ETHICAL ISSUES

IN

MORTGAGE FORECLOSURES

Submitted* by:

Vincent O. Hanley, Esq.

Bond Schoeneck & King, PLLC

October 2016

*Riane F. Lafferty, an associate of Bond Schoeneck & King, PLLC assisted with the research
and drafting of these materials.

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 Ethical Issues in Mortgage Foreclosures
Table of Contents
I. Recent NYSBA Committee on Professional Ethics Opinions ................................................ 1
A. Opinion 924 – 5/21/2012 ................................................................................................... 1
B. Opinion 921 -- 4/26/2012 .................................................................................................. 1
C. Opinion 893 – 12/1/2011 ................................................................................................... 2
D. Opinion 927 -- 8/2/2012 .................................................................................................... 2
E. Opinion 1031 -- 8/1/2014................................................................................................... 2
II. Conflicts of Interest................................................................................................................. 3
A. Timing of Conflict Review .............................................................................................. 3
B. Waivers of Conflicts of Interest Must be Confirmed in Writing. .................................... 3
III. Mandatory Settlement Conferences ........................................................................................ 4
A. Current Statutory Requirements ...................................................................................... 4
B. Zombie Properties Bill (S08159) ..................................................................................... 4
C. The Good Faith Standard ................................................................................................. 5
1. What Constitutes Good Faith? ................................................................................ 5
a. The Uniform Rules ........................................................................................ 5
b. Judicial Guidance ........................................................................................... 5
c. Zombie Properties Bill (S08159). ................................................................... 7
2. Potential Ethical Violations .................................................................................... 7
3. Sanctions for Violations of Good Faith .................................................................. 8
a. Zombie Properties Bill (S08159) ................................................................... 8
b. Wells Fargo Bank, N.A. v. Ronci, 15 Misc.3d 531 (Sup. Ct. Kings Co.
November 9, 2015). ....................................................................................... 8
c. U.S. Bank Nat. Ass’n v. Sarmiento, 991 N.Y.S.2d 68 (2nd Dept. 2014). ...... 9
d. HSBC Bank USA, Nat. Ass’n v. McKenna, 37 Misc.3d 885 (Sup. Ct. Kings
Co. 2012)........................................................................................................ 9
e. One W. Bank, FSB v. Greenhut, 2012 N.Y. Misc. LEXIS 3052, 10-23
(2012) ............................................................................................................. 9
IV. Attorney Affirmation Requirement......................................................................................... 9
A. Basis for Enactment ......................................................................................................... 9
B. Effect of Enactment ....................................................................................................... 10
1. Initial Decrease in Filings ..................................................................................... 10
2. “Shadow Docket” & the Unified Court System Pilot Programs........................... 10
C. Certificate of Merit Bill (A005582A) ............................................................................ 11
1. Mandatory Attorney Affirmation .......................................................................... 12
2. Elimination of Shadow Docket ............................................................................. 13
3. Ohio Attorneys Combat a Similar Requirement ................................................... 13
a. Affirmation Requirements in Cuyahoga County and Franklin County ....... 13
b. Opinion Letter .............................................................................................. 13
c. Ohio Supreme Court Ruling ........................................................................ 14
V. Legal Services to Distressed Homeowners ........................................................................... 15

i 1262084.2 10/13/2016
 A. Zombie Properties Bill (S08159) ................................................................................... 15
B. RPL 265-a: Home Equity Theft Prevention Act ............................................................ 15
1. Background and Application ................................................................................ 15
2. Contract Requirements (RPL §265-a(4)) .............................................................. 16
3. Seller’s Right to Cancel and Right of Recession (RPL §265-a(5)) ...................... 17
4. Purchaser’s Limitations and Restrictions (RPL §265-a(7)) .................................. 18
5. Criminal Penalties (RPL §265-a(10)(a)) ............................................................... 19
C. RPL 265-b: Distressed Property Consulting Contract ................................................... 19
1. Application ............................................................................................................ 19
a. Who is a Distressed Homeowner ................................................................. 19
b. Who is a Property Consultant ...................................................................... 20
c. What are Consulting Services (RPL §265-b(1)(c)) ..................................... 20
2. Prohibitions on Distressed Property Consultants (RPL §265-b(2))..................... 21
3. Contract Requirements (RPL §265-b(3)(a)) ......................................................... 21
4. Ability to Cancel (RPL §265-b(3)(b)) .................................................................. 22
5. Penalties (RPL §265-b(4)) .................................................................................... 22
6. Advertisements (RPL §265-b(3-a)(a)) .................................................................. 22
D. Attorney Arrangements with “Foreclosure Consultants” .............................................. 23
1. August 2, 2012 N.Y. Committee on Professional Ethics Opinion........................ 24
2. Case Study: Cincinnati Bar Ass’n v. Mullaney, 119 Ohio St.3d 412 (2008) ........ 26
a. Facts ............................................................................................................. 26
b. Disciplinary Violations ................................................................................ 27
c. Sanctions ...................................................................................................... 28
VI. The Steven Baum, P.C. Firm ............................................................................................... 28
A. Background and Chronology of Events ......................................................................... 28
B. Lawsuits & Other Investigations ................................................................................... 30
C. Lessons from the Baum Firm’s Demise......................................................................... 31
VII. Forged/Faked Attorney Signatures ....................................................................................... 32
A. Statutory Requirements .................................................................................................. 32
1. Presence of an Attorney Signature ........................................................................ 32
2. Defects in Form..................................................................................................... 33
3. Sanctions ............................................................................................................... 33
B. Case Study ..................................................................................................................... 33
1. Civil Law Violations ............................................................................................. 33
2. Sanctions for Professional Misconduct ................................................................. 34
C. Cases Involving Faked Attorney Signatures in Foreclosure Filings .............................. 35
1. Stewart v. Bierman, 10-CV-2822, 2012 WL 1655716 (D. Md. May 8, 2012) ..... 35
a. Facts ............................................................................................................. 35
b. Holding ........................................................................................................ 35
c. Court of Appeals of Maryland Rule............................................................. 35
2. Loughren v. Bair, et al., GD-10-021437 ............................................................... 36
a. Facts ............................................................................................................. 36
b. Status of the Lawsuit .................................................................................... 37
c. Renaming ..................................................................................................... 37

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 existing law for each client, the attorneys failed to
seek the client’s lawful objectives.

c. Sanctions

 The court disciplined the three attorneys according to their

experience level and involvement. The inexperienced
associate received a public reprimand. The seasoned
practitioner received a one-year suspension. The seasoned
practitioner not admitted in Ohio received an injunction
prohibiting his pro hac vice practice in Ohio for two years.
He also received reciprocal discipline in Kentucky, the
state in which he was admitted to practice. See Ky. Bar
Ass’n v. Moeves, 297 S.W.3d 552 (Ky. 2009).

VI. The Steven Baum, P.C. Firm

A. Background and Chronology of Events

 Steven J. Baum, P.C. (the “Baum Firm”), a large foreclosure law firm that was
headquartered in Amherst, New York, attracted considerable media attention
in 2011 and ultimately closed its doors following investigations by the New
York State Attorney General’s and the U.S. Attorney General’s office related
to the firm’s foreclosure practice during the housing crisis, and allegations of
overcharging, filing false documents and representing parties on both sides of
a mortgage transaction. See Thom Weidlich and Karen Freifeld, ‘Twilight
Zone’ Foreclosure Law Firm Draws Fine, Suits in New York Courts,
Bloomberg News, Dec. 8, 2010 available at
http://www.bloomberg.com/news/2010-12-08/-twilight-zone-foreclosure-law-
firm-in-n-y-draws-fine-suits.html

 The Baum firm represented some of the largest lenders and servicers of
residential mortgage loans, and handled a significant share of the mortgage
foreclosure actions brought in New York State. Between 2007 and 2010
alone, the Baum Firm reportedly handled over 100,000 mortgage foreclosure
actions – representing plaintiffs in approximately 40% of the foreclosure
actions commenced in the state during that period. Andrew Keshner, Baum
Firm Reaches Settlement with Attorney General, New York Law Journal
March 22, 2012.

 In April of 2011, at a time when the attorneys general in all 50 states were
investigating banks, loan servicers, and law firms to determine whether papers
used to commence hundreds of thousands of mortgage foreclosure actions
nationwide were properly prepared, the office of New York State Attorney
General, Eric T. Schneiderman, issued subpoenas to the Baum Firm and a

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 related company and commenced investigations regarding the firm’s
foreclosure practices. The Attorney General’s office alleged that the Baum
Firm had repeatedly filed papers in foreclosure and bankruptcy proceedings
without taking appropriate steps to verify the accuracy of allegations or the
lender’s right to foreclose. The purpose of the investigation was to determine
whether the Baum Firm knowingly or recklessly filed misleading pleadings,
affidavits, and mortgage assignments in the state and federal courts.

 In October of 2011, the Baum Firm and Pillar Processing LLC agreed to pay
$2 million to resolve a separate investigation by the U.S. Attorney’s office for
the Southern District of New York regarding the firm’s foreclosure filings.
The settlement agreement, however, did not constitute a finding that the firm
engaged in any unlawful practice or wrongdoing.17

 On October 28, 2011, New York Times columnist, Joe Nocera, published an
article and photos he had received from a former Baum employee of a 2010
Baum Firm office Halloween party at which employees had reportedly
dressed as people whose homes had been foreclosed upon.18 The article did
not, however, indicate that the principals of the Baum Firm were involved in
or even aware of the theme of the party.

 Shortly after the Halloween party story was published, the Baum Firm was
blacklisted by both national mortgage servicing giants, Freddie Mac and
Fannie Mae.

 Due in large part to the decrease in foreclosure business, the Baum Firm,
which, at the time, employed 67 full and part-time employees in Amherst,
New York, and 22 full and part-time employees at its West Perry, New York
location, announced that it would be closing its doors in November 2011. Joe
Palazzolo, The Demise of Steven J. Baum PC: A Chronology, WSJ Law Blog,
Nov. 21, 2011 available at http://blogs.wsj.com/law/2011/11/21/the-demise-
of-steven-j-baum-pc-a-chronology/

 In March of 201219, New York State Attorney General, Eric T. Schneiderman,

issued a press release announcing that the Baum Firm had reached a
settlement agreement with the New York Attorney General’s office pursuant
to which the Baum Firm and Pillar Processing LLC (a separate document

17
See The Demise of Steven J. Baum PC: A Chronology, WSJ Law Blog, Nov. 21, 2011 available at
http://blogs.wsj.com/law/2011/11/21/the-demise-of-steven-j-baum-pc-a-chronology/
18
See Joe Nocera, What the Costumes Reveal, New York Times (October 28, 2011)
(http://www.nytimes.com/2011/10/29/opinion/what-the-costumes-reveal.html?_r=2)
19
See Press Release, NYS Attorney General’s Office , March 22, 2012 ( http://www.ag.ny.gov)

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 processing company that was used by the Baum Firm for processing
foreclosure documents) would be jointly responsible for paying a $4 million
fine, and Steven J. Baum and Baum Firm attorney Brian Kumiega each agreed
not to handle foreclosure cases for lenders or servicers for two years. While
the Baum Firm did not admit wrongdoing as part of the settlement, the
Attorney General’s office, in its press release, indicated that its investigation
found that the Baum Firm: (1) routinely brought foreclosure proceedings
without taking appropriate steps to verify the accuracy of the allegations or the
plaintiff’s right to foreclose; (2) repeatedly verified foreclosure complaints
stating that the plaintiff was the “owner and holder of the note and mortgage
being foreclosed” when, in many securitized loans, the Baum Firm did not
have documentary proof that the plaintiff was the owner and holder of the
note and mortgage; (3) foreclosure complaints were prepared in an assembly-
line fashion by non-attorney Pillar Processing LLC employees with
inadequate attorney supervision; (4) attorneys routinely signed complaint
verifications stating that they had read the complaints and knew the contents
thereof without reviewing the complaints or the underlying documents; (5) in
some cases Baum Firm attorneys had pre-signed and notarized verification
and certification pages that were subsequently attached to the complaints and
filed with the foreclosure papers; (6) even after the practice of attaching pre-
signed and notarized verification and certification pages was discontinued,
attorneys in the firm continued to verify complaints without reading them; (7)
until sometime in 2011, Baum Firm attorneys routinely signed documents
without being in the notaries’ presence; (8) the Baum Firm repeatedly failed to
timely file Requests for Judicial Intervention (“RJIs”) and Attorney
Affirmations attesting to the accuracy of the foreclosure summons and
complaint; and (9) failure to timely file the RJIs and Attorney Affirmations
delayed the triggering of mandatory settlement conferences, denying
homeowners the benefit of potential loan modification options.20

B. Lawsuits & Other Investigations

 The Baum Firm was also accused in a federal court in Central Islip on Long
Island of charging homeowners illegally for attending foreclosure-settlement
conferences (Menashe v. Steven J. Baum P.C., 10-cv-5155, U.S. District
Court, Eastern District of New York), was named in a civil suit in federal
court in Brooklyn accusing the firm of racketeering by forcing false
foreclosures (Campbell v. Baum, 10-cv-3800, U.S. District Court, Eastern
District of New York (Brooklyn)), and in Nassau County District Court, Judge
Scott Fairgrieve, fined the Baum Firm $5,000 related to papers which
contained numerous falsities. (Fed. Home Loan Mortg. Corp. v. Raia, 918
N.Y.S.2d 397 (Dist. Ct. 2010))

20
See Baum Firm Reaches Settlement With Attorney General, New York Law Journal, March 22, 2012.

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  In addition to the numerous lawsuits, the Committee on Oversight and
Government Reform of the United States House of Representatives initiated
an investigation in February of 2011 into the allegations of abuse by
foreclosure attorneys and law firms. On November 4, 2011 Elijah Cummings,
Ranking Member of the Committee sent a letter to Steven Baum requesting
copies of all documents, records, court filings or pleadings, communications,
reports and audits relating to false or misleading documents and to attempts by
the firm to foreclose on borrowers attempting to obtain loan modifications.
The letter referred to the October 6, 2011 settlement between the Baum Firm
and the U.S. Attorney General’s Office for the Southern District of New York,
quoted at length from the October 28, 2011 New York Times article regarding
the Halloween party, and stated that the allegations (contained in the New
York Times article), if true, demonstrate a culture of distain for families
suffering from foreclosure and a disregard for the rule of law.

C. Lessons from the Baum Firm’s Demise

 Many local attorneys who had interacted with the Baum Firm for years were
taken aback by the intensity of the investigations of the firm because the
principals and staff attorneys of the Baum Firm are generally held in high
regard within the legal community. On the other hand, similar investigations
were being undertaken across the nation following the subprime mortgage
market disaster, the decline in housing values, and near collapse of global
financial markets.

 In its defense, the Baum Firm asserted that it made “inadvertent errors in its
legal filings in state and federal court, which it attributes to human error in
light of the high volume of mortgage defaults and foreclosures throughout the
State of New York in the wake of the national subprime mortgage crisis”.21

 Lessons can be taken from the findings of the New York State Attorney
General that were announced in connection with the March 2012 settlement,
including:

o Take appropriate steps to verify the accuracy of the allegations of

foreclosure (and other) pleadings;

21
See November 4, 2011 letter from Elijah Cummings, Ranking Member of the Committee on Oversight and
Government Reform, to Steven J. Baum, citing the Press Release - U.S. Attorney’s Office, Southern District of New
York, October 6, 2011 (www.appellate-brief.com/images/stories/PDF/10-6-11USATTYPR.pdf)

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 o Before commencing a foreclosure, obtain documentation from
your client showing that your client is the owner and holder of the
mortgage and underlying note;

o Properly supervise any nonlawyer employees who assist in the

preparation of papers;

o Do not verify pleadings or sign any certifications without actually

reading the papers and any attachments;

o Be sure that any notarized documents are actually signed in the

presence of the Notary Public;

o Proceed with foreclosure actions diligently and without any

unnecessary delay so as not to prejudice the rights of other parties;
and

o Finally, as a matter of professionalism, we need to ensure that the

culture of our firm or law office includes respect for opposing
parties.

VII. Forged/Faked Attorney Signatures

A. Statutory Requirements

1. Presence of an Attorney Signature

 22 NYCRR 130-1.1a (a) requires that an attorney sign all

documents prepared by that attorney, which are served on another
party or submitted to the court. The attorney’s signature is
intended to certify that the presentation of the papers or the
contents are not frivolous22.

22
For purposes of this 22 NYCRR 130.1, conduct is frivolous if:

(1) it is completely without merit in law and cannot be supported by a reasonable argument for an extension,
modification or reversal of existing law;

(2) it is undertaken primarily to delay or prolong the resolution of the litigation, or to harass or maliciously injure
another; or

(3) it asserts material factual statements that are false.

Frivolous conduct shall include the making of a frivolous motion for costs or sanctions under this section. In
determining whether the conduct undertaken was frivolous, the court shall consider, among other issues the
circumstances under which the conduct took place, including the time available for investigating the legal or factual

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  CPLR 2106 authorizes an attorney to sign his or her own statement
and to affirm its truth without a notary. Therefore, an officer of the
court has an ongoing professional duty to state the truth in papers
filed with the court. See MZ Dental P.C. v. Progressive
Northeastern Ins. Co., 6 Misc.3d 649, 653 (2004).

2. Defects in Form

 CPLR 2101 governs the form of legal papers in civil practice, and
requires that leave to correct be freely given. “A defect in the form
of a paper, if a substantial right of a party is not prejudiced, shall
be disregarded by the court.” Furthermore, the party upon whom
the paper is served is deemed to have waived objection to the
defect in form, unless within two days after receiving it, it is
returned to the party serving it with a statement of particular
objections.

3. Sanctions

 22 NYCRR 130-1.1 allows the court to impose financial sanctions

upon any attorney who engages in frivolous conduct. The signing
requirement is contained in the sanctions rule to stress the
individual responsibility of the lawyer to make a reasonable effort
to ascertain the truth or accuracy of the content of the paper signed.
Siegel, NY Prac. §414A, at 710 (4th ed).

B. Case Study

1. Civil Law Violations

 In MZ Dental P.C. v. Progressive Northeastern Ins. Co., 6 Misc.3d

649 (2004) the court found that two attorneys engaged in deceptive
practices and frivolous conduct, by failing to sign the summons
and complaint and affirmations submitted to the court. As the
attorneys had full knowledge of the false signatures on the
summons and complaint, but never made an effort to correct them
the complaint was dismissed without prejudice. The court found
that the false signatures were part of deceptive practices and
imposed a sanction of $5,000 per case, for a total of $35,000.

basis of the conduct, and whether or not the conduct was continued when its lack of legal or factual basis was
apparent, should have been apparent, or was brought to the attention of counsel or the party. 22 NYCRR 130.1-1b .

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  Based on the above violations, the law firm was required to attend
a status conference as the attorneys had admitted that papers filed
in excess of 11,000 actions contained attorney signatures which
were not in fact their signatures. The attorneys used a computer
program to record and view documents, which were printed out at
a later time. One of the attorneys believed that because he had
already viewed the material on the computer screen, he could
delegate the signing of his name. In order to deal with the large
workload the attorneys took shortcuts and delegated authority to
sign papers to others. It became part of the firm’s regular practice
to have someone else sign the attorneys’ names.

 Although the court found that the attorneys abdicated their

responsibilities, the court found that the conduct was the result of
an overwhelming workload, not an improper attempt to deceive the
court. Here, because the attorney made an effort to correct, the
court treated the submission of papers with false signatures the
same as if they were submitted without a signature. Therefore,
rather than dismiss the cases, the court required the attorneys to
submit sworn statements ratifying the signature. The firm was also
fined $40,000 for using false signatures. See In re Edward Shapiro,
P.C., 9 Misc.3d 369 (2003)

2. Sanctions for Professional Misconduct

 The two attorneys involved in the above cases were suspended for
six months for professional misconduct. See In re Shapiro, 55
A.D.3d 291 (2d Dept. 2008); In re Moroff, 55 A.D.3d 200 (2d
Dept. 2008). By submitting documents to the court which did not
bear their true signatures, the two attorneys were charged with the
following ethical violations:

o Rule 8.4(c): engaging in dishonesty, fraud, deceit or

misrepresentation (formerly a violations of DR 1-102(a)(4));

o Rule 8.4(h): engaging in conduct that adversely reflects on the

fitness to practice law (formerly a violation of DR 1-
102(a)(7));

o Rule 8.4(d) engaging in conduct prejudicial to the

administration of justice (formerly a violation of DR 1-
102(a)(5));

o Rule 5.1: engaging in conduct that failed to ensure that all

lawyers in the firm conformed to the disciplinary rule and for

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 failing to adequately supervise an associate (formerly a
violation of DR 104(a)(b) and (c));

C. Cases Involving Faked Attorney Signatures in Foreclosure Filings

1. Stewart v. Bierman, RWT 10CV2822, 2012 WL 1655716 (D. Md. May 8,

2012)

a. Facts

 Bierman, Geesing, Ward and Wood, LLP was charged with

participating in fraudulent “robo-signings” to initiate
foreclosure proceedings. Attorneys instructed firm
employees to sign for them and instructed firm notaries to
certify those documents as having been signed by them.
When the notaries were too busy, the firm began requiring
clerical employees to forge notary signatures. Forged
signatures were submitted with court documents and also
on trustees’ deeds of foreclosure.

 The lawsuit against the firm was brought by homeowners

alleging violations of the federal Fair Debt Collection
Practices Act (the “FDCPA”), along with state violations of
the Maryland Consumer Protection Act and the Maryland
Consumer Debt Collection Act for submitting false
signatures to expedite the foreclosure process. No
allegations were made that the existence of the secured debt
or delinquency was factually inaccurate.

b. Holding

 The court dismissed all actions against the defendants even

though the foreclosure practices did not comply with the
signature requirements because there were no material
violations. The method of applying signatures to an
otherwise substantially correct legal foreclosure document
is immaterial. Furthermore, the plaintiffs in this action were
still living in their home with no foreclosure actions
pending.

c. Court of Appeals of Maryland Rule

 The Rules Committee of the Court of Appeals responded to

this practice by enacting emergency rules, which allow
courts to screen for falsified affidavits and order parties to
show cause why those affidavits should not be stricken and

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 cases relying on them dismissed. If the courts have reason
to believe that an affidavit may be invalid, they may enter
an order directing the affiant, and where applicable, the
notary, to appear before the court and establish that the
affidavit is genuine. Steve Lash, Maryland Court of
Appeals Adopts New Foreclosure Rules, The Daily Record,
Oct. 19, 2010 available at
http://thedailyrecord.com/2010/10/19/maryland-court-of-
appeals-adopts-new-foreclosure-rule/

 Soon after the filing of the emergency rule, Judge W.

Michael Pierson appointed Elizabeth Ritter, as special
master, to review a sampling of files from firms believed to
have signature irregularities.

o Thomas Dore, of Covahey Boozer Devan and Dore,

was one of the first attorneys questioned by Judge
Pierson and Ritter. Dore conceded that five pending
foreclosure proceedings should be dismissed
because he could not vouch for his signature. He
admitted that other individuals would sign his name,
and the firm’s notaries would certify that Dore’s
signature appeared on the document, even though
they did not witness him signing it.

 Eighteen of the current and former notaries

employed by the firm were called to testify,
but invoked their Fifth Amendment right
and were subsequently excused by the judge
without any charges against them. Steve
Lash, Notaries Invoke Fifth Amendment in
Foreclosure Hearings, The Daily Record,
Jan. 25, 2011 available at
http://thedailyrecord.com/2011/01/25/notari
es-invoke-fifth-amendment-in-foreclosure-
hearings/

2. Loughren v. Bair, et al., GD-10-021437

a. Facts

 Goldbeck, McCafferty & McKeever, a law firm that

represents lenders in residential foreclosure disputes, was
sued for allegedly using paralegals instead of lawyers to
sign legal papers related to foreclosures. The Complaint

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 accuses the law firm of engaging in fraud in mortgage
foreclosures and of participating in the unauthorized
practice of law.23 The equity suit was filed by Patrick
Loughren, a Pennsylvania attorney, against the firm and
thirty-three non-lawyer employees. Jeff Blumenthal,
Goldbeck McCafferty law firm sued, Philadelphia Business
Journal Dec. 3, 2010 available at
http://www.bizjournals.com/philadelphia/blogs/law/2010/1
2/goldbeck-mccafferty-law-firm-sued.html?page=all

 Three of the firm’s partners have admitted that the firm

authorized its administrative staff to sign attorneys’ names
and file court documents in hearings or depositions in other
cases. See Kimberley A. Robinson v. Countrywide Home
Loans, Inc. et al., No 08-cv-01563 (W. Dist. Pa. 2010);
DeAngelis v. Countrywide Home Loans, Inc., 2012 Bankr.
LEXIS 3313 (Bankr. WD Pa. 2010).

b. Status of the Lawsuit

 The case is currently before Judge Christine A. Ward in

Allegheny County Court. The case not yet been decided,
but preliminary motions have been ruled on. The latest
updates are available at:
https://dcr.alleghenycounty.us/CaseDetails. Case No: GD-
10-021437

c. Renaming

 In an effort to rebrand itself after the filing of the lawsuit,

Goldbeck, McCafferty & McKeever has changed its name
to the KML Law Group. Jeff Blumenthal, Facing Legal
Issues, Goldbeck McCafferty becomes KML, Philadelphia
Business Journal, Sept. 30, 2011 available at
http://www.bizjournals.com/philadelphia/print-
edition/2011/09/30/facing-legal-issues-
goldbeck.html?page=all

23
The 78 page Complaint is available at
https://dcr.alleghenycounty.us/DisplayImage.asp?gPDFOH=vol911%20%20%20%20%20%20%20%20%20%20%2
0%20%20%20000002D8&CaseID=GD%2D10%2D021437&DocketType=COMPL&SeqNumber=2

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