Chapter 2
Unauthorized Practice of Law
Power Point Presentation: Warning! There are over 80 slides for UPL. They are meant to be
broken down into three topics. Even so, 25 – 30 slides is too many for an hour lecture. You will
have to pick and choose.
Chapter Assessment: Once again, I ask you to create your chapter assessment now instead of
waiting until the end of the chapter. It is easier to be sure to teach something than it is to
Chapter Hypothetical: This fact pattern has happened to several people in your class. Open
your class discussion by finding out who they are and how they dealt with the situation. Then, at
Video Alert: You may have used this video in Chapter 1. If you did not, read on —–
The first segment in the video series (#1 UPL Issue: When Friends Ask for Legal Advice).
Dante’s friend has a problem with his lease. Can Dante help his friend and never cross the UPL
line? I think so. My conservative friend, Tom Goldman, author of The Paralegal Professional,
If you can keep your own analysis to yourself, it may be worthwhile to show this one video clip
at the end of this chapter to see if your students have changed their opinions.
Lesson Objective: What is UPL? (pg. 38)
Lecture Suggestion: Teach a clear, succinct, practical definition: the application of a rule of
law to a particular person’s fact pattern and giving a response or answer. This definition will
A copy of your state’s UPL statute, although the “Finding the Law in Your State” section comes
later. If your students cannot find the statute, refer them to paralegalethics.net. They should find
You might want to discuss the idea that immigrants are often cheated by their own people who
are pretending to be immigration legal practitioners. There are many good articles (newspapers,
the State Department) and do a search for “immigration, scams, abuse” and you will get their
Lesson Objective: Why should the practice of law be limited to lawyers? (pg. 39)
Lecture Suggestion: Find out how your students feel about the lawyer-monopoly question. Do
lawyers insist on their strangle-hold on the practice of law out of concern for the public? Or out
of self-interest? How do they feel about the 85% of America that cannot afford legal help? Do
they have any ideas for solving the problem?
Challenge Assignment: Your students can also find this case on paralegalethics.net in the
Chapter 2 Extra Resources section.
Check Your Understanding (pg. 40) 1. b; 2. b
Lesson Objective: Finding the law in your state (pg. 40)
Lecture Suggestion: Be sure to find both the UPL statute AND the statute that sets forth the
penalty. Additionally, there might be some topic-specific UPL rules in your state. They could be
lurking in your Probate or Real Property codes. There should be a law that says that lawyers
Lesson Objective: What does history say about UPL? (pg 41)
Lecture Suggestion: This is where UPL may start to get a little foggy for your students because
we’re entering the realm of court–driven definitions of UPL…always a murky place. In State
Bar of Arizona v. Arizona Land Title (cited in the text at endnote 4) 90 Ariz. 76, 366 P.2d 1, the
state UPL committee took on several title companies to try to get them to stop preparing
documents that affect title to real property…something that title companies typically do. The
court delivers a lengthy dissertation on “The Legal Profession” citing Roscoe Pound’s book, The
Lawyer from Antiquity to Modern Times circa 1953. Pound (and the court) trace the origins of our
lawyers to the Roman orators in the 6th Century B.C.E! In the second section, the Court says the
practiced by lawyers. UPL, then, would be someone other than a lawyer doing those tasks. Not
very helpful, but an excellent lesson in the history of UPL.
Baron v. City of Los Angeles, 2 Cal.3d 535, 469 P.2d 353 (1970) (footnote 6) is an old California
case answering the question: Is a lawyer always a lawyer or is he not a lawyer when he is a
lobbyist? Ultimately, the court held that the lawyer had to register as a lobbyist for the times
Lesson Objective: What do the modern rules say about UPL? (pg. 41)
Lecture Suggestion: Your state’s Rule 5.5 is pretty clear about the part where a lawyer should
not practice law in a jurisdiction where he or she is not licensed. (Tell this to the Birbower law
firm!) But the part about helping someone else (who is not a lawyer) practice law, is not so
clear. Your state may not have adopted the Comments that the ABA wrote to accompany the
Model Rules. However, Comment #3 to that rule includes this curious sentence that is a good
one for class discussion: “Lawyers also may assist independent nonlawyers, such as
This is an excellent place to discuss the philosophical differences between NALA and NFPA.
NALA, the more conservative organization, defines a paralegal or legal assistant as someone
Are any of your students members of NALA or NFPA? This would be a good place to find out
why each joined which organization.
Lesson Objective: What is it exactly that non-lawyers cannot do? (pg. 43)
Lecture Suggestion: Explain the four categories of UPL. The first three are listed and
misrepresentation is the fourth category of UPL (although it may not look like it at first).
Video Alert: Video segment #9 (UPL: Helping the Client Fill Out Forms) shows Alicia
apparently doing some freelance work for a client of her law firm. This is so that you can engage
your students in a conversation about filling out forms being UPL. Interesting side question:
Alicia appears to be working for Mr. H on the side (not as part of her work for the law firm). But
she is doing the work in the law firm offices. Does that make the law firm liable for her mistakes
or malpractice?
Check Your Understanding; 1. TTF; 2. b
Lesson Objective: What activities look like UPL but aren’t? (pg. 44)
Lecture Suggestion: Many people think that the right of self-representation is granted in the
Bill of Rights. It is not. The Bill of Rights grants us the right to a jury trial in criminal matters
represent ourselves, it does not fit into our definition that requires giving legal advice to another
person. Can you show them how to find this Code on their own?
Speaking of self-representation, the U.S. Supreme Court has ruled that parents have a right to
represent their children in matters of accommodation against school districts. Why isn’t this
Guest Speaker Suggestion: It would be nice if you could find someone to spend some time
talking with your students about practicing law before administrative agencies. I know several
Challenge Assignment: (pg. 45) “Any person entitled to appear in a hearing may appear in
person or by a representative in any proceeding or hearing and may be heard with respect to
matters relevant to the issues under consideration. A representative must either be an employee
of the person or an attorney at law who is a member of the bar, in good standing, of any State,
Lesson Objective: The “incidental to” Rule (pg. 45)
Lecture Suggestion: The “incidental to” rule is one of those blurry lines that is made more clear
by examples from real life so use as many examples as you can from your experience.
Video Alert: Video Segment #3 (UPL: Traditional Exceptions) shows a person getting tax
advice from someone who appears to be some sort of non-lawyer. What we’re trying to illustrate
Lesson Objective: What’s definitely not UPL because there’s no “giving legal advice?” (pg.
46)
Lecture Suggestion: The “conduit theory” is one of those places where the paralegal’s duties
can be stretched so it’s fun to talk about. How would your state feel about a paralegal who was
giving clients very specific legal advice pursuant to a firm manual setting out answers to
commonly asked questions? How would lawyers you know react to the statement in the text:
“Here’s what I think the answer (to your legal advice question) but I’ll check with a lawyer and
call you back if this answer isn’t correct.”
Video Alert: Video segment #2 (UPL: Helping the Client without Practicing Law) shows
Paralegal Michael trying to help a distraught client. This is a good time to explain that it is this
sort of situation where we often cross the UPL line. We want to be helpful, as Michael is when
Lesson Objective: What about secretarial and typing services? (pg. 47)
Lecture/Activity Suggestions: Are there actual typing services anymore? Does anyone “type”
for other people now? How is your state dealing with We the People shops? Here’s a case from
Ohio and a DocUPrep company. Ohio State Bar Assn. v. Cohen, 107 Ohio St.3d 98, 836 N.E.2d 1219
(2005). The court issued an injunction against Cohen doing any further business. This is a 2 page case that you can have your
students read in class. Find it on the paralegalethics.net or Google the case name and it will pop right up for you in pdf format.
Challenge Assignment: (pg. 47) LegalZoom was outlawed in Missouri in 2011. There is a copy of the court’s order in Chapter 2
Extra Resources on paralegalethics.net. The North Carolina State Bar concluded that it was a UPL-er in 2008. Webster v.
LegalZoom reached a settlement in April 2012 requiring LZ in California to make changes to its advertising (alleged deceptive) and
to comply with the Legal Document Assistant Act. This Judgment is in Chapter 2 Extra Resources on paralegalethics.net.
Washington entered into an agreement with LZ to discontinue certain activities in that state in October 2010. This Consent Decree
is in Chapter 2 Extra Resources on paralegalethics.net.
Lesson Objective: Are kits and books UPL? (pg. 48)
Lecture Suggestion: What do your students think of this concept? How can a book be UPL?
Our definition of UPL is: take the facts of a particular case, apply the law, and give an answer.
Books don’t do that. They are not interactive.
What do your students think about the expression “Legal Information Is Not Legal
Advice”?
Lesson Objective: Corporations and UPL? (pg. 49)
Lecture Suggestion: In the spirit of keeping the cost to the consumer at a reasonable place, it
seems logical to make an exception to the requirement of a lawyer in small-claims courts, for the
cost factor and for the sake of keeping lawyers out of small claims court. Claims for consumer
rent collection or getting your security deposit back should not be cluttered with lawyers.
However, how can the legislature differentiate between the mom and pop apartment complex
(Cleveland Bar v. Pearlman at the end of the chapter) and the huge corporation property
manager?
There are many other interesting questions in this section. In the 1980s (and any time the
economy gets bad) it became common practice to staff corporate legal departments with
paralegals to cut back on the cost of lawyers. The paralegal’s job was to coordinate outside legal
counsel with the needs of the company, not to practice law on the company’s behalf. But what
happens when the corporation (via an employee) has a question and asks the paralegal for an
answer. When that paralegal researches the answer and presents it to the corporation, isn’t that
really self-representation? This is a complex question so it’s best to demonstrate it by
contrasting a paralegal answering a question when the paralegal is not employed by the
Lesson Objective: Is just asking the court for a continuance UPL? (pg. 49)
Video Alert: In the video series, there is a segment on the paralegal “making an appearance” in
court to get a document signed (#24 Zealous Representation: Candor to the Court). The segment
is about being truthful with the court, but it also illustrates that tricky place where the paralegal
ventures into the other side of the gate.
Check Your Understanding: (pg. 50) 1. b and c; 2. a , b and d; 3. b, c and d
Lesson Objective: What’s so bad about UPL anyway? (pg. 50)
Lecture Suggestion: What are some public policy reasons for keeping the practice of law
restricted to licensed lawyers? Are those public policy reasons important enough to balance out
the lack of access to legal assistance?
Challenge Assignment: (pg. 50) Can a paralegal supervise a real estate closing in your state?
There are some bar opinions on this issue in the Extra Resources section at paralegalethics.net. It
was pretty easy to find the answer by doing a simple internet search (can a paralegal supervise a
real estate closing in yourstate) Alabama: (Ala. Code § 34-3-6(c)); Delaware: In re Mid-Atlantic
Settlement Servs., 755 A.2d 389 (Del. 2000)); Georgia: (In re UPL Advisory Opinion 2003-2,
Lesson Objective: How do lawyers help others commit UPL? (pg. 51)
Video Alert: Video Segment #8 (UPL: Improper Supervision) shows Paralegal Michael trying
Lesson Objective: How is Improper Supervision UPL? (pg. 52)
Lecture Suggestions: This is a good place to discuss the similarities and differences of
paralegals and disbarred lawyers. When I wrote the first edition of this book (1984) there
weren’t any cases about paralegals so all I had to go on were cases about disbarred lawyers.
Some states allow their disbarred lawyers to act as paralegals or law clerks (North Dakota is an
What is the position of your state bar? Clearly, a disbarred lawyer who continues to
practice law commits UPL. In In re Schelly we learn that the supervising lawyer will be held
accountable for that UPL, too.
In the reverse of Hu v. Fang, in Matter of Martinez we see the bad acts of the paralegal
imputed to the lawyer under the doctrine of respondeat superior expanded not just to protect the
injured party but for disciplinary purposes, as well.
I use the facts from Matter of Martinez 107 N.M 171, 754 P.2d 842 (1988) (in the last
paragraph of this section – pg. 52) to illustrate the improper supervision of a paralegal because it
has some interesting twists, including the tenuous relationship between Martinez (the lawyer)
and Felix, the paralegal. They did not share offices; the court says Felix was employed by
If you’re in Ohio, here are two cases of paralegal UPL from both angles. Columbus Bar
Assn. v. Watson, 106 Ohio St.3d 298, 834 N.E.2d 809 (2006) and Columbus Bar Assn. v.
Thomas, 109 OhioSt.3d 89, 846 N.E.2d 31 (2006). (Both available to you on line.) What
Lesson Objective: Improper Delegation is UPL (pg. 52)
Lecture Suggestion: Improper delegation extends to tasks that are ethical, but simply
inappropriate for that particular employee. The lawyer who delegates an appellate brief to a
Video Alert: Video Segment #7 (UPL Issue: Working with Experts) shows Lawyer Saunders
delegating taking a deposition to Paralegal Alicia.
Activity Suggestion: How about a game of “Just Deal With It”? Questions are on the next
page.
Lesson Objective: Improper business relationship (pg. 53)
Lecture Suggestion: What are some examples of attempts to replace the lawyer’s professional
judgment with lay judgment? Is just making a suggestion okay? How about arguing for that
suggestion? Really trying to convince the lawyer? So if a lawyer and a paralegal go into
Lesson Objective: Improper Division of Fees as UPL (pg. 53)
Lecture Suggestion: Does your state allow fee splitting arrangements when one of the lawyers
does nothing other than refer the case? Please let me know if this is allowed in your state
because, to my knowledge, California is the only state that permits fee splitting.
Recently I had a lawyer say to me that an annual bonus (like a Christmas bonus) is illegal
Just Deal With It examples:
#1: A client of the firm asks you out on a date – for dinner – to discuss his case.
#2: You get a text message from your supervisor “Need legal rate of interest. Text me back.”
#3: Your best friend calls and says my landlord won’t let me have a cat in my apartment but my
neighbor has one. Can you help me?
#5: You’re sitting quietly in your office when you hear one of the attorneys run into a
neighboring office, slam the door and start yelling at your neighbor. The yelling eventually stops,
the door slams as the attorney exits, and now you hear your neighbor crying.
#6: You are interviewing a client about burglary charges filed against him. Apropos of his
recount of his dealings with the police, he tells you that he killed his wife seven years ago and
buried her body in his backyard.
#8: Your boss hands you a stack of papers. They have names, date of birth, social security
numbers, and case type on the first page. Your boss drops the stack on your desk and says: these
need to be organized.
#9: A person in the lunch room makes a racially insensitive comment.
Lesson Objective: Multidisciplinary Practice splitting fees (pg. 54)
Lecture Suggestion: This entire section may be too detail-y for your students, but it makes for
an interesting class discussion. If our job is to make legal assistance cost effective, isn’t the
addition of on-staff accountants aid in that endeavor?
Check Your Understanding: (pg. 54) 1. d (although c is close); 2. b
Lesson Objective: How is misrepresentation UPL? (pg. 55)
Video Alert: UPL: Interviewing a Client shows the attorney introducing himself and then his
paralegal without identifying her as a non-lawyer. Later in the video, Alicia re-introduces herself
and explains that she is a paralegal. Allowing Alicia to continue the interview by herself is not
UPL so long as she is asking questions. Telling the client he has a good case is UPL. But what
could Alicia have said instead? Give your students some time to think about it and then ask them
to role play an interview.
Video Alert: UPL: Working with a Witness shows Paralegal Dante failing to identify himself to
a store owner, the witness to an auto accident. Dante tells the fellow to show up at a certain
seems to be Dante’s misrepresentation. What kind of card could Dante have handed Mr.
Witness? His own business card would surely have identified him as a paralegal. The other
UPL issue in this video is covered above. (Dante tells the witness that the client has a good case
against the other driver.) Dante appears to be offering this witness a bribe, as well. That’s a
“zeal question” suitable for discussing in Chapter 8.
Lecture Suggestion: States have different philosophies on how hard the paralegal and law firm
have to work to make it clear to the public that the paralegal is not a lawyer. Some of our more
conservative states take a hard line on what business cards must say or whether you can list your
paralegals on firm letterhead. Your state probably has a bar opinion that sets forth your rule so
now would be a good time to go look for that. There’s one place where all states should agree
but they do not and that is door signs. A paralegal’s door sign should say “paralegal” and a
This is the place where you want to emphasize that paralegals who graduate from a
certificate program are certificated paralegals, not certified paralegals. Use of the expression
“Certified Legal Assistant” will land you in trouble with NALA as it has a trademark on that
designation.
Lesson Objective: How Are UPL laws enforced? (pg. 56)
See Fogarty v. Parker, Poe, Adams and Bernstein, L.L.P., 961 So.2d 784 (Ala. 2006) for a case on the private
cause of action for UPL. The Parker, Poe law firm is a North Carolina law firm that took up the representation of an Alabama
company. When Mr. and Mrs. Fogarty wanted to look at the records of that Alabama company (they were shareholders who
You can find this case on www.plol.org (a free public law library) by searching the name of the case.
Lesson Objective: What are the penalties? (pg. 57)
Activity Suggestion: Hopefully, your students found the penalty statute back on page 40 of the text, but if they haven’t, now is
the time.
Answers to End of Chapter 2 Review Questions
Critical Thinking
1. In Re Gaftick is a New York “We the People” case. The Federal Law provides for
bankruptcy petition preparers. 11 USCA 110, but that law does not permit a BPP to
“give legal advice” or to collect a fee. At WTP, the client is given a “workbook” to
complete. The information provided by the client in the workbook is then typed into the
workbook answers regarding exemptions. The court found that the activities of WTP
constituted UPL. Now, can we relate that to Hamed helping his friend Antonio with a
workbook and software for a living will? If we use our UPL definition (“the application
2. Green v. UPL Committee of Texas
Here’s Texas’ UPL statute:
[T]he preparation of a pleading or other document incident to an action or
special proceeding or the management of the action or proceeding on
behalf of a client before a judge in court as well as a service rendered out
of court, including the giving of advice or the rendering of any service
Green got a power of attorney from each client. He claimed he acted as a “go–between”
for people in their auto accident negotiations with insurance companies. He assessed
people’s damages, however, and wrote demand letters to insurance companies. He
accepted offers with permission from his clients, but they obviously relied on his
3. The facts of Brown v. Grimes are set forth in the question. Basic contract law dictates
that when one party fails to perform a contractual obligation, the other party is relieved
from his duty to perform. The trial court decided that Brown’s refusal to pay the
investigator was a material breach that relieved Grimes of further obligation to him and
4. LegalZoom has lawyers on staff in some states now, too. Their E&O insurance must be
astronomical! But does it make a difference? Only if, in fact, those lawyers are either
5. Indiana State Bar v. United Financial Systems Corp. You can find the whole case in pdf
format in the Extra Resources section of paralegalethics.net. It’s 17 pages. The court
categorized UFSC as an “insurance marketing agency” targeting retirees. The court
6. Paralegal Sarah cannot be supervised by Attorney Franco because he is not competent to
supervise her. Therefore, she is practicing law without a license when she conducts the
Assignments
2. This may be a time-consuming assignment. You could limit it by asking for just 2 or 3.
3. Erin Brockovich also lies to people to get access to documents and uses her obvious
4. This is another research project that can reinforce office memorandum writing.
Collaborative Assignments
1. Keep track of these and send them to me, too! ☺
Review Questions
Application Questions
1. Depending upon how the letter is phrased, either a paralegal or a lawyer can sign a letter
that contains legal advice. More conservative firms only allow lawyers to sign these
letters. It only takes a few minutes to review a letter and sign it, so why not have this
rule?
2. You would hate to have your friend do something that harms himself and then blame you
3. Elements are: 1. the application of the law; 2. to a particular person’s fact pattern; and 3.
4. Lawyers are licensed and subject to discipline; lawyers are educated in the law; the public
will likely be harmed by a nonlawyer practicing law and have no legal recourse.
5. Answers will vary but hopefully your students will see that some questions are really
more like statements and are made for the purpose of educating, not querying.
6. You do not want to appear to be making promises to clients by saying “You have a great
8. There are many tasks that a lawyer could ask a paralegal to do that would be UPL from
taking a deposition (the subject of one of the videos) to a court appearance, to signing a
complaint or discovery responses. What should you do when asked to do such a thing?
9. Paralegals often get business cards from their employing law firms that do not properly
10. The answers to these questions are state law oriented so answers will vary.
Notes about Cases for Consideration
Case #1: South Carolina v. Despain (pg. 60)
Ms. Despain operated a business known as Professional Document Services. She helped people with their divorce, child custody,
Here is South Carolina’s definition:
The generally understood definition of the practice of law “embraces the preparation of
pleadings, and other papers incident to actions and special proceedings, and the
management of such actions and proceedings on behalf of clients before judges and
courts.”
But the court adds: “we now hold that the preparation of legal documents for others to present in
family court constitutes the practice of law when such preparation involves the giving of advice,
consultation, explanation, or recommendations on matters of law. Further, instructing other
individuals in the manner in which to prepare and execute such documents is also the practice of
Questions About Case #1
1. What is a declaratory action? What does it mean to enjoin? What is an injunction?
2. What is the court’s definition of the unauthorized practice of law?
3. What activities did the defendant engage in that were arguably UPL?
4. What is the court’s reason for not allowing the defendant to have her computer generated
legal forms business?
5. After reading this case, can you answer the hypothetical posed at the beginning of this
chapter?
Case #2: Cleveland Bar Assn. v. Pearlman (pg. 61)
Mr. Pearlman is an apartment house manager. He owns 99% of the business. His wife owns the other 1%. He brings small claims
actions in municipal court against tenants or former tenants. He has never told anyone he is a lawyer. Magistrates know he’s not a
lawyer. They let him make his arguments and give testimony, but not examine witnesses.
Here’s Ohio’s law:
“The unauthorized practice of law is the rendering of legal services for another by
any person not admitted to practice in Ohio . . . .” The term “rendering of legal
services” has been defined further: “The practice of law is not limited to the
Their rationale:
…limiting the practice of law to licensed attorneys is generally necessary to protect the
public against incompetence, divided loyalties, and other attendant evils that are often
associated with unskilled representation.
Questions About Case #2
1. According to the court, what is the unauthorized practice of law?
2. What are Roosevelt and Boulevard and what was Pearlman’s association with them?
3. What was Pearlman doing that the Cleveland Bar Association argued constituted the
unauthorized practice of law.
4. This court has held that there are some exceptions to the UPL law. What are they?
5. Corporations can’t practice law by themselves. They need to have a person represent
them. What things can a lay person do on behalf of a corporation according to this
Ohio court?
6. Ultimately, what does this court decide?
Cases #3 and #4: Furman I (pg. 65) and II (pg. 67)
I had to give you the Furman cases because she was the pioneer in UPL. Notice the dates we’re
dealing with here: 1978-1984 before the age of computer generated pleadings. Furman sold do-
it-yourself divorce kits, much like bookstores do today. She prepared legal pleadings for people
to use in representing themselves in family court and she charged a reasonable fee. She claimed
Furman made an excellent point: many of her customers were people who could not afford to get
help anyplace else. As part of the judgment in this case, then, the court directs the Florida Bar to
begin a study to find better ways of providing legal services to the indigent. (Surely a study will
help them.) And the court issued an injunction.
Questions About Cases #3 and #4
1. Why was Rosemary Furman tried again?
2. Who is the “watch dog” in this case?
3. Furman argued that the court’s earlier order was “vague.” What do you see in the
order that is vague?
4. Furman wants to re-argue whether her actions constitute the unauthorized practice of
law. Why does the court say it will not allow that argument?
5. The court said: “Of the sixteen alleged instances of unauthorized practices of law,
four were nolle prossed by the Bar.” What does nolle prossed mean?
6. What were the consequences for Rosemary Furman?
In the News (pg. 70)
Questions
2. Answer: This is “failure to supervise” UPL. Ivan was working in immigration law but
3. Answer: Placeres had only two choices: 1) personally supervise the nonlawyer, or 2) hire
4. Answer: If we use the ABA standards (pg 14 of the text), he should be suspended
Video Case Studies
UPL: Helping Clients without Practicing Law
Answer: The purpose of this video is to demonstrate what a paralegal can do when
speaking with a client, and where the UPL line may be in your state. Michael begins by asking
UPL: Traditional Exceptions
Answer: The purpose of this video is to point out that there are many places where legal
UPL Interviewing a Client
Answer: The purpose of this video is to demonstrate how lawyers quite innocently
misrepresent the status of a paralegal and how the paralegal can, without making the lawyer feel
UPL: Working with a Witness
Answer: The purpose of this video is to demonstrate that witnesses, like clients, don’t
read, don’t remember, and have more respect for people in a suit than they ought to. Mr. Norton
accepts Dante’s card (which Dante had every reason to believe was a good enough explanation
UPL: Working with Experts
Answer: Alicia commits UPL when she asks the witness questions under oath. There is
UPL: Improper Supervision
Answer: Poor Michael. I really love this kid. He tries so hard to do the right thing. And
don’t you just love that he figures out the right thing to do at the end? This is a good time to talk
UPL: Helping the Client Fill Out Forms
Answer: The sub-issue here is whether it is appropriate for Alicia to do any freelance
work inside the law office. Isn’t that too confusing for the client? Filling out the form with
factual information such as Hutchinson’s name, address, etc. is not UPL but answering the
