Can an Ohio lawyer practice in more than one law firm at the same time?
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This page answers the general question as of 2013. Ezel answers yours: whether it's allowed on your facts, under the current Ohio Rules of Professional Conduct, with citations.
Plain-English summary
The Board reconsidered its 1989 position in Advisory Opinion 89-35, which had concluded that a lawyer may not practice with more than one legal professional association or law firm in Ohio at the same time, a result based largely on a former version of Gov. Bar R. III(3)(D) and on concerns that multiple-firm practice could mislead the public, risk disclosure of confidential information, increase conflicts, and threaten professional independence. The Board revisited the question under the current Rules of Professional Conduct and the current Rules for the Government of the Bar.
The Board concluded that a lawyer may practice in more than one firm simultaneously if the practice otherwise complies with the Rules. It identified the ethical issues such practice creates and how the current rules address them: the lawyer must be diligent in avoiding conflicts of interest, and conflict imputation under Rule 1.10 applies across all of the associated "firms," so the lawyer's conflicts in one association are treated as shared by the others.
The Board further concluded that the lawyer must scrupulously maintain client confidentiality and professional independence, and that, as part of the duty to refrain from false, misleading, or nonverifiable communications about the lawyer or the lawyer's services, the lawyer must inform clients of all multiple-firm associations. The Board withdrew Advisory Opinion 89-35 and withdrew Advisory Opinions 97-2 and 99-7 in part.
In practice
The opinion holds that, under the Ohio Rules of Professional Conduct as they stood at the time of the opinion, simultaneous practice in more than one firm is permitted when the practice otherwise complies with the rules. Per the opinion, the practitioner must guard against conflicts of interest with the understanding that imputation under Rule 1.10 reaches across every associated firm, must protect client confidences and professional independence, and must disclose all multiple-firm associations to clients so that communications about the lawyer's services are not misleading. The opinion withdrew Opinion 89-35 in full and Opinions 97-2 and 99-7 in part.
Common questions
Q: Can an Ohio lawyer be a member of two firms at once?
A: The opinion concluded yes, a lawyer may practice in more than one firm at the same time if the practice otherwise complies with the Rules of Professional Conduct.
Q: How do conflicts work across the firms?
A: The opinion concluded that the lawyer must be diligent in avoiding conflicts and that imputation under Rule 1.10 applies across all of the associated firms.
Q: Does the lawyer have to tell clients about the multiple-firm arrangement?
A: The opinion concluded yes; as part of the duty against false, misleading, or nonverifiable communications, the lawyer must inform clients of all multiple-firm associations.
Q: Did this change Ohio's earlier position?
A: The opinion concluded yes; it withdrew Advisory Opinion 89-35, which had barred simultaneous multiple-firm practice, and withdrew Advisory Opinions 97-2 and 99-7 in part.
Background and rules framework
The opinion interprets the Rules for the Government of the Bar of Ohio (Gov. Bar R. III) together with Ohio Prof. Cond. R. 1.0, 1.4, 1.6, 1.7, 1.8, 1.9, 1.10, 1.18, 2.1, 5.4, and 7.1 (Model Rules including 1.6, 1.7, 1.9, 1.10, 5.4, 7.1). It centers on conflict imputation across associated firms (Rule 1.10), confidentiality (Rule 1.6), professional independence (Rule 5.4), and truthful communication about the lawyer's services (Rule 7.1).
Citations and references
Rules of Professional Conduct:
- Ohio Prof. Cond. R. 1.7, 1.9, 1.10 (conflicts and imputation) (Model Rules 1.7, 1.9, 1.10)
- Ohio Prof. Cond. R. 1.6 (confidentiality); R. 5.4 (professional independence) (Model Rules 1.6, 5.4)
- Ohio Prof. Cond. R. 1.4 (communication); R. 7.1 (false, misleading, or nonverifiable communications) (Model Rules 1.4, 7.1)
- Gov. Bar R. III (organization of law practice)
Other opinions cited:
- Ohio BPC Op. 89-35 (1989) (withdrawn by this opinion): bar on simultaneous multiple-firm practice
- Ohio BPC Ops. 97-2 and 99-7 (withdrawn in part by this opinion)
See also
Source
- Landing page: https://ohioadvop.org/advisory-opinion-index/
- Original PDF: https://www.ohioadvop.org/wp-content/uploads/2017/04/Op_13-001.pdf
Original opinion text
Reproduced from the official source for research purposes. The linked source is authoritative.
BOARD OF COMMISSIONERS ON GRIEVANCES & DISCIPLINE
65 SOUTH FRONT STREET, 5TH FLOOR, COLUMBUS, OH 43215-3431
Telephone: 614.387.9370
RICHARD A. DOVE Fax: 614.387.9379 MICHELLE A. HALL
SECRETARY www.supremecourt.ohio.gov SENIOR COUNSEL
OPINION 2013-1
Issued April 4, 2013
Simultaneous Practice in Multiple Firms
SYLLABUS: A lawyer may practice in more than one firm at the same time if the
practice otherwise complies with the Rules of Professional Conduct. A lawyer
who engages in simultaneous practice in multiple firms must recognize the
potential ethical issues connected with such practice. The lawyer has to be
diligent in avoiding conflicts of interest, and imputation of conflicts will apply
across all associated ‚firms.‛ The lawyer is also required to scrupulously
maintain client confidentiality and professional independence. As part of the
lawyer’s duty to refrain from false, misleading, or nonverifiable communications
about the lawyer or the lawyer’s services, the lawyer must inform his or her
clients of all multiple firm associations.
Advisory Opinion 89-35 is withdrawn, and Advisory Opinions 97-2 and 99-7 are
withdrawn in part.
QUESTION PRESENTED: May a lawyer practice simultaneously in more than
one firm?
APPLICABLE RULES: Rule III of the Rules for the Government of the Bar of
Ohio and Rules 1.0, 1.4, 1.6, 1.7, 1.8, 1.9, 1.10, 1.18, 2.1, 5.4, and 7.1 of the Ohio
Rules of Professional Conduct
OPINION:
The Board’s Position on Practice in Multiple Firms under the Former Code
An Ohio lawyer has asked for the Board’s current view on simultaneous
practice in multiple firms. The Board first addressed this issue in Advisory
Op. 2013-1 2
Opinion 89-35. The syllabus of that opinion states that a lawyer ‚may not
practice with more than one legal professional association or law firm in Ohio at
the same time.‛ Ohio Sup. Ct., Bd. of Comm’rs on Grievances and Discipline,
Op. 89-35 (Dec. 15, 1989). The Board’s conclusion was based primarily on
Gov.Bar R. III(3)(D), which then indicated that ‚*n+o attorney shall be associated
in any capacity with a legal professional association other than the one with
which the attorney is actively and publicly associated.‛ In Opinion 89-35, the
Board also identified several potential ethical issues with practice in multiple
firms. The Board concluded that practice in more than one firm could be
misleading and confusing to the public, create the possible disclosure of
confidential lawyer-client information, increase the number of conflicts of
interest, and threaten the lawyer’s professional independence. At the time of
Opinion 89-35, the former Code of Professional Responsibility (Code) defined a
‚law firm‛ as including ‚a professional legal association or a legal clinic.‛ Code,
Definitions, at (2) (amended effective June 11, 1979). Given this definition of
‚law firm,‛ it appears that the Board’s position in 1989 was that a lawyer could
not engage in part-time practice in both a traditional law firm and a legal clinic.
In Colaluca v. Climaco, Climaco, Seminatore, Lefkowitz & Garofoli Co., L.P.A.,
72 Ohio St.3d 229, 648 N.E.2d 1341 (1995), the Supreme Court of Ohio (Court)
interpreted the Gov.Bar R. III language relied upon by the Board in Advisory
Opinion 89-35. Colaluca was an action brought by a lawyer against his former
law firm to compel redemption of the share the lawyer held in the firm. The
lawyer argued that Gov.Bar R. III(3)(D) required redemption of the share because
otherwise the lawyer could not practice in another firm. The Court held that ‚the
intent of Gov.Bar R. III(3)(D) is to prohibit an attorney from practicing with more
than one firm, including a legal professional association, in Ohio at the same
time.‛ Id. at 233, 648 N.E.2d at 1344. Because the lawyer was practicing in a new
firm and was no longer associated with the former firm, the Court determined
that the lawyer was not in violation of Gov.Bar R. III and the former firm was not
required to redeem the lawyer’s share.
Colaluca was decided on May 24, 1995. On September 26, 1995, the Court
adopted amendments to Gov.Bar R. III, effective November 1, 1995. The impetus
for the 1995 amendments was legislation in 1994 that permitted lawyers and
other professionals to form limited liability companies, corporations, and
partnerships. See Proposed Amendments to Rules for the Government of the Bar
of Ohio, 72 Ohio St.3d xxix-xxxiii (1995). As a result of the Court’s 1995
amendments, the language of Gov.Bar R. III that banned practice in multiple
Op. 2013-1 3
legal professional associations was eliminated. The replacement language was
virtually identical to the current version of Gov.Bar R. III(3)(D), which states, ‚*a+
legal professional association, corporation, legal clinic, limited liability company,
or limited liability partnership in which an attorney is an officer, director, agent,
employee, manager, member, partner, or equity holder shall be considered the
attorney’s firm for purposes of the Ohio Rules of Professional Conduct and these
rules.‛ See Amendments to the Rules for the Government of the Bar of Ohio, 74
Ohio St.3d CXXVI-CXXVIII (1995).
In 1997, the Board considered a question related to practice in multiple
firms, that is, whether a retired lawyer may be ‚of counsel‛ to two different law
firms. The Board concluded that a retired lawyer was permitted to be ‚of
counsel‛ to more than one firm, but made clear that it was ‚not contradicting,
overruling, or withdrawing the advice in Opinion 89-35 that ‘*a+n attorney at law
may not practice with more than one legal professional association or law firm in
Ohio at the same time.’‛ Ohio Sup. Ct., Bd. of Comm’rs on Grievances and
Discipline, Op. 97-2 (April 11, 1997), at 2. At that time, the Board deemed ‚of
counsel‛ relationships as ‚unique and distinct from that of partner or associate
relationships‛ in explaining the Board’s continued adherence to the advice
provided in Advisory Opinion 89-35. Id.
Four years after the Court’s rewrite of Gov.Bar R. III, the Board again
addressed simultaneous practice in multiple firms. In Advisory Opinion 99-7,
the Board was asked to determine whether a lawyer not admitted in Ohio could
be a member, partner, or other equity holder in both an out-of-state firm and an
Ohio firm. See Ohio Sup. Ct., Bd. of Comm’rs on Grievances and Discipline, Op.
99-7 (Dec. 2, 1999). The Board declined to answer this specific question, but
reaffirmed its view that a lawyer should not practice in more than one law firm.
Id. at 4-5. Although the Board recognized that the Court had repealed the former
Gov.Bar R. III(3)(D) language, the Board concluded that the potential ethical
issues mentioned in Opinion 89-35 still justified a prohibition on practice in
multiple firms. As further support for its stance against practice in multiple
firms, the Board noted that in 1992 the Court chose not to adopt an amendment
to Gov.Bar R. III that would have explicitly allowed practice in multiple firms.
Id. This rule proposal predated the 1994 legislation on professional associations
and the Court’s complete rewrite of Gov.Bar R. III in 1995, however.
Op. 2013-1 4
The Board’s View on Multiple “Of Counsel” Relationships under the Current Rules
The Court repealed the Code and adopted the Rules of Professional
Conduct (Rules) effective February 1, 2007. The Board has not revisited the
question of simultaneous practice in multiple firms since the adoption of the
Rules, although it provided additional guidance on ‚of counsel‛ relationships in
Advisory Opinion 2008-1. See Ohio Sup. Ct., Bd. of Comm’rs on Grievances and
Discipline, Op. 2008-1 (Feb. 8, 2008). In that opinion, the Board analyzed
whether the Rules permit a lawyer to serve as ‚of counsel‛ to more than one law
firm, and was unable to identify a Rule of Professional Conduct that prohibits
multiple ‚of counsel‛ relationships. The Board concluded that so long as a
lawyer maintains the requisite ‚continuing, close, regular, and personal
relationship with each firm‛ and avoids conflicts of interest, the lawyer may
serve as ‚of counsel‛ to more than one firm. Id. at 7. Opinion 2008-1 references
Opinion 97-2, in which the Board allowed multiple ‚of counsel‛ relationships
under the Code, but also disallowed practice in multiple firms. Nonetheless,
Opinion 2008-1 fails to take a position on practice in multiple firms under the
Rules.
The Approach in Other Jurisdictions
In Advisory Opinion 89-35, the Board cited a Maryland advisory opinion
as authority for its conclusion that practice in multiple firms raises too many
potential ethical issues for it to be permissible. Ohio Sup. Ct., Bd. of Comm’rs on
Grievances and Discipline, Op. 89-35 (Dec. 15, 1989) at 1, citing Md. State Bar
Assn. Commt. on Ethics, Op. 88-45 (Jan. 13, 1988). However, the American Bar
Association (ABA) and a number of other jurisdictions take the position that
practice in multiple firms is permissible if it can be accomplished without
violation of the applicable ethics rules. See ABA Comm. on Ethics and Prof’l
Responsibility, Informal Op. 1253 (‚the Code of Professional Responsibility does
not prohibit a lawyer from being associated with more than one law firm‛); ABA
Comm. on Ethics and Prof’l Responsibility, Informal Op. 83-1499 (‚a+ lawyer
may be a partner in two law firms in different states‛); D.C. Bar Op. 338 (Oct.
2006) (‚a lawyer may practice in more than one firm,‛ noting that ‚the prevailing
view among the various jurisdictions that have considered these issues is that a
lawyer is not prohibited from being a partner in more than one firm if the firms
are treated as one for imputation of conflicts‛); Fla. State Bar Assn., Commt. on
Prof’l Ethics, Op. 93-6 (May 15, 1994) (‚a+s a general rule, an attorney is not
ethically precluded from practicing simultaneously in two bona fide law firms‛);
Op. 2013-1 5
Ga. Sup. Ct., State Bar of Ga., Op. 97-2 (Feb. 13, 1997) (‚a+n attorney may
practice in more than one firm so long as those firms represent different
ownership, the public and individual clients are clearly informed, and each firm
adheres to all requirements<governing conflicts of interest and client
confidences and secrets‛); N.Y. State Bar Assn., Commt. on Prof’l. Ethics, Op. 944
(Nov. 8, 2012) (adopting Florida view that a lawyer is not ‚ethically precluded
from practicing simultaneously in two bona fide law firms‛); Phila. Bar Assn.,
Prof’l. Guidance Commt., Op. 2001-5 (April 2001) (‚there is nothing unethical in
the Rules per se about an attorney practicing as a partner or member in more
than one firm at the same time,‛ finding conclusion comparable to multiple ‚of
counsel‛ relationships); S.C. Bar, Ethics Adv. Commt., Op. 95-15 (July 1995) (‚i+t
is permissible for an attorney to practice as a sole practitioner in City A and
simultaneously practice law in a partnership in City B,‛ but the attorney must
ensure ‚that no conflicts of interest exist between the lawyer and the client‛). 1
The Board’s Current Position on Practice in Multiple Firms
Rarely does the Board advocate its position on a single issue in three
separate advisory opinions. That is the case here, as the Board disapproved of
simultaneous practice in multiple firms in Advisory Opinions 89-35, 97-2, and 99-
7. The Board carefully considers any reversal of course and generally defers to
its prior advice, but in this instance the Board finds substantial justification for a
new perspective on practice in multiple firms.
Reviewing the association with multiple firms in the context of current
rules and modern practice, the Board has identified at least six reasons for a
withdrawal of its long-standing position. First, in 1995 the Court repealed the
language of Gov.Bar R. III(3)(D) that prohibited a lawyer’s involvement with
multiple legal professional associations. The Board issued Advisory Opinions
97-2 and 99-7 after this rule amendment, but the former Gov.Bar R. III(3)(D)
language was the only outright prohibition against practice in multiple firms in
place at the time of the Board’s original opinion in 1989. The remainder of
Advisory Opinion 89-35 bases the Board’s ban on practice in multiple firms on
the potential problems that could result, not any absolute restriction contained in
the former Code.
1See also, Mason & Mesulam, Legal Polygamy: Ethical Considerations Attendant to Multiple Law Firm
Affiliations, 29 Law. Man. Prof. Conduct 75 (2013).
Op. 2013-1 6
Second, the Court adopted the Rules in 2007, and the Board has not
considered practice in multiple firms since that time. No Rule of Professional
Conduct or Rule for the Government of the Bar prohibits practice in multiple
firms, and the Board last addressed the issue 14 years ago.
Third, after the Court adopted the Rules, the Board issued Advisory
Opinion 2008-1, which allows lawyers to maintain multiple ‚of counsel‛
relationships with different firms. As stated in Opinion 2008-1, lawyers who are
‚of counsel‛ are considered members of the firm for purposes of conflicts and
division of fees. If lawyers may be members of multiple firms for ‚of counsel‛
purposes, it seems contradictory to prohibit actual membership or employment
with multiple firms. Opinion 2008-1 makes no mention of the Board’s prior
advice on practice in multiple firms.
Fourth, as demonstrated by the opinions from other jurisdictions cited
previously, the prevailing view is that practice in multiple firms is permissible if
it otherwise complies with the applicable rules of ethics. Fifth, the definition of
‚firm‛ and ‚law firm‛ in Prof.Cond.R. 1.0(c) is expansive:
(c) ‚Firm‛ or ‚law firm‛ denotes a lawyer or lawyers in a
law partnership, professional corporation, sole
proprietorship, or other association authorized to practice
law; or lawyers employed in a private or public legal aid or
public defender organization, a legal services organization,
or the legal department of a corporation or other
organization.
Under the Board’s former opinions on practice in multiple firms, a lawyer could
not work for a legal aid, public defender, or legal services organization while also
engaging in the private practice of law. This practice restriction contravenes a
lawyer’s responsibility to ‚seek improvement of the law, ensure access to the
legal system, *and+ advance the administration of justice.‛ Rules, Preamble, at ¶
[6].
Finally, on a related point, the financial reality of the current practice of
law, especially in small communities, is that lawyers may have to create full-time
employment through part-time positions in different practice environments. The
Board does not believe it is appropriate to impede a lawyer’s ability to generate
full-time work if it may be accomplished in compliance with the Rules. For all of
Op. 2013-1 7
these reasons, the Board withdraws Advisory Opinion 89-35 in full and Opinions
97-2 and 99-7 in part and concludes that lawyers may engage in simultaneous
practice in multiple firms, with ‚firm‛ defined as in Prof.Cond.R. 1.0(c).2
Ethical Issues for Lawyers Practicing in Multiple Firms
Notwithstanding its modern view of practice in multiple firms, the Board
still believes, as it stated in Opinions 89-35, 97-2, and 99-7, that there are
significant ethical issues for lawyers to consider if they practice in more than one
firm. The primary concern for these lawyers is dealing with conflicts of interest
as addressed in Prof.Cond.R. 1.7, 1.8, 1.9, and 1.10. A lawyer practicing in
multiple firms must conduct conflict checks that span all of the lawyer’s firms,
rather than confining the checks to individual firms. In addition, the conflicts of
a lawyer who practices in multiple firms will be imputed across all of the firms.
Under Prof.Cond.R. 1.10 conflicts of lawyers ‚associated in a firm‛ are imputed
to all of the lawyers in the ‚firm.‛ Accordingly, all of the firms in which a lawyer
practices will be treated as one firm for purposes of imputation, unless the
conflict may be ameliorated in compliance with Prof.Cond.R. 1.10. A lawyer
may not violate the duty of client loyalty by representing clients in an additional
firm that the lawyer is already prohibited from representing due to a conflict.
This conclusion is consistent with the Board’s position on imputation in ‚of
counsel‛ associations. See Ohio Sup. Ct., Bd. of Comm’rs on Grievances and
Discipline, Op. 2008-1 (Feb. 8, 2008).3 See also Phila. Bar Assn., Prof’l. Guidance
Commt., Op. 2001-5 (April 2001). The specific conflict situations described in
Prof.Cond.R. 1.8, such as business transactions with clients, the use of
information to the disadvantage of a client, the solicitation of gifts from clients,
and providing financial assistance to clients, will also be imputed to all of the
lawyers associated with the lawyer’s multiple firms. See Prof.Cond.R. 1.8(k).
Lawyers should further be aware of the conflicts involving prospective clients
that may arise under Prof.Cond.R. 1.18 and the potential for imputation. See
Prof.Cond.R. 1.18(c). Due to the complex conflict concerns for lawyers who
practice simultaneously in multiple firms, such lawyers must notify all of the
applicable firms of the lawyer’s other firm associations.
2 Government agencies are not ‚firms‛ for purposes of Prof.Cond.R. 1.0(c). See Prof.Cond.R. 1.0,
Comment [4A].
3 Advisory Opinion 2008-1 also addresses the division of fees when a lawyer is designated as ‚of
counsel.‛ Prof.Cond.R. 1.5(e) governs the division of fees between lawyers who are not in the
same firm.
Op. 2013-1 8
Additional considerations for lawyers who practice in multiple firms fall
into the general categories of confidentiality, communication, advertising,
professional independence, and fiduciary responsibilities. Prof.Cond.R. 1.6
states that in general ‚*a+ lawyer shall not reveal information relating to the
representation of a client,‛ and lawyers practicing in multiple firms have to take
scrupulous care to maintain client confidences across all associated firms.
Reading a lawyer’s duty to communicate under Prof.Cond.R. 1.4 with a lawyer’s
duty to refrain from false or misleading communications about the lawyer or his
or her services under Prof.Cond.R. 7.1, a lawyer must inform his or her clients of
all multiple practice associations. Both clients and prospective clients may
require this information to make informed decisions about the representation.
Prof.Cond.R. 2.1 obligates lawyers to exercise independent judgment, and
lawyers must be mindful of this responsibility when selecting multiple firms for
practice. A lawyer should decline any additional firm associations if the lawyer’s
obligations to any one of the firms would interfere with professional
independence and judgment. See also Prof.Cond.R. 5.4. Further, a lawyer’s
fiduciary responsibilities to a firm’s members may prevent association with
additional firms. See Phila. Bar Assn., Prof’l. Guidance Commt., Op. 2001-5
(April 2001), at 2; Mason & Mesulam, supra note 1, at 75. This issue falls outside
the Rules of Professional Conduct and the Board’s advisory authority, but the
Board recommends that lawyers carefully research any fiduciary issues before
embarking on practice in multiple firms.
CONCLUSION:
The Board no longer believes that a lawyer may not practice with more
than one firm in Ohio at the same time, and withdraws the Board’s previous
position on this issue as stated in Advisory Opinions 89-35, 97-2, and 99-7. The
Board has changed its view for the following reasons:
The Supreme Court repealed former Gov.Bar R. III(3)(D)’s prohibition
against multiple professional associations in 1995;
Neither the Rules for the Government of the Bar nor the Rules of
Professional Conduct currently prohibit simultaneous practice in multiple
firms;
In Opinion 2008-1, the Board sanctioned multiple ‚of counsel‛
relationships with multiple firms;
Op. 2013-1 9
The prevailing view from other jurisdictions is that practice in multiple
firms is permissible;
Due to the expansive definition of ‚firm‛ in Prof.Cond.R. 1.0(c), which
includes legal aid, public defender, and legal services organizations, a ban
on practice in multiple firms would prohibit a lawyer with a private
practice from also choosing to promote access to the legal system through
work in such organizations; and
For financial reasons, and especially in smaller communities, lawyers may
have to maintain more than one part-time position to create the equivalent
of full-time employment.
The Board’s current position is that a lawyer may practice in more than
one firm at the same time if the practice otherwise complies with the Rules of
Professional Conduct. For purposes of this Opinion, a ‚firm‛ is defined as stated
in Prof.Cond.R. 1.0(c).
A lawyer who engages in simultaneous practice in multiple firms must
recognize the potential ethical issues associated with such practice. The lawyer
has to be diligent in avoiding conflicts of interest, and imputation of conflicts will
apply across all ‚firms‛ of practice. Practice in more than one firm may not be
used to eschew the duty of client loyalty, and the lawyer is advised to notify all
firms of any multiple associations. Client confidences must be scrupulously
maintained in regard to all associated firms. As part of the lawyer’s duty to
refrain from false, misleading, or nonverifiable communications about the lawyer
or the lawyer’s services, the lawyer shall inform his or her clients of all multiple
firm associations. A lawyer should decline any additional firm associations if the
lawyer’s obligations to any one of the firms would interfere with professional
independence and judgment.
Advisory Opinions of the Board of Commissioners on Grievances and
Discipline are informal, nonbinding opinions in response to prospective or
hypothetical questions regarding the application of the Supreme Court Rules
for the Government of the Bar of Ohio, the Supreme Court Rules for the
Government of the Judiciary, the Ohio Rules of Professional Conduct, the
Ohio Code of Judicial Conduct, and the Attorney’s Oath of Office.
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