands, nearly half of the lawyers surveyed felt their firms insufficiently supported their personal well-being, and nearly one-third felt their firms fostered a dysfunctional firm culture.
As practice leaders, there is unfortunately little we can do about the pressure of the job itself. Clients will always have needs and demands, and litigation is always subject to scheduling coming from the judges’ chambers. And with less than a quarter of attorneys reporting unhappiness with compensation, how can we continue to get the most out of our lawyers and our practices?
In our view, law firms can make the greatest strides by creating a better, healthier work environment for their lawyers. is strategy has worked for us. We call it “win-win” law practice management.
e core concept requires aligning our firm’s economic interests with our lawyers’ interests. Put into practice, it starts by minimizing the importance of the billable hour — e Miller Law Firm has no minimum billable hour requirement. Of course, billable hours are still supremely important — they are the financial lifeblood of any firm. But they do not accurately measure each attorney’s overall contribution to the firm. Nonetheless, we reward timely and accurate timekeeping. Recently, we brought in representatives from Shinola to fit our firm’s best timekeepers with brand-new watches.
Beyond time, while we want to set up our attorneys for a future with the firm, we want them to have work-life balance, be able to start a family if they choose, and pursue their own personal goals. Accordingly, one program we adopted was to purchase Michigan Education Trust contracts for all partners’ children. is provides full fouryear tuition at all of Michigan’s public universities. Again, this aligns our firm’s goals with those of our attorneys; we want our firm to be a great place to have and support a family.
Our philosophy also emphasizes collegiality and collaboration within the firm. We work with our doors open and encourage attorneys to bounce ideas off one another to benefit from diversity of thought and solve problems in unexpected ways. We have a fully stocked kitchen with all kinds of snacks and drinks to keep our attorneys and staff nourished and healthy and to encourage them to take breaks and talk to one another. We sponsor weekly catered lunches to further encourage our attorneys to dine with one another and talk about something other than work or our cases. We also hold two firmwide parties each year, one in the summer and one around the holidays, where our attorneys and their families can come together and celebrate all
the effort and intensity they put into their work. And at those parties, we play raffle games and give away cool prizes, including each year’s grand prize, an all-expenses-paid vacation.
Once per week, we offer free one-on-one massage sessions with a licensed massage therapist we bring on-site. We also bring a personal trainer on-site twice per week whom any attorney or staff member can work with.
We also look to use other firm benefits to reward attorneys where possible. For instance, the firm buys a suite at Comerica Park and Ford Field each year. When we have spare tickets, we like to bring our attorneys’ families along. Occasionally, when one of the venues is hosting some other event, like a concert, we try to find an attorney at the firm who likes the artist and give them the opportunity to host the suite.
e results of our efforts have been clear: Our attorneys feel special and appreciated, and as a result, the firm benefits from happy, healthy, satisfied attorneys. Our attrition rate is low, and the quality of our work is exceptionally high. We strongly encourage all firm leaders to consider how to create a win-win working environment within your firm.
E. Powell Miller founded e Miller Law Firm, P.C., nearly 30 years ago on a mission to practice law for the betterment of society. His Jesuit education, with its motto to be “men for others,” has guided him to make Miller Law a great place to do great work. Now, his rm is one of the most successful in the state of Michigan, and its attorneys have garnered nationwide recognition for excellence in their elds. His co-author, Brandon Goldstein, joined the rm as an associate in 2022. Goldstein shares Miller’s belief in the power of service to others and the mission with which he founded the rm.
Footnote:
1. Chelsey Fredlund, Mental Health by the Numbers: An Infographic Mapping the Legal Industry’s Well-Being, THE AMERICAN LAWYER (May 18, 2023) https://www.law. com/americanlawyer/2023/05/18/mental-health-bythe-numbers-an-infographic-mapping-the-legalindustrys-wellbeing. See also Patrick R. Krill, et al., Stressed, Lonely, and Overcommitted: Predictors of Lawyer Suicide Risk, MDPI (Feb. 11, 2023) https://pmc. ncbi.nlm.nih.gov/articles/PMC9956925.
• Practical strategies for handling difficult ethical situations.
• How financial pressure influences ethical decision-making.
• The role of mental fortitude, meditation, and daily affirmations in resisting ethical pressure.
• Why mentorship is critical in helping new and solo practitioners maintain integrity.
Certain clients seek an attorney not for their legal expertise, but because they believe the attorney has “inside connections.” They assume that legal results can be manipulated through relationships with judges, prosecutors, or court officials.
Clients may say:
• “I heard you have a great relationship with the judge — can you make sure we get a favorable ruling?”
• “You know the prosecutor, right? Can you talk to them and get this charge dropped?”
• “I need a lawyer who has the right connections, not just legal knowledge or experience.”
These are red flags. Clients who attempt to test an attorney’s ethical limits may later claim that the attorney misrepresented their influence, which could result in disciplinary action.
Relevant Ethical Rules
• ABA Model Rule 8.4: Prohibits attorneys from engaging in conduct that implies undue influence on a government agency or official.
• Michigan Rule of Professional Conduct 8.4 (MRPC 8.4): Prohibits lawyers from engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation.
Case Study: The Attorney Who Claimed Special Access
In 2019, a New York attorney was disbarred after falsely claiming he had a “special relationship” with a judge and could secure favorable rulings for clients in exchange for higher fees. When the promised outcomes did not materialize, the deception was exposed, leading to his disbarment under ABA Rule 8.4(c) and (d).
How to Handle These Clients Properly
• Set Boundaries Early: Make it clear that
your legal practice is based on skill and advocacy, not personal favors.
• Educate Clients on Legal Processes: Help clients understand that cases are won through evidence and strong legal arguments, not personal relationships.
• Be Willing to Walk Away: If a client insists on unethical behavior, terminate representation before they entangle you in misconduct.
Sounds easy to walk away, doesn’t it? But what if you need the income or you really want to please the client? Your ethics must be rooted in having the courage to focus on what is the right thing to do. You will end up regretting the money and the people-pleasing once your ethics are questioned.
2. The Pressure to File Frivolous or Baseless Claims
Clients sometimes believe that filing a lawsuit — even if weak — will pressure the opposing party into settling. They may push attorneys to pursue cases that have no legal merit, hoping to exploit legal processes for financial or personal gain.
Common justifications include:
• “Just file it — maybe they’ll settle to avoid legal fees.”
• “The claim isn’t perfect, but we need to put pressure on them.”
• “Other lawyers do this all the time!”
Filing frivolous claims is a direct violation of ABA Model Rule 3.1 and MRPC 3.1 (Meritorious Claims and Contentions), which prohibit attorneys from advancing claims lacking legal and factual basis.
In 2021, a Michigan attorney faced sanctions for filing a series of retaliatory lawsuits against a former employer. Despite knowing the cases had no merit, the attorney proceeded to file multiple claims, ultimately resulting in Rule 11 sanctions and referral to the Michigan Attorney
Grievance Commission, leading to suspension of his license.
• Conduct a Comprehensive Case Assessment: Before accepting a case, research the legal and factual basis to ensure it meets the threshold for legitimacy.
• Educate Clients About Legal Standards: Explain that lawsuits must be grounded in valid claims, not personal grievances.
• Have the Courage to Decline Representation: Walking away from a frivolous case protects your professional credibility.
Many ethical violations occur not because attorneys lack moral principles, but because financial desperation leads to poor choices. For solo practitioners, particularly those in the early stages of building a practice, the fear of losing a client — and thus income — can be overwhelming.
1. Taking on clients despite ethical concerns (e.g., knowingly defending a fraudulent claim to keep business going).
2. Overbilling clients (padding billable hours to make up for slow business periods).
3. Cutting corners on legal work (rushing through important case research to save time).
4. Failing to return client funds (withholding refunds from retainers that should be returned).
• ABA Model Rule 1.5 and MRPC 1.5: Prohibit unreasonable fees or expenses.
• ABA Model Rule 1.15 and MRPC 1.15: Govern handling client funds and prohibit misuse of retainers.
I highly recommend purchasing malpractice insurance. Some, if not most, carriers have an ethics helpline where you can call an actual, dedicated attorney; provide a scenario; and get their thoughts on it. Of course, we have our State Bar of Michigan Ethics Helpline, but nothing beats a dedicated adviser.
At a recent OCBA event, we had the chance to hear from a panel of judges. I remember Judge Noah Hood saying to “operate in good faith — because you will make mistakes, but if you have a good reputation, that reputation will stand up for you.” Judge Kwamé Rowe similarly said, “Protect your reputation. Always try to do good because the good you do will be there for you when your integrity is questioned.” Powerful words that have stayed with me ever since I heard them.
You must believe in yourself and that you can face your challenges. I believe in the power of the thoughts we have in our mind and the control they have over us. So, maintaining daily affirmations to yourself can help ground you into being the person you want to be and the person you want the world to see you as. Some
of my daily affirmations to help strengthen my resolve include statements to myself such as:
• “I am grateful; the universe is abundant.”
• “I have limitless integrity.”
Ethical shortcuts may provide short-term financial gains, but they lead to long-term career consequences. Attorneys who prioritize integrity build stronger reputations, better professional networks, and more-sustainable careers.
For those entering the legal field, the message is clear:
Located in the award-winning Kaufman Financial Center in Farmington Hills. One to five private office spaces, with staff cubicles, are available for immediate occupancy. The lease includes the use of several different sized conference rooms, including a conference room with dedicated internet, camera, soundbar and a large monitor for videoconferencing; reception area and receptionist; separate kitchen and dining area; copy and scan area; and shredding services.
PLEASE CONTACT
Heni A. Strebe, Office Manager, 248.626.5000, hastrebe@kaufmanlaw.com
Integrity is not just a professional requirement — it is the foundation of a meaningful and respected career.
Attorney Jalal “J.” Dallo is a dedicated advocate in the elds of criminal defense and immigration law, stemming from a lifelong commitment to justice, in uenced by over 35 years of martial arts training. is discipline instilled in him the values of integrity, resilience, advocacy, and the protection of those whose rights, freedom, and way of life are at stake.
With over 16 years of legal experience, Dallo has successfully represented clients across Michigan and throughout the United States. A returning contributor to L, he also plays a key role in authoring the Institute of Continuing Legal Education’s Michigan Model Criminal Jury Instructions. Beyond his legal practice, he has been invited to speak at colleges and universities, sharing his insights on law and justice. Committed to service, he provides pro bono and low bono representation, driven by a deep sense of responsibility to those facing lifealtering legal challenges.
By Sheldon G. Larky
When law firms send clients bills, clients need to be properly charged based upon what is being done. This is especially true when a legal assistant, paralegal, secretary, or clerk is doing some tasks. As stated in Missouri v Jenkins, 491 US 274, 299, n 10, 109 S Ct 2463, 105 L Ed 2d 229 (1989), and NLRB v Bannum, Inc, Nos. 21-2664/2690 (CA 6, May 17, 2024) sl op at 8, “[P]urely clerical or secretarial tasks should not be billed at a paralegal rate, regardless of who performs them.”
Here are examples of tasks which should not be billed at attorney or paralegal rates, but rather at clerical or secretarial rates:
• Receiving and filing correspondence. B & G Mining, Inc v Director, Office of Workers’ Compensation Programs, 522 F3d 657, 666 (CA 6, 2008).
• Delivering, picking up, and photocopying documents. In re Meese, 907 F2d 1192, 1203 (CA DC, 1990).
• Filing and organizing documents as well as obtaining transcripts. Nadarajah v Holder, 569 F3d 906, 921 (CA 9, 2009).
• Sending and receiving faxes, requesting and receiving medical records, serving papers, and hand-delivering courtesy copies of filings to the courthouse. Lilly v City of New York, 934 F3d 222, 234 (CA 2, 2019).
• Faxing, emailing, filing, scanning, assembling, and conforming. McKenna v City of Philadelphia, 582 F3d 447, 457 (CA 3, 2009).
• Serving amended deposition notices. Miller v Kenworth of Dothan, Inc, 117 S Supp 2d 1247 (MD Ala, 2000).
• Administering a complex litigation matter. In re Armored Car Antitrust Litigation, 472 F Supp 1357 (ND Ga, 1979).
• Reviewing documents and helping to prepare chart exhibits. Hall v Lowder Realty Co, 263 F Supp 1352, 1365 (MD Ala, 2003).
• Reviewing and completing trial binders. Hall v Lowder Realty Co, 263 F Supp 1352, 1365 (MD Ala, 2003).
• Unloading and organizing trial documents. Hall v Lowder Realty Co, 263 F Supp 1352, 1365 (MD Ala, 2003).
• Communicating with process servers and court reporters, preparing forms, drafting an appearance, and creating spreadsheets. Segovia v Fuelco Energy LLC, SA-17-CV1246-JKP (WD Tex, 2024).
• Reviewing court notices; scheduling; notifying clients and counsel of deadlines; preparing filings; maintaining files; copying, printing, labeling, and emailing documents; and communicating with court staff. Meadows v Latshaw Drilling
e mission of the Oakland County Bar Association is to serve the professional needs of our members, enhance the justice system, and ensure the delivery of quality legal services to the public. We fulfill our mission through our 30 committees, regular networking events, and numerous educational programs for both OCBA members and the public. We work hand in hand with the OCBA volunteer board directors and members, and we partner closely with the courts.
Below are recent examples of the OCBA at work in service to the bar and to the community.
On March 19, the Oakland County Bar Association and the Women’s Bar Association — Oakland Region of WLAM joined forces with the Chaldean American Bar Association, D. Augustus Straker Bar Association, Jewish Bar Association of Michigan, South Asian Bar Association of Michigan, and Women Lawyers Association of Michigan Macomb Region at Platform in Birmingham to raise funds for seven different charities. Each participating bar association, along with its guest judge, selected a charity to support. Attendees cast their votes for their favorite bar association by donating cash “tips” to the association’s tip jar. e Women’s Bar Association emerged victorious, raising the most for its chosen charity, the Ruth Ellis Center. In total, the seven bar associations raised over $4,200 for these worthy causes.
On March 20, the Oakland County Bar Association hosted an informative virtual seminar highlighting the power of social media in supporting legal cases. Manson Ho, Esq., from Magna Legal Services led the session, covering key topics such as rules of engagement, effective strategies, and best practices for leveraging social media during trials. is seminar is part of the OCBA’s range of self-paced online training programs available on demand. Attendees can browse and register for a variety of educational programs, after both in-person and Zoom presentations. To explore the OCBA’s on-demand CLE offerings, visit ocba.org/ondemand.
irty senior community members attended a free legal education program, sponsored by the OCBA’s Providing Access to Legal Services (PALS) Committee and financially supported by the Oakland County Bar Foundation, on April 4. e event, held for the first time at the Madison Heights Active Adult Center, marked a significant expansion of the OCBA’s outreach to older adults in this part of Oakland County. e half-day program, which included lunch, provided seniors with valuable legal information and guidance. Attendees had the opportunity to hear a keynote address on estate planning and choose from specialized tracks on probate planning or Medicare/Medicaid planning. Additionally, individuals were able to meet one-on-one with an attorney during the popular “Ask a Lawyer” session, receiving brief advice and counsel on their legal questions.
your friends and colleagues for a good cause, publicize pro bono and other volunteer training opportunities — the possibilities are endless.
ere may be other assistance you can give that would be personally meaningful. Rest assured any help you give will be appreciated and rewarding. ere will certainly be many appeals to your generosity in the coming months. Please be patient and gracious with those who come to you. With very rare exceptions, they are just trying to do good and need help.
Jennifer Miller Oertel is a member of Bodman PLC and co-chair of the rm’s Exempt Organizations and Impact Investing practice group. Oertel has an extensive business law background in securities, private equity, mergers and acquisitions, and corporate governance, as well as exempt organization compliance, which she leverages to further the business interests of tax-exempt organizations and the donors and investors who support them. Oertel has been the co-chair of the Nonpro t Corporations Committee of the Business Law Section of the State Bar of Michigan since 2011 and is an adjunct faculty member at the Lilly Family School of Philanthropy at Indiana University. She is a frequent author and speaker on impact investing and philanthropy and has served on the boards and advisory committees of several philanthropic organizations nationally. Oertel is a Fellow of the Michigan State Bar Foundation and the American Bar Foundation.
The Oakland County Bar Foundation’s mission is to ensure access to justice and an understanding of the law in our community. It is dedicated to:
Improving and facilitating the administration of justice in Oakland County and throughout the state of Michigan;
Ensuring to the fullest extent possible that legal services are made available to all members of the public;
Promoting legal research and the study of law as well as the diffusion of legal knowledge;
Promoting the continuing legal education of lawyers and judges; and
Educating the public as to their legal rights and obligations, and fostering and maintaining the honor and integrity of the legal profession.
If you know an organization that could use assistance to pursue these goals within Oakland County, please refer them to ocba.org/ocbfgrants, where they can find information about applying for a grant from the foundation.
It is with great pleasure that I write this column welcoming Judge Traci Richards to the Oakland County Probate Court. Judge Richards was elected November 5, 2024, to fill the seat of Judge Linda S. Hallmark, who retired at the end of the year.
We are excited to have Judge Richards join the probate court. She possesses a vast array of experience that will provide her with an excellent base of knowledge. is knowledge base equips her with the necessary tools to address all types of cases on the probate docket. In addition to private-practice experience litigating probate matters, Judge Richards’s first legal position was with the Kalamazoo County Prosecutor’s Office. She was also a Veterans Affairs-appointed fiduciary for a disabled veteran and obtained her real estate brokerage license.
Judge Richards took over Judge Hallmark’s full probate docket of all case types. Judge Richards is in Courtroom 2E (Judge Jennifer S. Callaghan’s old courtroom on the second floor of the east wing of the courthouse).
Welcome, Judge Richards!
Every so often, I like to direct LACHES readers to the probate court website and highlight some of the useful information they can find there. e web address for our website is oakgov.com/ courts/probate. e information there may save you time because it is the information you need or, possibly, because clients can get some general information without taking up a law firm’s valuable time or incurring the expense. In that instance, everyone wins.
We have a “Frequently Asked Questions” tab where visitors can find a range of information, not all of which is about procedure. ere are answers to questions such as “How can I avoid the long line at the probate counter?” and “Why is the line so long?” Hopefully, the line isn’t nearly the issue it used to be. ere are also answers to questions such as “Do I need an at-
By Edward A. Hutton III
torney?” and “How do I request a waiver of my filing fees?” Self-represented litigants find this area helpful, and attorneys may find it to be a time-saver for them and their clients. is area can be found by hovering your cursor over the “About” tab and then clicking the “Frequently Asked Questions” tab.
Another area that is helpful to selfrepresented litigants and could be useful for clients is the glossary. e glossary is found by hovering your cursor over the “Resources” tab on our homepage and then clicking on “Glossary.” is section gives the legal definitions of words and phrases commonly used in the probate court. As we know, the legal use of certain terms often deviates from the common usage. is area can be utilized so everyone understands the terminology and can communicate more effectively. Hopefully, this will lead to increased efficiency.
Instructions and forms necessary for viewing hearing recordings or ordering a transcript can be found by hovering your cursor over the “Resources” tab and then clicking on “Doing
Business with Probate.” From there, scroll down toward the bottom of the page. Under “General Administrative Forms & Information” is a “Transcripts” heading. ere, you will find a link to a list of the transcription agencies and the judicial chambers linked to each one. To order a transcript, you must contact the transcription agency associated with the judge presiding over your case. e contact information of each transcription agency is included on the list.
Instructions on how to view recordings of hearings are also found here. ere is a link to the form titled “Request for Viewing Video Court Proceeding,” which is required to be completed and submitted to circuitcourt@oakgov. com. Never mind that it is a circuit court email address. It will get to the right place.
I invite you to jump on our website and poke around. I am confident you can find at least one helpful thing you didn’t know was there.
Edward A. Hutton III is the Oakland County Probate Court administrator.
Recently, a series of events led me to ponder our approach to confidential or protected information within the context of the courts. We all have at least a passing familiarity with the legal requirements, be they statutes, rules, or regulations, that protect various types of information. Common examples include HIPAA, Social Security number protections, nonpublic records, and so on. At the same time, I regularly receive information or requests touching upon information filed with the court. ese puzzling, sometimes contradictory rules reminded me of the song “When You Had Left Our Pirate Fold” from e Pirates of Penzance, which explored the quirks of paradox.
How quaint the ways of Paradox!
At common sense she gaily mocks! ough counting in the usual way, Years twenty-one I’ve been alive. Yet, reckoning by my natal day, Yet, reckoning by my natal day, I am a little boy of five!
For those who do not recall the Gilbert and Sullivan comic opera, Frederic, who was captured by the pirates of Penzance as a child, was indentured to serve with the pirates until his 21st birthday. While he served the pirates loyally, Frederic’s goal was to leave the pirates and combat the scourge of piracy upon turning 21. As the verse above highlights, poor Frederic was born on February 29 and, while reaching his 21st year, had only celebrated five birthdays. is paradox, which illustrates the play’s subtitle, “ e Slave of Duty,” presents Frederic with a challenge, for he is duty-bound to serve the pirates until his 21st birthday, which is decades away from his 21st year.
For this article, the paradox that comes to mind compares the ongoing challenges presented by attorneys and parties filing protected personal identifying information in court documents despite the prohibition created
By Richard Lynch
in MCR 1.109(D)(9)(b)(i) and (iii) and the efforts of counsel to protect information by sealing records.
By way of background, a year ago, in the June/July 2024 edition of LACHES, I dedicated this space to an article titled “ e Ongoing Obligation of Protected Personal Identifying Information.” I would like to write that since the publication of this article, the Clerk’s Office has noticed a marked reduction in the number of documents submitted that contain protected personal identifying information, or PPII. Unfortunately, the Clerk’s Office reports that little has changed regarding the appearance of PPII in this respect. While I would like to place the burden of this problem on self-represented litigants or attorneys either regularly violating the rule or waiving their client’s rights to the protection provided in the rule, let me take a moment to remind you of your obligations under MCR 1.109(D)(9)(b) (i) and (iii). First, the rules focus on the publication of information of an opposing party or witness. If a party wishes to waive their PPII protections, the court rules leave that up to the party and their counsel. Second, the State Court Administrative Office created Form MC 97, Protected Personal Identifying Information, which is used for a defendant, respondent, or decedent, and Form MC 97a, Addendum to Protected Personal Identifying Information,
which is used for individuals not covered by Form MC 97, to assist filers in complying with the requirements of MCR 1.109(D)(9) (b)(i). ird, when a party files another’s PPII, the aggrieved party may file a request for redaction of PPII, Form MC 97r, with the clerk. MCR 1.109(D)(10)(c)(i). e request requires a party to identify the documents containing specified PPII, including the paragraph number and line number of the PPII one seeks to have redacted. Once the form is completed and submitted, the clerk will redact qualifying information. If one wishes to remove personal identifying information (PII), one may file an ex parte motion to protect personal identifying information, Form MC 97m. Because the court rules treat PII differently from PPII, one must file a motion to request the protection of PII, rather than the request used for PPII. See MCR 1.109(D)(10)(c)(ii).
A similar issue arises from time to time when parties or counsel seek to protect information filed in a case by sealing the file, and this is where the paradox begins. Typically, efforts to seal a file occur after the parties settle a case and the passion associated with the litigation begins to subside. At this point, counsel recognizes that information that could prove directly or indirectly damaging in some way to their client appears in public records. I suspect that most readers are familiar with this process; however, because questions regarding sealing files arise with some frequency, I thought that I would offer a quick reminder of the process.
First, sealing a record does not operate as an alternative to a protective order either directly or retroactively. e general procedures for protective orders in civil cases are outlined at MCR 2.302(C) and MCR 2.313(A)(3). e court rules reference other times and reasons, but these are the two most common instances I encounter at the court. Of note, and at the risk of stating the obvious, protective orders address discovery issues. Equally important,
MCR 2.302(C)(6) speaks to accessing a deposition sealed during the discovery process. Neither Subrule C nor Section 6 of it creates the sealing mechanism, only the access to the deposition under the scope of a properly entered protective order.
Second, Michigan public policy favors public records. A party seeking to seal a document or file bears a heavy burden to obtain this relief. e process requires that a party who seeks to seal a document or record must file “a written motion that identifies the specific interest to be protected.” MCR 8.119(I)(1)(a). e court must make a “finding of good cause, in writing or on the record, which specifies the grounds for the order” and determine that “there is no less restrictive means to adequately and effectively protect the specific interest asserted.” MCR 8.119(I)(1)(b) and (c). In determining “good cause,” the court considers the interests of both the parties and the public. MCR 8.119(I)(2). e court must also allow “any interested person the opportunity to be heard concerning the sealing of the
records.” MCR 8.119(I)(3). While a motion to seal records seals information subject to the motion temporarily pending the court’s ruling on it, the subrule specifically provides that a “court may not seal a court order or opinion, including an order or opinion that disposes of a motion to seal the record.” MCR 8.119(I) (4) and (6). e court must submit a copy of the order sealing a record to the Michigan Supreme Court Clerk’s Office. MCR 8.119(I)(7). Recognizing the burdens established in this subrule, the Supreme Court specifically states that MCR 8.119(I) is not “intended to limit the court’s authority to issue protective orders pursuant to MCR 2.302(C).” MCR 8.119(I) (8). Finally, the subrule permits “any person” to file a motion regarding the order sealing a record or file. MCR 8.119(I)(9).
In short, Michigan rules encourage parties and counsel to protect information through the PPII requirements at MCR 1.109(D) (9)(b)(i) and (iii) or a protective order under MCR 2.302(C). e rules the Supreme Court has authorized for sealing a record or parts
of a file under MCR 8.119(I) present a much greater burden and offer only incomplete protection, as they do not seal the entire file. Paradoxically, despite the front-loaded tools that assist counsel in protecting information, attorneys often find themselves looking to seal records after the fact to protect information that they otherwise would not have entered into the public record. As indicated above, while it is possible to seal a record, the process is imperfect and often does not afford the protection that could have been obtained by proactively addressing the issue at the start of the case. Hopefully, this reminder will help you avoid
A paradox, A most ingenious paradox!
We’ve quips and quibbles heard in flocks, But none to beat this paradox!
Richard Lynch is the court administrator for the Oakland County Circuit Court.
2024-290214-FH People v. Colline
2024-290265-FH People v. McDougle
2024-289351-FC People v. Boykin
2024-288210-FH
People v. McIntyre
2021-277688-FH People v. Ratcliff
2024-288218-FC
People v. Walker
2023-199875-NH
Paul Howard v. Michigan Healthcare Profession
2023-284213-FH People v. Moore
2023-198436-NO
Stanley Berger v. Beverly Hills Village
2024-290891-FH People v. Overman
2024-290916-FC People v. Delavara
2024-291296-FH
People v. Abid
2023-287246-FH People v. Dabrowski
2021-188930-CB
Essco of Birmingham v. Clark Construction Co. Inc.
2024-290820-FH People v. Clay
2024-290196-FC
People v. Harris
2023-201799-NO
Jamal Mohsin v. David Ungar
Sumeet Aggarwal
Christopher Gates
Andrew McGarrow
Tina Saxon
Christian Arndt
George Chedraue
Danielle Librandi
Gregory Mortimore
Cynthia Brown
Melissa Krauskopf
Brandon Barlog
Stephen Barker
Milton Greenman
Jonas Parker
Mahira Musani
Jordan Zuppke
Joseph Howitt
Todd Lipsey
Zachary Houchin
Paul Streetman
David Champine
Zachary Glaza
Nicole Garmo
David Goukassian
Nicole Garmo
Mani Khavajian
Mark Sassak
David Landry
Sumeet Aggarwal
Lyle Harris
Dillon Salge
Jerome Sabbota
John Alexander
Lawrence Garcia, R. Carl Lanfear
Weap. FA Poss. by Prohib. Per., Weap. Ammun. Poss. by Prohib. Per., CCW, FF
Domestic ViolenceAggravated 2nd Off.
Ct. 1 Hom. 2nd Deg., Cts. 2, 4, 6 FF 3rd Off., Ct. 3 AWIM, Ct. 5 Weap. FA Poss. by Prohib. Per., CCW
Assault w/I GBH
Ct. 1 C/S Del./Man. 50-499 G, Cts. 2, 4, 6 FF 2nd Off., Ct. 3 C/S Del./Man. <50 G, Ct. 5 Felon. Poss. FA
of LesserDomestic
Ct. 1 Armed Robbery, Cts. 2 & 4 Weap. FF, Ct. 3 Felon. Poss. FA No
Medical Malpractice
Cts. 1-3 Felon. Poss FA, Ct. 4 Weap. Ammun. Felon., Ct. 5 Weap. FF
Other Personal Injury
Cts. 1 & 2 CSC 4th Deg., Ct. 3 Attempted 4th
Cts. 1 & 4 CSC 1st Deg., Ct. 2 CSC 2nd Deg., Ct. 3 Home Inv. 1st Deg.
Cts. 1 & 4 Guilty, Cts. 2, 3 & 5 Not Guilty
OWI Causing Serious Injury
Business Court
Police Officer Aslt./Resist/ Obst., Weap. FF
Cts. 1, 3 & 4 Guilty, Ct. 2 Not Guilty
Other Personal Injury
Executive Director
Jennifer Quick (jquick@ocba.org)
Deputy Director
Katie Tillinger (ktillinger@ocba.org)
Finance Director
Susan Maczko (smaczko@ocba.org)
Professional Development Director
Shanay Cuthrell (scuthrell@ocba.org)
Court Services Manager
Cristin Doble (cdoble@ocba.org)
Marketing Communications Specialist
MB Cairns (mcairns@ocba.org)
Bookkeeper
Mayly McRae (mmcrae@ocba.org)
Administrator – Court and Public Services
Janise Thies (jthies@ocba.org)
Administrator – Events and Member Services
Kari Ross (kross@ocba.org)
Administrator – LRS and Membership
Geni Fritch (gfritch@ocba.org)
Administrator – Laches and Foundation
Lori Dec (ldec@ocba.org)
Unless otherwise indicated, please call (248) 334-3400 for assistance.
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Michael A. Luberto
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Yuliy Osipov
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Eliana Ribitwer
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Nicholas Schneider
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Michael J. Vomastek
Monique L. Williams
The Laches editorial board hopes you’ve enjoyed the crossword puzzles. As we look to include more photographs from OCBA events in future issues, this will be the final crossword. However, if you’d like, you can always revisit previous issues of Laches to enjoy past puzzles at ocba.org/laches
By Lisa R. Bremus
1. Clammy
5. Lawyer’s exam
8. Swiss mountain range
12. Film director Kazan
13. Coastal inlet
14. Actress Ward
15. “__, meeny, miny, moe”
16. Fiend
17. Troubles
18. J.D., e.g.
20. Room
21. Lawyer’s workplace
24. Liability
27. Mineral
28. “The Raven” author
31. Actor James __ Jones
32. Soar
33. Invoice
34. School’s language program, briefly
35. Chomped
36. Jury pool
37. Tooth layer
39. Representative
43. Speaker
47. SBM __ 21 refers to designating an interim administrator
48. Unhappy
50. Tidy
51. Trees
52. Ongoing edu. courses for lawyers
53. Civil or criminal proceeding
54. Plenty (2 wds.)
55. Unwell
56. Paramedics, briefly
1. Document transferring property
2. Away from the wind
3. Actress __-Na Wen
4. Staff wages
5. Written legal argument
6. Objective
7. Musical genre
8. Immediately (abbr.)
9. Star Wars princess
10. Business structure for lawyers, briefly
11. Letter enclosure (abbr.)
19. Type of fin. transaction
20. View
22. Acct. for client funds
23. Weep
24. Contingency __
25. Community college offerings, briefly
26. Web addr.
28. Fasten
29. Grand __ Opry
30. Building extension
32. Flipper
33. Work-life __
35. Wager
36. According to
38. Business template
39. Field
40. Seabird
41. Ticklish Muppet
42. Bird house
44. Crew
45. Kiln
46. Hwys.
48. __-fi movie
49. Everything
Answers can be found at ocba.org/laches.