ANNOTATIONSSource:
Comment amended April 20, 2000, effective July 1, 2000.
COMMENT
The client should have sufficient information to participate
intelligently in decisions concerning the objectives of the
representation and the means by which they are to be pursued, to the
extent the client is willing and able to do so. In order to avoid
misunderstandings and hence to maintain public confidence in law and
lawyers, a lawyer should fully and promptly inform the client of
material developments in the matters being handled for the client. For
example,
a lawyer negotiating on behalf of a client should provide the client with
facts
relevant to the matter, inform the client of communications from another
party
and take other reasonable steps that permit the client to make a decision
regarding a serious offer from another party. A lawyer ought to initiate
this decision-making process
if the client does not do so. A lawyer who receives from opposing
counsel an offer of settlement in a civil controversy or a proffered
plea bargain in a criminal case should promptly inform the client of its
substance unless prior discussions with the client have left it clear
that the proposal will be unacceptable. See Rule 1.2(a). Even when a
client delegates authority to the lawyer, the client should be kept
advised of the status of the matter. A lawyer should exert best efforts
to insure that decisions of the client are made only after the client
has been informed of relevant considerations.
Adequacy of communication depends in part on the kind of advice or
assistance involved. A lawyer should advise the client of the possible
legal effect of each alternative course of action. For example, in
negotiations where there is time to explain a proposal, the lawyer
should review all important provisions with the client before proceeding
to an agreement. In litigation a lawyer should explain the general
strategy and prospects of success and ordinarily should consult the
client on tactics that might injure or coerce others. On the other
hand, a lawyer ordinarily cannot be expected to describe trial or
negotiation strategy in detail. The guiding principle is that the
lawyer would fulfill reasonable client expectations for information
consistent with the duty to act in the client's best interest, and the
client's overall requirements as to the character of representation.
Ordinarily, the information to be provided is that appropriate for
a client who is a comprehending and responsible adult. However, fully
informing the client according to this standard may be impracticable,
for example, where the client is a child or suffers from mental
disability. See Rule 1.14. When the client is an organization or
group, it is often impossible or inappropriate to inform every one of
its members about its legal affairs; ordinarily, the lawyer should
address communications to the appropriate officials of the organization.
See Rule 1.13. Where many routine matters are involved, a system of
limited or occasional reporting may be arranged with the client.
Practical exigency may also require a lawyer to act for a client without
prior consultation.
Information Pertaining to Fees Charged, Costs, Expenses, and
Disbursements
Information provided to the client under Rule 1.4(a) should
include information concerning fees charged, costs, expenses,
and disbursements with regard to the client's matter.
Additionally, the lawyer should promptly respond to the client's
reasonable requests concerning such matters. It is strongly
recommended that all these communications be in writing. As to
the basis or rate of the fee, see Rule 1.5.
Withholding Information
In some circumstances, a lawyer may be justified in delaying
transmission of information when the client would be likely to react
imprudently to an immediate communication. Thus, a lawyer might
withhold a psychiatric diagnosis of a client when the examining
psychiatrist indicates that disclosure would harm the client. A lawyer
may not withhold information to serve the lawyer's own interest or
convenience. Rules or court orders governing litigation may provide
that information supplied to a lawyer may not be disclosed to the
client. Rule 3.4(c) directs compliance with such rules or orders.
COMMITTEE COMMENT
Twenty-eight (28) of 39 States which have adopted some form of the
Model Rules have adopted or recommended adoption of Rule 1.4 without
substantive change. This Committee views it as a necessary recognition
of a lawyer's obligation to the client.
The Rule states a lawyer's obligation in an affirmative way.
Although there is no direct counterpart to Rule 1.4 in the Code the
subject matter is covered in several provisions of the Code. The
Committee intends no substantive change from the provisions of the Code
of Professional Responsibility.
ANNOTATION
Law reviews. For article, "The Evolving Doctrine of Informed Consent
in Colorado", see 23 Colo. Law. 591 (1994).
For article, "Confirm Attorney Fees in Writing: Court Changes Colo. RPC 1.4, 1.5", see
29 Colo. Law. 27 (June 2000).
Annotator's note.
Rule 1.4 is similar to
DR 6-101 and DR 9-102 as they
existed prior to the 1992 repeal and reenactment of the Code of
Professional Responsibility.
Relevant cases construing DR 9-102 have
been included in the annotations to this rule.
Cases construing DR 6-101 have
been included under Rule 1.1.
Public censure appropriate where harm suffered by attorney's client was
speculative, attorney retracted his misrepresentations and admitted to his
client before the institution of disciplinary proceedings that he had done
nothing on the client's appeal, attorney had no prior discipline, he made full
and free disclosure of his misconduct to the grievance committee, and he
expressed remorse for his misconduct. People v. Nelson, 848 P.2d 351 (Colo.
1993).
Public censure instead of private censure was appropriate where
attorney failed to respond to discovery requests and motions for summary
judgment and the findings of the board did not support the applicability of ABA
Standard 9.32(i) as a mitigating factor since there was no medical evidence
that attorney was affected by chemical dependency or that alcohol contributed
to or caused the misconduct. People v. Brady, 923 P.2d 887 (Colo. 1996).
Aggravating and mitigating factors. The following factors are considered
aggravating when deciding the appropriate level of discipline: (1) Prior discipline, (2) a
pattern of misconduct, and (3) bad faith obstruction of the disciplinary process through total
non-cooperation with the disciplinary authorities. Failure to appear before the disciplinary
board will cause one to lose the ability to present evidence of mitigating factors. People v.
Stevenson, 980 P.2d 504 (Colo. 1999).
Attorney's restitution agreement was neither an aggravating nor mitigating
factor
since the attorney did not propose or attempt any form of restitution until
after a request for investigation had been filed with the office of
disciplinary counsel. People v. Brady, 923 P.2d 887 (Colo. 1996).
Attorney's argument that public discipline is not appropriate because it
would stigmatize a recovering alcoholic was rejected since overriding
concern in discipline proceedings is to protect the public through the
enforcement of professional standards of conduct. People v. Brady, 923 P.2d
887 (Colo. 1996).
Neglecting to file response to motion for summary judgment and to return
client files upon request was sufficient to result in one-year and one-day
suspension. People v. Honaker, 847 P.2d 640 (Colo. 1993).
Ninety-day suspension justified where attorney's failure to respond to
discovery requests resulted in default and entry of judgment against client
for $816,613. People v. Clark, 927 P.2d 838 (Colo. 1996).
Attorney's inaction over a period of more than two years and other
disciplinary violations warrant suspension for 30 days where there are
mitigating factors. People v. LaSalle, 848 P.2d 348 (Colo. 1993).
Suspension for one year and one day appropriate when attorney neglected
to return client files upon request. People v. Honaker, 847 P.2d 640
(Colo. 1993).
Suspension for three years, rather than disbarment, was appropriate where
violation of this rule and others caused serious harm to attorney's clients, but mitigating
factors were present, including no previous discipline in 14 years of practice, personal
and emotional problems, and cooperation and demonstrated remorse in proceedings. People
v. Henderson, 967 P.2d 1038 (Colo. 1998).
Three-year suspension warranted for attorney who effectively abandoned and failed
to communicate with clients. People v. Shock, 970 P.2d 966 (Colo. 1999).
Previously disbarred attorney who violated this rule would be forced
to pay restitution to clients as a condition of readmission. People v.
Vigil, 945 P.2d 1385 (Colo. 1997).
Conduct violating this rule in conjunction with other disciplinary rules
is sufficient to justify public censure.
People v. Titoni, 893 P.2d 1322 (Colo. 1995);
People v. Doherty, 908 P.2d 1120 (Colo. 1996);
People v. Woodrum, 911 P.2d 640 (Colo. 1996);
People v. Barbieri, 935 P.2d 12 (Colo. 1997);
People v. Williams, 936 P.2d 1289 (Colo. 1997);
People v. Buckingham, 938 P.2d 1157 (Colo. 1997);
People v. Todd, 938 P.2d 1160 (Colo. 1997);
People v. Doherty, 945 P.2d 1380 (Colo. 1997);
People v. Barr, 957 P.2d 1379 (Colo. 1998).
Conduct violating rule sufficient to justify public censure.
People v. Smith, 847 P.2d 1154 (Colo. 1993);
People v. Damkar, 908 P.2d 1113 (Colo. 1996);
People v. Marsh, 908 P.2d 1115 (Colo. 1996);
People v. Jenks, 910 P.2d 688 (Colo. 1996);
People v. Pooley, 917 P.2d 712 (Colo. 1996);
People v. Belsches, 918 P.2d 559 (Colo. 1996).
Conduct violating this rule in conjunction with other
disciplinary rules is sufficient to justify suspension.
People v. Crews, 901 P.2d 472 (Colo. 1995);
People v. Kuntz, 908 P.2d 1110 (Colo. 1996);
People v. Murray, 912 P.2d 554 (Colo. 1996);
People v. Hohertz, 926 P.2d 560 (Colo. 1996);
People v. Paulson, 930 P.2d 582 (Colo. 1997);
People v. Bates, 930 P.2d 600 (Colo. 1997);
People v. Reynolds, 933 P.2d 1295 (Colo. 1997);
People v. Townshend, 933 P.2d 1327 (Colo. 1997);
People v. Scott, 936 P.2d 573 (Colo. 1997);
People v. Sather, 936 P.2d 576 (Colo. 1997);
People v. Harding, 937 P.2d 393 (Colo. 1997);
People v. Primavera, 942 P.2d 496 (Colo. 1997);
People v. Field, 944 P.2d 1252 (Colo. 1997);
People v. Johnson, 946 P.2d 469 (Colo. 1997);
People v. Wright, 947 P.2d 941 (Colo. 1997);
People v. Rishel, 956 P.2d 542 (Colo. 1998);
In re Corbin, 973 P.2d 1273 (Colo. 1999);
In re Bobbitt, 980 P.2d 538 (Colo. 1999);
In re Demaray, 8 P.3d 427 (Colo. 1999).
Conduct violating this rule, in conjunction with other disciplinary
rules, sufficient to justify disbarment where the attorney continued to
practice law while
on suspension, repeatedly neglecting his clients and failing to take
reasonable steps to
protect clients' interests. People v. Fager, 938 P.2d 138 (Colo. 1997).
Conduct violating this rule in conjunction with other disciplinary rules
is sufficient to justify disbarment. People v. Jamrozek, 921 P.2d 725
(Colo. 1996);
People v. Steinman, 930 P.2d 596 (Colo. 1997);
People v. Wallace, 936 P.2d 1282 (Colo. 1997);
People v. Mannix, 936 P.2d 1285 (Colo. 1997);
People v. Madigan, 938 P.2d 1162 (Colo. 1997);
People v. Swan, 938 P.2d 1164 (Colo. 1997);
People v. Clyne, 945 P.2d 1386 (Colo. 1997);
People v. Crist, 948 P.2d 1020 (Colo. 1997);
People v. Roybal, 949 P.2d 993 (Colo. 1997);
People v. Holmes, 951 P.2d 477 (Colo. 1998);
People v. Holmes, 955 P.2d 1012 (Colo. 1998);
People v. Hindman, 958 P.2d 463 (Colo. 1998);
People v. Valley, 960 P.2d 141 (Colo. 1998);
People v. Skaalerud, 963 P.2d 341 (Colo. 1998);
In re Bilderback, 971 P.2d 1061 (Colo. 1999);
In re Hugen, 973 P.2d 1267 (Colo. 1999);
In re Tolley, 975 P.2d 1115 (Colo. 1999);
In re Stevenson, 979 P.2d 1043 (Colo. 1999).
Conduct violating rule sufficient to justify disbarment.
People v. Robnett, 859 P.2d 872 (Colo. 1993).
Cases Decided Under Former DR 9-102.
Law reviews. For series of articles, "Interest on Lawyer Trust
Accounts Program: A Primer for Lawyers", see 12 Colo. Law 577 (1983).
For article, "Ethical Problem Areas for Probate Lawyers", see 19 Colo. Law.
1069 (1990).
Paragraphs (A) and (B)(3) require as a minimum standard of conduct that
a lawyer segregate his clients' funds from his own and keep them in
identifiable bank trust accounts. People v. Harthun, 197 Colo. 1, 593 P.2d
324 (1979); People v. Schubert, 799 P.2d 388 (Colo.
1990).
Most severe punishment is required when a lawyer disregards his
professional obligations and converts his clients' funds to his own use.
People v. Kluver, 199 Colo. 511, 611 P.2d 971 (1980);
People v. Dohe, 800 P.2d 71 (Colo. 1990);
People v. Whitcomb, 819 P.2d 493 (Colo. 1991).
Misuse of funds by a lawyer strikes at the heart of the legal profession
by destroying public confidence in lawyers. The most severe punishment is
required when a lawyer disregards his professional
obligations and converts his clients' funds to his own use.
People v. Buckles, 673 P.2d 1008 (Colo. 1984);
People v. Wolfe, 748 P.2d 789 (Colo. 1987).
Conversion of client funds is conduct warranting disbarment because it
destroys the trust essential to the attorney-client relationship, severely
damages the public's perception of attorneys, and erodes public confidence
in our legal system. People v. Radosevich, 783 P.2d 841 (Colo. 1989).
Disbarment is the presumed sanction for misappropriation of funds
barring significant mitigating circumstances. People v. Young, 864 P.2d
563 (Colo. 1993); People v. Varallo, 913 P.2d 1 (Colo. 1996); People v.
Coyne, 913 P.2d 12 (Colo. 1996).
Failure and refusal to refund unearned portions of fees collected from
two clients constituted violations
of C.R.C.P. 241(B) (now C.R.C.P. 241.6), DR 2-110, and this rule.
People v. Gellenthien, 621 P.2d 328 (Colo. 1981).
Attorney obligated to forward client's file upon request. Failure to
forward client's file a year after a request is made constitutes conduct
violative of disciplinary rules. People v. Belina, 765 P.2d 121 (Colo. 1988).
Failing to provide a client with an accounting of charges applied against
a retainer after the client's request therefor, in conjunction with other
instances of neglect, is conduct warranting public censure.
People v. Goodwin, 782 P.2d 1 (Colo. 1989).
Failure to make proper accounting to client with respect to trust
funds and failure to promptly deliver to the client funds to which she is
entitled warrants public censure. People v. Robnett, 737 P.2d 1389
(Colo. 1987).
Failure to deposit funds in trust account, to notify client of
receipt of funds and provide accounting, and to forward file promptly to
new attorney constitute a violation of this rule and, with other offenses,
warrants public censure. People v. Swan, 764 P.2d 54 (Colo. 1988).
Violation of duty to account for and promptly return client property upon
request over a three-year period warrants public censure. People v.
Shunneson, 814 P.2d 800 (Colo. 1991).
Public censure for failure to promptly distribute proceeds of a
settlement is warranted since respondent's negligence did little or no
actual or potential injury to client. People v. Genchi, 824 P.2d 815
(Colo. 1992).
Conduct violating this rule in conjunction with other disciplinary rules
is sufficient to justify public censure. People v. Ashley, 796 P.2d 962
(Colo. 1990); People v. Sadler, 831 P.2d 887 (Colo. 1992).
Converting estate or trust funds for one's personal use, overcharging
for services rendered, neglecting to return inquiries relating to client
matters, failing to make candid disclosures to grievance committee, and
attempting to conceal wrongdoing during disciplinary proceedings warrants
the severe sanction of disbarment. People v. Gerdes, 782 P.2d 2 (Colo. 1989).
Conduct violating this rule sufficient to justify public censure.
People v. Bollinger, 648 P.2d 620 (Colo. 1982);
People v. Wright, 698 P.2d 1317 (Colo. 1985);
People v. Mayer, 716 P.2d 1094 (Colo. 1986);
People v. Schaiberger, 731 P.2d 728 (Colo. 1987);
People v. Barr, 748 P.2d 1302 (Colo. 1988);
People v. Danker, 759 P.2d 14 (Colo. 1988).
Two-year unjustified retention of one client's file, coupled with
failure to withdraw at request of said client and refusal to forward a
second client's file to subsequent counsel, resulting in both clients
sustaining injuries, justifies suspension for the
period of a year and a day.
People v. Hodge, 752 P.2d 533 (Colo. 1988).
Failure to account for money collected on behalf of client, despite
numerous client requests for accounting, and failure to adhere to terms of
agreement with client regarding representation, coupled with prior, ongoing
suspension, warrants additional six-month suspension.
People v. Yost, 752 P.2d 542 (Colo. 1988).
Conduct violating this rule in conjunction with other
disciplinary rules is sufficient to justify suspension.
People v. Moya, 793 P.2d 1154 (Colo. 1990);
People v. Creasey, 793 P.2d 1159 (Colo. 1990);
People v. Schubert, 799 P.2d 388 (Colo. 1990);
People v. Garrett, 802 P.2d 1082 (Colo. 1990);
People v. Lamberson, 802 P.2d 1098 (Colo. 1990);
People v. Crimaldi, 804 P.2d 863 (Colo. 1991);
People v. Dunsmoor, 807 P.2d 561 (Colo. 1991);
People v. Dash, 811 P.2d 36 (Colo. 1991);
People v. Creasey, 811 P.2d 40 (Colo. 1991);
People v. Wilson, 814 P.2d 791 (Colo. 1991);
People v. Heilbrunn, 814 P.2d 819 (Colo. 1991);
People v. Smith, 828 P.2d 249 (Colo. 1992);
People v. Driscoll, 830 P.2d 1019 (Colo. 1992);
People v. Regan, 831 P.2d 893 (Colo. 1992);
People v. Denton, 839 P.2d 6 (Colo. 1992).
People v. Smith, 880 P.2d 763 (Colo. 1994);
People v. Banman, 901 P.2d 469 (Colo. 1995);
People v. Crews, 901 P.2d 472 (Colo. 1995);
People v. Dickinson, 903 P.2d 1132 (Colo. 1995);
People v. Davis, 911 P.2d 45 (Colo. 1996).
Conduct violating this rule sufficient to justify suspension.
People v. Vernon, 660 P.2d 879 (Colo. 1982);
People v. Pilgrim, 698 P.2d 1322 (Colo. 1985);
People v. Foster, 716 P.2d 1069 (Colo. 1986);
People v. Coca, 716 P.2d 1073 (Colo. 1986);
People v. Calvert, 721 P.2d 1189 (Colo. 1986);
People v. Holmes, 731 P.2d 677 (Colo. 1987);
People v. Geller, 753 P.2d 235 (Colo. 1988);
People v. Griffin, 764 P.2d 1166 (Colo. 1988);
People v. Goldberg, 770 P.2d 408 (Colo. 1989);
People v. Goens, 770 P.2d 1218 (Colo. 1989);
People v. Kaemingk, 770 P.2d 1247, (Colo. 1989);
People v. McGrath, 780 P.2d 492 (Colo. 1989).
Derelictions in fiduciary duties by an attorney which go
beyond mere negligence warrant disbarment. People v. Roads,
180 Colo. 192, 503 P.2d 1024 (1972).
Attorney failed to deliver property of a client in violation of this
rule by ignoring requests for client's files made by the client, the
client's attorney, and the grievance committee. People v. Felker, 770 P.2d
402 (Colo. 1989).
Refusal to provide accounting for money and jewelry delivered to him
and refusal to itemize the services performed and the costs incurred warrant disbarment.
People v. Lanza, 660 P.2d 881 (Colo. 1983).
Commingling and appropriation of funds warrants disbarment. When a
lawyer collects $3000 on behalf of a client in connection with a sale of
real estate and commingles it with his other trust funds and unlawfully converts
it to his own use, his flagrant disregard of his professional obligation
warrants disbarment. People v. McMichael, 199 Colo. 433, 609 P.2d 633 (1980).
Where a practicing attorney breached fiduciary duties to his client in
misrepresenting his dealings and in handling of funds given to him in trust,
his conduct warranted disbarment, and, before he may seek readmittance to
the state bar association, he must first demonstrate to the grievance committee
that rehabilitation has occurred and that he is entitled to a new start.
People ex rel. Buckley v. Beck, 199 Colo. 482, 610 P.2d 1069 (1980).
Commingling a client's funds with those of the lawyer is a serious
violation of the Code of Professional Responsibility, even in the absence
of an actual loss to the client, because the act of commingling subjects the
client's funds to the claims of the lawyer's creditors. People v. McGrath,
780 P.2d 492 (Colo. 1989).
Misappropriation of funds, failure to account, and deceit and fraud
in handling the affairs of a client necessitate that an attorney be disbarred.
People v. Bealmear, 655 P.2d 402 (Colo. 1982);
People v. Costello, 781 P.2d 85 (Colo. 1989).
Conduct which causes a client serious or potentially serious injury
and demonstrates a complete lack of concern for a client's interests and
welfare warrants disbarment. People v. Lyons, 762 P.2d 143 (Colo. 1988).
Alcoholism not excuse.
Efforts at alcoholism rehabilitation do not excuse conduct which includes
dishonesty and fraud, failing to preserve identity of client funds, and
failing to properly pay or deliver client funds, and which otherwise warrants
disbarment. People v. Shafer, 765 P.2d 1025 (Colo. 1988).
Total disregard of obligation to protect a client's rights and
interests over an extended period of time in conjunction with the
violation of a number of disciplinary rules and an extended prior record of
discipline requires most severe sanction of disbarment. People v. O'Leary,
783 P.2d 843 (Colo. 1989).
Disbarment was appropriate where attorney removed $5,000 from a
client's trust account, refused to return money upon several request by the
client which ultimately resulted in a suit against the attorney, and the
attorney lied about the transaction to the attorney with whom he shared
office space. Factors in aggravation included a history of prior discipline,
including suspension for conversion of client funds, the dishonest motive of
the
attorney in removing and not returning the client's funds, the attorney's
refusal to acknowledge the wrongful nature of his conduct, the vulnerability
of the client, and the attorney's legal experience. Mitigating factors were
insufficient for disciplinary action short of disbarment. People v. McGrath,
833 P.2d 731 (Colo. 1992).
Disbarment is appropriate sanction where attorney knowingly converts
client property and causes injury or potential injury to a client. People
v. Bowman, 887 P.2d 18 (Colo. 1994);
People v. Varallo, 913 P.2d 1 (Colo. 1996).
Rule is violated when attorney "knowingly" converts client funds;
there is no requirement that the attorney intend to permanently deprive the
client of the funds. People v. Varallo, 913 P.2d 1 (Colo. 1996).
Disbarment was appropriate where attorney converted $25,000 of client
funds on seven different occasions over a period of four months and did not
restore any of the missing funds until after he was detected. People v.
Robbins, 869 P.2d 517 (Colo. 1994).
Disbarment was appropriate where the balance of the respondent's
trust accounts fell below the amount necessary to pay settlements on at least
45 occasions and where the respondent withdrew attorney fees on at
least 68 occasions from trust accounts before receiving the funds from
which the fees were to be taken. People v. Lefly, 902 P.2d 361 (Colo. 1995).
Conduct violating this rule in conjunction with other disciplinary rules
is sufficient to justify disbarment.
People v. Nichols, 796 P.2d 966 (Colo. 1990);
People v. Broadhurst, 803 P.2d 478 (Colo. 1990);
People v. Rhodes, 814 P.2d 787 (Colo. 1991);
People v. Vermillion, 814 P.2d 795 (Colo. 1991);
People v. Ashley, 817 P.2d 965 (Colo. 1991);
People v. Rouse, 817 P.2d 967 (Colo. 1991);
People v. Whitcomb, 819 P.2d 493 (Colo. 1991);
People v. Margolin, 820 P.2d 347 (Colo. 1991);
People v. Bradley, 825 P.2d 475 (Colo. 1992);
People v. Mullison, 829 P.2d 382 (Colo. 1992);
People v. Tanquary, 831 P.2d 889 (Colo. 1992);
People v. McGrath, 833 P.2d 731 (Colo. 1992);
People v. Brown, 840 P.2d 348 (Colo. 1992);
People v. Walsh, 880 P.2d 766 (Colo. 1994);
People v. Varallo, 913 P.2d 1 (Colo. 1996);
People v. Coyne, 913 P.2d 12 (Colo. 1996);
People v. Jamrozek, 921 P.2d 725 (Colo. 1996).
Conduct violating this rule sufficient to justify disbarment.
People v. Kendrick, 646 P.2d 337 (Colo. 1982);
People v. Dwyer, 652 P.2d 1074 (Colo. 1982);
People v. Golden, 654 P.2d 853 (Colo. 1982);
People v. Fitzke, 716 P.2d 1065 (Colo. 1986);
People v. Quick, 716 P.2d 1082 (Colo. 1986);
People v. Yost, 729 P.2d 348 (Colo. 1986);
People v. James, 731 P.2d 698 (Colo. 1987);
People v. Coca, 732 P.2d 640 (Colo. 1987);
People v. Foster, 733 P.2d 687 (Colo. 1987);
People v. Quintana, 752 P.2d 1059 (Colo. 1988);
People v. Kengle, 772 P.2d 605 (Colo. 1989);
People v. Frank, 782 P.2d 769 (Colo. 1989);
People v. Dulaney, 785 P.2d 1302 (Colo. 1990);
People v. Franks, 791 P.2d 1 (Colo. 1990);
People v. Mulligan, 817 P.2d 1028 (Colo. 1991);
People v. Young, 864 P.2d 563 (Colo. 1993).
Failure to transfer file to new attorney after repeated requests
constitutes a violation of this rule. People v. Hebenstreit,
764 P.2d 51 (Colo. 1988).
Conduct held to violate this rule.
People v. Goss, 646 P.2d 334 (Colo. 1982).
Applied in
People v. Spiegel, 193 Colo. 161, 567 P.2d 353 (1977);
People v. Good, 195 Colo. 177, 576 P.2d 1020 (1978);
People v. Pacheco, 198 Colo. 455, 608 P.2d 333 (1979);
People v. Belfor, 200 Colo. 44, 611 P.2d 979 (1980);
People ex rel. Silverman v. Anderson, 200 Colo. 76, 612 P.2d 94 (1980);
People v. Lanza, 200 Colo. 241, 613 P.2d 337 (1980);
People v. Meldahl, 200 Colo. 332, 615 P.2d 29 (1980);
People v. Davis, 620 P.2d 725 (Colo. 1980);
People v. Dutton, 629 P.2d 103 (Colo. 1981);
People v. Moore, 681 P.2d 480 (Colo. 1984);
People v. Underhill, 683 P.2d 349 (Colo. 1984);
People v. Franco, 698 P.2d 230 (Colo. 1985);
People v. Blanck, 700 P.2d 560 (Colo. 1985);
People v. Turner, 746 P.2d 49 (Colo. 1987).
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