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Obligation to give file to prior client?

Charles C. Abut, Esq

Charles C. Abut, Esq02-10-2014 10:31 AM

  • 1.  Obligation to give file to prior client?

    Posted 02-10-2014 09:52 AM
    What is my obligation to give a copy of my file to a prior client?  A prior client of mine is asking for a copy of their divorce file.  The attorney has requested everything from the Divorce Complaint to both parties' CIS's to all correspondence.  I copy my client on all documentation (orders, correspondence, CIS, discovery, etc.), so the client should have everything.  What do I have to give the client's new attorney?

    The client's file is very large and it will take a few hours to go through and copy everything the attorney is requesting.  The prior client owes a significant amount of fees to my office, but I know that doesn't really matter in terms of providing a file.  

    Any help will be most appreciated,

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    Gregory Thomlison Esq.
    Toms River NJ
    (732)736-8100

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  • 2.  RE:Obligation to give file to prior client?

    Posted 02-10-2014 10:27 AM

    There are a few possibilities.

    You could ask new counsel to come to your office to identify what they actually want, which may tirn out to be less than originally requested.

    If they say no, then you can take the entire file to a copy shop for an estimate of reproducing it. Tell the other firm the estimated cost and that they have to pay (or your former client does) the copy shop directly -- or nothing gets copied.

    There are ethics opinions stating that you are entitled to keep your file (except for the client's original documents) and the client must pay reasonable copying costs.

    Hanan
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    Hanan Isaacs Esq.
    Kingston NJ
    (609)683-7400

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  • 3.  RE:Obligation to give file to prior client?

    Posted 02-10-2014 10:31 AM
    See :

    (a)

    115 N.J.L.J. 565
                                             May 16, 1985

    ADVISORY COMMITTEE ON PROFESSIONAL ETHICS

    Appointed by the New Jersey Supreme Court

    OPINION 554

    Retention of Client's File after Termination of Employment Relationship

     
    and

    (b)
     
    Superior Court of New Jersey,
    Appellate Division.
    Stephen FRENKEL, Plaintiff-Respondent,
    v.
    Michelle FRENKEL, Defendant,
    Landi & Kessler, Intervenor-Appellant.
    Argued Oct. 22, 1991.
    Decided Dec. 6, 1991.

    Matrimonial action was filed. Husband's attorney moved to be relieved as counsel for husband. Husband filed cross motion to compel former counsel to turn over original file or photocopy thereof to substitute counsel. The Superior Court, Chancery Division, Family Part, Monmouth County, ordered former counsel to turn over photocopy of file to substitute counsel. Former counsel appealed. The Superior Court, Appellate Division, Michels, P.J.A.D., held that former counsel was required to turn over photocopies of husband's file to substitute counsel despite existence of attorneys' lien for unpaid balance of the bill for legal services.   Affirmed. 

    Charles Abut Esq.
    Hackensack NJ
    (201)342-0404




  • 4.  RE:Obligation to give file to prior client?

    Posted 02-10-2014 10:38 AM
    Make life easy for yourself. It is not worth the stress and aggravation of having to defend your actions to an ethics investigator as a result of an ethics complaint filed against you for failure to turn over a file while a matter is still pending in the court system.
    For whatever it will cost you to recopy the file, it is worth it against standing on ceremony and sweating your actions later.
    Copy the whole file, send the fee arbitration letter to the client ( if not done so already), file an application with the court for the imposition of an appropriate lien on the file and move on with your day. 

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    Richard Diamond Esq.
    Millburn NJ
    (973)379-9292

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  • 5.  RE:Obligation to give file to prior client?

    Posted 02-10-2014 11:12 AM
    I respect Richard's approach. I will do what he suggests in a fairly young or inactive case involving a few dozen pages of stuff. Once a casefile is in bankboxes, though, forget it. Substituting firm can have total access and they can have complete copies. But it's not on my time and not on my dime.

    One other thought.

    If I know the substituting firm and trust them, I will agree to turn over files lock stock and barrel, with a signed agreement that if I need the original file back for Fee Arb, ethics issues, or "other" reasons, the substituting firm shall promptly turn over the original file to my office for as long as I need it.

    Hanan
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    Hanan Isaacs Esq.
    Kingston NJ
    (609)683-7400

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  • 6.  RE:Obligation to give file to prior client?

    Posted 02-10-2014 11:41 AM
    You indicate that your former client received a copy of the file in a contemporaneous manner, to wit, by copying the client with each letter, pleading and document that was generated.  I believe that we are not required to replace copies of letters, pleadings, documents, etc that were generated during our representation and supplied to the client as the documents were generated.  Once a copies have been initially provided a duplication of letters, pleadings, documents, etc must be paid for by the former client.  Obtaining an estimate from a copy center of the cost of re-duplication is the best avenue.  I would, however, agree with Richard if the file is a small one to just provide it and move on with the collection process.  That is not the case as you indicate the file is very large.

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    Ralph Tawil Esq.
    West Long Branch NJ
    (732)229-4848

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  • 7.  RE:Obligation to give file to prior client?

    Posted 02-10-2014 11:47 AM


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    Larry Raiken Esq.
    Montville NJ
    (973) 808-2003

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  • 8.  RE:Obligation to give file to prior client?

    Posted 02-10-2014 12:08 PM

    I very much appreciated Mr. Diamond's response.  I didn't know that I could motion the court for the lien order.  But I disagree with the gentleman that says if you contemporaneously provided the client with copies of everything then you can dawdle until paid.

    My understanding of the rules are that, when requested, you must quickly provide a copy of the file to your client.  This is so regardless of contemporaneously copying him.

    You have to give him a bill for the cost of copying.  Or deliver the bill to the new attorney.

    I would  hope the new attorney would pay for at least that from whatever retainer he received.  But too often, our brethren, are inconsiderate of the preceding counsel and just ignore that copying bill also.

    You reap what you sow.  So for piece of mind copy the file, forward it or arrange for it to be picked up; and file your lien.  

    Clients are very quick to file ethics complaint and/or post nasty things about their attorneys on the internet.  So just man up and send him the file.

    Best wishes.
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    Marianne Auriemma Esq.
    Maywood NJ
    (201)712-9663

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  • 9.  RE:Obligation to give file to prior client?

    Posted 02-10-2014 12:57 PM
    I also agree with Mr. Diamond. It's not worth the aggravation.  But, there's also nothing from preventing you from providing an electronic copy. You can scan all the documents to a disc, and provide it.  

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    Stephanie Hunnell Esq.
    Belmar NJ
    (732)749-3500

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  • 10.  RE:Obligation to give file to prior client?

    Posted 02-10-2014 05:26 PM
    Thanks for all of the replies on-list and off.  I really appreciate the insight; it was very helpful!

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    Gregory Thomlison Esq.
    Toms River NJ
    (732)736-8100

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  • 11.  RE:Obligation to give file to prior client?

    Posted 02-12-2014 06:58 AM
    Greg,

    Check RPC 1.6d. I've seen lawyers ask the requesting attorney to c


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    Rachel Cotrino Esq.
    Jackson NJ
    (732)987-9966

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  • 12.  RE:Obligation to give file to prior client?

    Posted 02-12-2014 07:02 AM

    Sorry, my prior message was cut off. As I was saying, I've seen lawyers ask the requesting attorney to come to their office to go through the file to determine what they actually need, this is particularly helpful in cases where the file is many many boxes. I've also seen attorneys charge a fee to reproduce the file. The key is to ensure that your fee is reasonable. I would recommend that if you have further questions about this specific issue that you contact Carol Johnston of the office of Atty. ethics. I once had an issue involving your question and she was very helpful to me.

    Good luck!
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    Rachel Cotrino Esq.
    Jackson NJ
    (732)987-9966

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  • 13.  RE:Obligation to give file to prior client?

    Posted 02-11-2014 09:10 AM
    I agree with Ms. Hunnell. Since we scan everything in every case, if someone requests their file, we simply dump the entire file onto a CD and send it away. It takes less than 10 minutes of secretarial time. This way, there is no issue with the cost of reproduction; the substituting attorney can print up everything at his/her client's own expense. 

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    John Nachlinger Esq.
    Howell NJ
    (732)414-6669

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