9 26 13 NVB 05104 File Stamped Memorandum on Mtn to Withdraw as Counsel for Interested Party Hall...

7/27/2019 9 26 13 NVB 05104 File Stamped Memorandum on Mtn to Withdraw as Counsel for Interested Party Hall 52639

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Zach Coughlin,Esq. f7 ;{Nevada Bar No: 9473- f\( (/ > ~ fl . , \L:. , t l R ~ c : \ e ~3 261."..... ~ ~ . - - - ; , I V > J .

{. t . . ~ E r V E DAND FILED

ZD13 SEP 26 Ppl 3 JlJU.S. BANKRUPTCY COURTMARYA. SCHOTT. CLERK

Reno, NV 1 L . . / 1 f E3. t/-Ir\ S: J .Tele: - I ~ , '


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the United States \pteqt and Tradel1)ark Office (USPTO). Coughlin would like to continue to,.,r d / t :r Ir e p r e s e n t ~ f i t l t s ~ n submits to this Court that refusing to allow Coughlin to do so~ i . t \may unduly b u r d e ~ ~ r whom has fulfilled his end of the bargain with Coughlin by paying3

45 the bargained for flat fee in full, and whom stands little chance of receiving back from Coughlin any6 sort of refund anytime soon (though arguably, under a quantum meruit theory, Coughlin has made7 substantial progress towards fulfilling his end of that bargain ... . This motion is made and based8 upon the pleadings and papers on file herein , and upon the Points and Authorities, and declaration r

If IZACHARY B. C O U G ~ L T N ESQ., attached hereto. All future filings shall be servfd upon ~ t< N d \ - e ~ ~ ~ . d 11 A .the address on file for trim in his main bankruptcy case \ , t.,; - \ < bi ( V< \{ f'\.\ -flWI 1,1'\2 ,- , ,. Q JLaw C, fCC I/lk/ I )

91 011121 3 Matters Constituting Unauthorized Practice of Law in Bankruptcy Proceedings, 32 ALR.6th 53114 (Originally published in 2008). Revocation or suspension of state license 4 A41516171819202 122

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43 Practicing law with federal license while state license is suspended or revoked-Held orrecognized to be unauthorized practice oflaw 44 Pra.:ticing law with federal license while state license is suspended or revoked-Held or-ecognized not to be unauthorized practice of law. .Local Rule 2014. ATTORNEYS OF RECORD(a) Appearances. An attorney who appears in a case on behall of a party is the attorney of record forthe party for any and all purposes except adversary proceedings until an order is entered permittingthe withdrawal of the attorney or the case is closed or dismissed. I) An attorney approved as specialcounsel for the bankruptcy estate and/or the debtor under II U.S.c. 327(e) (or any other applicablecode section) is attorney of record for that special purpose only. The attorney is attorney of record forthe special purpose until an order is entered permitting the withdrawal of the attorney or the case isclosed or dismissed. (2) Unless the COUlt orders otherwise or further appearance ismade in anadversary proceeding, an attorney who has appeared for a party only in the main bankruptcy case isnot automatically the attorney of record for the party in the adversary proceeding.(b) Substitution of Counsel. A stipulation and order perm itting substitution of counsel may besubmitted ex parte if (i) the substitution is signed by the client, t h e . J Y i l l J d r a w i n ~ c Q u n ~ e l ~substituting counsel; and (ii) the substituting counsel acknowledges responsibility for all pending

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1 dates and deadlines. Notwithstanding this provision, the cOUl may require that requests forsubstitution of counsel be set on noticed hearing.2

3 ,(c) Withdrawals. See LR IA 10-6 of the Local Rules of Practice for the United States District Courtfor the District of Nevada.

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LR IA 10-6. APPEARANCES, SUBSTITUTIONS AND WITHDRAWALS.a) A party who has appeared by attorney cannot while so represented appear or act in the case.

An attorney who has appeared for a party shall be recognized by the court and all the parties as havingcontrol of theclient s case. The court in its discretion may hear a party in open court even though thepai-ty is represented by an attorney.

b) No attorney may withdraw after appearing in a case exceptby leave ofcoui-t after noticeserved on the affected client and opposing counsel.c) Any stipulation to substitute attorneys shall be by leave of coui-t and I bear the sionatures_ of the attorneys and of the client represented. Except where accompanied by a request for reliefundersubsection e) of this rule, the signature of an attorney to a stipulation to substitute such attorney into a

case constitutes an express acceptance of all dates then set for pretrial proceedings. for tiial or hearing,by the discovery plan, or in any court order.

d) Discharge. withdrawal or substitution of an attorney shallilot alone be reason for delay ofpretrial proceedings. discovery. the trial , or any hearing in the case.e) Except for good cause shown, no withdrawal or substitution shall be approved if delay of

discovery. the trial or any hearing in the case would result. Where delay would result, the papersseeking leave of court for the withdrawal or substitution must request specific relief from the scheduledtrial or hearing. If a trial setting has been made, an additional copy of the moving papers shall beprovided to the clerk for immediate delivery to the assigned district judge, bankruptcy judge ormagistrate judge.

44. Practicing law with federal license while state license is suspended or revokedHeld or recognized not to be unauthorized practice of lawThe courts in the following cases held or recognized that under the particular circumstancespresented, attorneys whose licenses to practice law in the situs state were suspended orrevoked did not engage in the unauthorized practice of law when they provided or offered toprovide legal services.In U.S. v. Kirtley, 5 F.3d 1110 7th Cir. 1993), the Seventh Circuit Court of Appeals recognizedthat attorneys admitted to practice before the federal bar do not engage in the unauthorizedpractice of law when they represent clients in bankruptcy actions while under suspensionin the situs state. Although the cOUli upheld the revocation of a probation of an attorneywho otherwise continued to engage in the practice of law by handling a real estate transactionas an attorney while his license was suspended by the State ofIllinois, it approved of the action

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1 reasoned that, since the record clearly reflected that the attorney was still a member in good2 stand ing of the federal bar, he had made an appearance before a court which had authorized3 his practice of bankruptcy law.4 The court in In re Disciplinary Action Against Lallier, 555 N.W.2d 903 (Minn. 1996), upheld56 a conclusion reached by a Minnesota referee in a state disciplinary proceedings that an7 attorney did not engage in the unauthorized practice oflaw when he practiced bankruptcy lawB in a U .S. District OUli at a time when his license to practice law by the State of Minnesota9 was suspended. As observed by the court, the attorney s actions occurred at a time when his

10 state license to practice law was suspended for nonpayment of attorney registration fees and at1112 a time when he was on a restricted status for noncompliance with continuing legal education13 (CLE) requirements. The court also reasoned that the United States District Courts have a separate14 system for imposition of discipline and only require an attorney to report only public disciplinary15 actions. As a result, it said that the federal courts have reserved discretion to impose16 different discipline than that imposed by other jurisdictions. The court concluded that because1718

the attorney had not been disciplined by the state so as to justify a suspension of his right to19 practice in the federal courts. the referee properly concluded that his practice in federal district20 couli was not unauthorized.2 1 45. Practicing law in violation of federal court order

In the following authority, the issue was addressed as to whether, under the particular circumstances2 324 presented. an attorney engaged in the unauthorized practice of law by continuing2S to practice law in violation of a federal court order.2 6 The Bankruptcy Court for the District of Maryland in Ie re Downing. 195 B.R. 87027 (Bankr. D. Md. 1996), found an attorney to be in cdminal contempt after she continued to28

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practice law in that court at a time when she was barred by a court order from doing so. As explainedby the court, at an earlier time, the court sanctioned the attorney by barring her fromacting as an attorney in any matter before the court until she purged herself in accordance withthat o r d ~ I The uncontradicted evidence from several witnesses established that she subsequentlyengaged in several activities within the district including: I) actively soliciting andobtaining new clients for bankruptcy cases; (2) advising debtors to file for bankruptcy; (3)drafting bankruptcy petitions which were filed pro se; and (4) accepting fees in conjunctionwith matters brought before the court.

43. Practicing Jaw with federal license while state license is suspended or revokedHeld or recognized to be unauthorized practice of law

[Cumulative Supplement]The courts in the following cases held or recognized that under the particular circumstancespresented. attorneys whose state licenses to practice law were suspended or revokedengaged in the unauthorized practice of law when they provided. or offered to provide, legalservices.In Lite Ray Realty Corp. v. Bernstein. 200 I WL 1223484 (S.D. N.Y. 200 I), the U.S. DistrictCourt for the Southern District of New York upheld a Bankruptcy Court order disqual ifyingan attorney from engaging in the practice of law before it after the attorney was suspendedfrom practice of law by State of New York. The District Court followed the reasoning appliedby the Bankruptcy Cour t in In re Lite Ray Realty Corp., 257 B.R. 150 (Bankr. S.D. N.Y.200 I), wherein that court held that the attorney could not practice bankruptcy law before itunless the attorney associated with an attorney admitted to practice in the situs state. The courtanalyzed Spanos v. Skouras Theatres Corp., 364 F.2d 161 (2d Cir. 1966), and reasoned thatthe Second Circuit interpreted the so-called federal eXi..;eption to the unauthorized practice

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1 of law doctrine as not being applicable where an attorney not licensed by the situs state does2 not limit his practice to appearing in a specific federal case and otherwise associate or collaborate3 with an attorney who is licensed by the situs state. In contrast. in the instant case, the attorney45 maintained a law office in New York, held himself out to the public as a practitioner of6 bankruptcy law, and conducted a regular and substantia bankruptcy practice by previously7 representing hundreds of debtors in the Bankruptcy COUl for the Southern District ofNew8 York. The court determined that an association with a state-licensed attorney was necessary9 based on the reasoning that an attorney who advises on bankruptcy law must consider and discuss

10 alternative choices,involving numerous state law issues before a bankruptcy petition is1112 ever tiled on behalf of a client. Such state law issues, observed the court, can include the1 3 strength of the creditors' claims and any defenses, other forms of debt relief (e.g., compositions,1 4 ,extensions), and the consequences of not choosing bankruptcy or choosing to do nothing.15 The court also reasoned that if an attorney can only practice bankruptcy law, the attorney1 6 might be unduly influenced to tilt legal advice toward filing for bankruptcy. In addition, the17

18court determined that a federal practice exception that would allow an attorney to otherwise

19 establish a law office in a state where the attorney is not admitted to practice law generally20 would be impossible to apply and enforce in the real world. ft based its determination on the21 reasoning that any proof regarding the issue ofwhether an attorney had exceeded the restric-22 tion ,vould inherently require an examination ofthe contc :, oflegal advice protected by the2324 attorney-client privilege.25 The Bankruptcy Court for the District ofColorado in In re Seehusen, 273 B.R. 63626 (Bankr. D. Colo. 200 I held that when an attorney was disbarred by the state of Colorado, but27 apparently not otherwise disciplined by the U.S. District Court for the District ofColorado,28

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the attorney was no longer in good standing with the u s District Court and therefore engagedin the unauthorized practice of law when he: I) held himself out as being an attorney;(2) assisted in the preparation of a bankruptcy petition and related documents; (3) determineda debtor's exemptions; (4) gave advice regarding how to place assets beyond the reach of creditors;and (5) utilized a software program to prepare a debtor's bankruptcy documents whileostensibly providing unbundled legal services or petition preparer services. As the BankruptcyCourt expressly said, although the individual may not have been in technical violationof the local rule, L.B .R 910, he violated the spirit of the rule. The court reasoned that, by applicationofD.C. Colo. LR 83.5, the attorney was not in good standing with the United StatesDistrict Court for the District of Colorado when he was disbarred by the state of Colorado andhe was therefore not in good standing with the Bankruptcy Court.In Matter ofTrousil, 1 Cal. State Bar Ct. Rptr. 229, 1990 WL 180836 (Cal. State Bar Ct.1990), the Review Department of the State Bar Court of California found that a California attorneyengaged in the unauthorized practice of law when he entered into an attorney-client relationshipto represent a client in a bankruptcy matter while under suspension from the CaliforniaBar Association for nonpayment of state bar dues.In Matter of Thomson, 266 Ga . J57,464 S.E.2d 818 (1996), the Supreme Court of Georgiaheld that, while an attorney's license is suspended by the state bar, the attorney may not practicebankruptcy law in a manner which would result in either screening telephone calls ortraining and monitoring younger lawyers and paralegals. The court reasoned that attorneyswho are suspended from the practice of law by the state are only authorized to act on behalf ofother attorneys as subordinates while conducting legal research and drafting memoranda orcorrespondence for attorneys not under suspension. It also explained that no client contact is

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permitted by an attorney whose state license issuspended.ObservationAfter the Supreme COUlt of Georgia rendered its decision in Matter of Thomson, 266 Ga. 157,464 S.E.2d 818 (1996), the Court of Appeals for the Eleventh Circuit issued its opinion inWilson v. State Bar of Ga., 132 F.3d 1422 (11th Cir. 1998), which indicated that it would notbe inclined to provide relief to allow attorneys to practice bankruptcy law after they have beendisbarred or had their licenses suspended by the state courts. In the Wilson case, anum,ber ofsuspended and disbarred attorneys employed by practicing lawyers brought a 42 U.S.CA. 1983 action against the State Bar of Georgia. They alleged that the state bar rules prohibitingsuspended and disbarred attorneys from having client contact within their employers firms violatedtheir right to fi ee speech . The Court of Appeals, however, upheld a summary judgmentfor the state bar while ruling that the state bar rules were not void for vagueness and theplaintiffs lacked standing to assert a First Amendment challenge to the rules . As the EleventhCircuit observed, the state bar s motion in support of its rules made it clear that the provisionswere only drafted to insulate disbarred attorneys frol11 having contact with the public with re-spect to legal matters and the rules did not extend to nonlegal matters. The COUlt further observedthat the Thomson case dealt with an attorney who was employed in a high volume consumerbankruptcy firm, but it did not otherwise indicate that it would be inclined to rule favorablyfor an attorney whose license to practice state law was suspended and thereafter onlysought to handle bankruptcy matters in an incidental way.In Matter of Perrello, 270 Ind . 390, 386 N.E .2d 174 (1979), the Indiana Supreme Courtheld that its earlier order suspending an attorney from practicing law precluded the attorneyfrom practicing law before the federal courts within the state. As a result, it ruled that an attorney

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1 who maintained a law office and handled several matters in the U.S. District Courts for2 the Southern District ofIndiana and counseling with clients on federal matters such as bankruptcy3 and appearing in COUIt during the sLlspension period, warranted another order to have4 the attorney incarcerated for 90 days. l t ~ o u g h the Indiana Supreme Court said that it could56 neither presume to tell the federal courts who they may permit to practice before them, nor set7 the standards, qualifications, or limitations they might place on such persons, it said that the8 Indiana Constitution provides that the sole authorityand responsibility for the practice oflaw9 in Indiana is in the Supreme Court of Indiana, that the federal courts do not have a independent

10 mechanism for determining who is qualified for practice before them. The Indiana Supreme11

Court cited Ginsburg v. Kovrak, 392 Pa. 143, 139 A.2d 889 (1958), as being analogous,1 2

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and it ruled that the practice of law in the federal courts in Indiana is the practice of lawfor the purposes of determining whether a person had engaged in the unauthorized practice oflaw.CautionThe opinion in Ginsburg v. Kovrak, 392 Pa. 143, 139 A.2d 889 (1958), was issued by thePennsylvania Supreme Court prior to the U.S. Supreme Court s ruling in Sperry v. State ofFla. ex reI. Florida Bar, 373 U.S. 379, 83 S Ct. 1322, 10 L Ed. 2d 428, 137 U.S.P.Q. 578(1963). Caution also needs to be exercised when citing Matter of Perrello, 270 Ind. 390, 386N .E.2d 174 (1979), because neither the Perrella opinion nor the Kovrak opinion analyzed orcited Theard v. U.S., 354 U.S. 278 , 77 S. Ct. 1274, I L Ed. 2d 1342 (1957) (holding that disbarmentby federal courts does not necessarily flow from disbarment by state courts), In reRuffalo, 390 U.S. 544, 88 S. Ct. 1222 20 L Ed. 2d 117 (1968) (accord), or Selling v Radford,243 U.S . 46 37 S. Ct. 377 61 L Ed. 585 (1917) (accord).

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1 In State v. Blase, 208 Kan. 969,494 P.2d 1224 (1972), the cOUIi held that an attorney who2 had been suspended fro l the practice of law by the Kansas Supreme Court engaged in the3 unauthorized4 practice of law when he gave bankruptcy advice to clients in exchange for a fee.56 Although the suspended attorney did not make a court appearance, the court observed that he:7 I) discussed the bankruptcy process with the couple; (2) informed them that he would be8 their attorney but that another attorney would make court appearances with them; (3) assisted9 them with completing their schedules; (4) advised them to ignore a creditor and respond to the

10 creditor by saying that they were filing bankruptcy and the creditor should contact the ir attorney;

12 and (5) advised them that they could legally reaffirm a debt provided that they entered into13 Ia new contract with the creditor.14 Failing to notify a bankruptcy client of disciplinary acti0n resulting in a suspension of the15 right to practice law by the State ofNorth Dakota, and failing to terminate an attorney--client16 relationship during the suspension period, was implicitly ruled to be the unauthorized practice1718 of law when the court ordered the disbarment of an attorney in Disciplinary Bd. of Supreme19 Court of State ofN.D. v. Robb, 2000 NO 194, 618 N.W.2d 72 (N.D. 2000).20 In State ex reI. Oklahoma Bar Ass n v. Holden, 1996 OK 88, 925 P.2d 32 (Okla. 1996), the21 COUlt implicitly ruled that an attorney engaged in the unauthorized practice oflaw when the22 attorney was suspended from practice by the Oklahoma Supreme Court and thereafter gave2324 legal advice regarding bankruptcy issues while under suspension.25 In Matter of Disciplinary Proceedings Against Kells, 172 Wis. 2d 6 3 , 493 N.W.2d 72326 (1993), reconsideration denied, (Mar. 23, 1993). the Wi.sconsin Supreme Court held that an attorney27 who was suspended from the practice of law in Wisconsin engaged in the unauthorized28

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practice of law in violation of Wis. Sup. Ct. R. 22.26(2) when he drafted sophisticated bankruptcy-2 related documents for his wife in her bankruptcy proceeding. The court rejected the3 challenge to its jurisdiction while saying that the suspended attorney mistakenly framed the issue4 as involving a challenge to the Wisconsin Supreme Court's authority or jurisdiction to determineS6 who is allowed to practice in federal courts in Wisconsin. The court said that although7 lhe suspended attorney correctly asserted that the determination regarding who is allowed to8 practice in the federal courts is for the federal courts to make, the COllrt concluded that it had9 the authorityto make the ultimate determination of whether an attorney whose license is suspended

10 had engaged in the unauthorized practice of law in Wisconsin. The court noted that,although the suspended attorney obtained an order from the Bankruptcy Court specitically1 2 ,

13 authorizing1 4 him to assist his wife (and apparently obtain an advance approval from the Bankruptcy15 Court for compensation related to subsequently performed legal services), he also16 made an inquiry with the Wisconsin Board of Attorneys Professional Responsibility and its1718 resolution counsel told him that he should not represent his wife as an attorney in the bankruptcy19 proceeding. The Wisconsin Board's resolution counsel apparently took the position that20 the Bankruptcy Court's order only authorized the suspended attorney to assist his wife to the21 extent that any spouse of a pro se debtor would and the cOUl reasoned that the Bankruptcy22

Court order did not supersede the prohibition of Wis. Sup. Ct. R. 22.26(2). The Wisconsin Supreme23

24 Court agreed with the Board's position, while concluding that the suspended attorney's2S actions exceeded the scope of the counseling provided by a spouse of a pro se debtor, in that26 he provided various legal documents for his wife which required a sophisticated knowledge of2 7 the law. The documents that he prepared included the bankruptcy petition , a motion for a protective

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1 order and accompanying affidavit, a document entitled Defendant's Objection to2 Plaintiff's Amendment of the Complaint and supporting affidavit, an adversary answer to the3 amended complaint, interrogatories to the plain tiff and a motion for an order compelling the4 plaint iff to answer the interrogatories, a trial brief, and a brief seeking sanctions. The preparation:)6 ofthese documents, reasoned the court, with the marshalling oflegal arguments and citations7 to state and federal law exceeded the kind of participation a pro se debtor's spouse would8 normally be permitted to undertake. The suspended attorney also conferred with opposing9 counsel, drafted letters to the court, and attended court conferences and hearings. The court

10 ,also thought that it was noteworthy that at the close of the bankruptcy proceeding, the attorney1 2 sought to recover payment for the assistance that he had given his wife. In the Bankruptcy13 Court. he submitted an affidavit to the court stating that he had provided 187.8 hours of service,1 4 for which he sought payment at a rate of 100 to 150 per hour, for a total fee of15 between 18,780 and 28,170 . The submission of his affidavit to the Bankruptcy Court showing16 the itemized services established that he directed and controlled his wife's case as her attorney.171 8 The Wisconsin Supreme Court also concluded that the order from the Bankruptcy19 Court which authorized the attorney's participation in his wife's bankruptcy proceeding did not20 supersede the prohibition of Wis. Sup. Ct. R. 22.26(2).21 Observation22

The Wisconsin Supreme Court in n re Disciplinary Proceedings Against Hyndman, 2002 WI23 ,24 6,249 Wis. 2d 650,638 N.W.2d 293 (2002), the facts of which are more fully set out in 25,25 reiterated its position that it has the authority to determine whether a revocation ofa license to26 practice law under its jurisdiction can preclude an individual from handling bankruptcy matters27 and whether specific activities constitute the unauthorized practice of law. While reasserting28

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its authority over activities within its geographical borders, it ultimately determined in the2 Hyndman case that the activities of an individual whose state license had been suspended did3 not engage in the unauthorized practice of law when he attended creditors meetings on behalf4 , of a non attorney employer because the individual did not violate the state rules and he made it56 clear to the attending parties that he was attending the creditors meeting while acting only as7 a layperson.8 Conduct of attorney, whose I cense had been suspended in advising a friend about which9 chapter to file in bankruptcy, and advising her not to exempt her house when filing for bankruptcy,

\,10 amounted to the unauthorized practice of law, in violation of the rule of professional1112 conduct prohibiting unauthorized practice of law; the advice given by suspended attorney required13 the use of legal judgment requiring legal knowledge, skill, and ability beyond those14 possessed by a layman. Sup.Ct.Rules, Rule 226, Rules ofProf.Conduct, Rule 5.5(a). In re1 5 Swisher, 179 P.3d 412 (Kan. 2008).1 617

181 92 0 suspension of Coughlin s law license entered by the Nevada Supreme Court on June 7th,21 20l2 .. Coughlin does, however, respectfully asl{ this Court for an indication of whether the22232425,

NVB has a position on attorney s, in general, continuing to practice before the NVB when thereI r I I

J I I i I ilaw license has been suspended by the State Bar of Nevada ~ " > e ' 1 ( ' i t( S i { j , lvi h :;.; >..- 6 11 J l I J

. F o r t h l J J a s . o J l ~ - & i t e e - a : m V e : - O ~ i d a l i t r e s p e C T f u t ~ s lilac thIS Court r ~ frOI l li e R t ~ r i b..2627 DATED this August 20, 2012.28

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1234 DEC LARATION OF ZACH COUGHLIN, ESQ. IN SUPPORT OF MOTION TO WITHDRA W ASCOUNSEL OF RECORD56789

T Zach Coughlin, Esq., declarE under penalty of peljury pursuant to NRS 54.045 that thefollowing s true and correct:I. That I am an attorney licensed to practice law n the State of Nevada CURRENTLYSUSPENDED THOUGH , and thatI have personal knowledge of and am competent to testify

1 0 ,concerning the facts herein.11 A copy of this application has been mailed to J \ 1 I \ H ~ ~ l = I a t his last known address: Robert Keller1213

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CERTIFICATE OF SERVICE AND MAILINGI HEREBY CERTIFY that on this this date a true and correct copy ofthe foregoing, document,wasfiled with the CM/ECF system, which thereby caused the above to be served electronically on all

I registered users of the CM/ECF system who have filed notices of appearance in this matter. I fUIthercertity that the foregoing was served via first class mail, postage-prepaid and addressed as follows:JMICHAEL P. O' ROURKE, ESQ.Nevada Bar No. 6764O'ROURKE LA W GROUP, PC800 Fifth Avenue, Suite 41 00Seattle, Washington 98104Telephone: (206) 477-1475Facsimile: (206) [email protected] 1. SMITH, ESQ.Nevada Bar No. 11279Of Counsel to O'ROURKE LAWGROUP, PC700 South Third StreetLas Vegas, Nevada 89101Telephone: (702) 380-8248Facsimile: (702) 382-7595

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9 26 13 NVB 05104 File Stamped Memorandum on Mtn to Withdraw as Counsel for Interested Party Hall...

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