[PROFESSIONAL] oye a ae re Office of Professional Conduct Sewing the Public by Regolating Attorneys and Licensed Paralegal Pacitionss {645 South 200 East, Suite 205 « Salt Lake City, Utah 88111-3894 ‘elephone: (801) 591-9170 + FAX: B01) 531-0012 E-mai: epe@opcutah.org June 14, 2019 Steven C. Boos Maynes Bradford Shipps & Sheftel LLP 835 E 2nd Ave, Ste 123 Durango, CO 81301 Re: Information Submitted by Kelly Pehrson OPC File No.: 19-0445 Dear Mr. Boos: This is to notify you that the Office of Professional Conduct (‘OPC’) has received information from Kelly Pehrson. A copy of the information is enclosed. We recognize that having our office involved in matters such as this can be inconvenient and unsettling. For this reason, the OPC strives to determine the appropriate course of action as quickly as possible. Although the information received does not constitute a complaint pursuant to Rule 14-510(a) of the Rules of Lawyer Discipline and Disability (‘RLDD"), the OPC has the duty to screen all information coming to its attention that may relate to misconduct of an attomey pursuant to Rule 14-504(b)(1) of the RLDD. In accordance with this duty, the OPC will review the information submitted and take one of the following actions: 1) Refer the information to the Utah State Bar's Consumer Assistance Program; 2) Refer the information to the Professionalism Counseling Board; 3) Return the information to the person with a request to resubmit it consistent with rule 14-510(a) as an informal complaint; 4) Open an OPC informal complaint; or 5) Decline to prosecute the matter. The OPC's course of action in these matters is generally based on our review of the materials provided by the complaining party as well as the attomey’s response to the allegations. This letter is to inform you that we have received the information, and any informationPage 2 of 3 you provide our office will assist in our initial review and may lead to a quicker resolution of this matter. If the OPC refers the matter to the Consumer Assistance Program, it can be addressed informally by the Consumer Assistance attorney, Jeannine Timothy. In that case, Ms. Timothy will contact you with respect to her efforts at resolution of the problem between you and the person who submitted the information. Please respond immediately if you are contacted by Ms. Timothy because if this problem is resolved by the Consumer Assistance Program, there will be no record of an official complaint against you based on this information If you have questions about the disciplinary process and your rights and obligations with respect to it please contact Jeannine Timothy, who also serves in the Disciplinary Process Information Office. You can reach Ms. Timothy in that office at 801-257-5516. Ms. Timothy can provide general information about attorney discipline and can refer you to the appropriate procedural rules in order to guide you through this process, Ms. Timothy cannot, however, give legal advice and because she is not part of the Office of Professional Conduct her opinions are not binding on this office. For more information about the process, and the rules governing the OPC, you may visit the Bar's website at www.utahbar.org/opc!. YOUR DESIGNATED ADDRESS As part of the licensing process, attorneys are required to provide the Utah State Bar (‘the Bar’) with a current business and home address, and to designate an address as their “Preferred Address.” During the course of its investigation, the OPC will keep you notified as the matter progresses. Unless you contact our office in writing and request that a different address be used, we will send correspondence to the “Preferred Address" as designated on your licensing forms. Keep in mind that providing an alternate address to our office does NOT change your preferred address with the Bar. If you wish to change your preferred address with the Bar for purposes other than the current OPC matter, you will need to contact the Bar's licensing department. Also keep in mind that, just like your preferred address with the Bar, any alternate address you provide to our office will be information that may be disclosed to complainants, or other necessary individuals, during the course of the OPC’s investigation.Page 3 of 3 Also note that if correspondence from our office is retumed as undeliverable, or if our requests for information are ignored by you, correspondence may be sent to your home address. Finally, if you are willing to accept future correspondence and notices from the OPC electronically at the email address on record with the Bar, you may notify us in writing or by email at opc@opcutah.org. Sincerel Emily A. Lee Assistant Disciplinary Counsel Office of Professional Conduct EALmb EnclosureStephanie Frias WordPress Thursday, June 13, 2019 8:00 AM OPCStaff; OPCStaff6877@utahbar.org New submission from CAP Request Form First Name Kelly Last Name Pehrson Your Street Address: 365 Silverstone Lane Your City: Monticello Your State Utah Your Zip Code: 84535 ‘ Your Daytime Telephone Number: 435-459-0587 Your Email address: khpehrson@gmail.com Name of the Attorney About Whom you Have a Problem Steven Boos The Lawyer's Firm Name and Address:Maynes, Bradford, Ships & Sheftel, LLP (MBSS) The Lawyer's Firm City, State, & Zip Code: West Building 836 East Second Avenue, Suite 123, Durango, CO 63101 Have you talked with the lawyer named about the subject of this request? NO. Tell us the problem you are having . Please give a detailed statement of facts, including dates and places, explaining why you are requesting assistance with regard to this lawyer: | have been the San Juan County Administrator for the last 8 years and | witnessed how awful Mr. Boos is. He represented the Navajo Nation vs. San Juan County in the redistricting case and this case is under appeal at the federal court. Currently Mr. 800s is owed roughly $3 million dollars from San Juan County in potential legal fees, which is under appeal. Mr. Boos now claims he represents two of San Juan County's current Native Commissioners personally and he is representing them pro bono. State law is very clear that all County business has to be ran through the elected County attorney, Kendall Laws. Mr. Boos has clearly admitted that he has been the author of Resolutions that have been passed by the two Commissioners, | attached the letter. also acted as the appeal officer for GRAMA requests for the County. The County has received many GRAMA requests about who authored these resolutions and also text messages that Mr. Boos has texted during Commission meetings to help the Commissioners answer questions. Mr. Boos wrote a very vindictive letter to me and to our Clerk trying to bully us on how to answer these GRAMA requests. | have attached that letter as well. | hope you can see the major conflict of interest and the frustration. How can say he is acting as their personal attorney and do County business? | also have a email he sent me giving me a draft of the policies and procedures for the County that | can send you ifneeded. Again this is an attorney that has actively sued the. county for many years and now claims he represents two of the current commissioners, Have you contacted the Utah State Bar about this lawyer before? No Under what circumstances have you contacted the Utah State Bar about this lawyer before? NIA Upload Files (8mb Max Size) Boos-Letters.pdf=- MBSS - Aaa MAYNES, BRADFORD, SHIPPS & SIIEFTEL LLP once wig. sinus taba ons) ase (SNES shoos@nbasp.com March 12, 2019 Kenneth Maryboy Willie Grayeyes San Juan County, Utah Re: GRAMA requests and attomey/ctient privilege Dear Commissioners Maryboy and Grayeyes: T understand that San Juan County has received several requests pursuant to the Utah Government Records Access and Management Act (GRAMA), UCA §63G-2-101, e/ seq., secking to leam how recent County Commission resolutions you submitted were drafted. | also understand you will soon be meeting with Kendall Laws, the County Attomey, to discuss this issue. I am sending this letter, which you may share with the County Atlomey at your discretion, to assist you with that meeting. As you know, we have had a long professional relationship. You were both delegates on the Navajo Nation Council during the period from 1995 through 2001 when I had the honor to serve as the Chief Legislative Counsel of the Navajo Nation. I helped you, as the Council's head attomey, with drafting legistative resolutions, navigating the legislative process and general issues of governance. | think itis fair to say that we came to respect and trust one another in our roles of legislators and attorney. In the last six months, you asked me to take up that role once again and serve as your attomey providing advice and help with drafting San Juan County Commission resolutions, navigating, the legislative process and advising on general issues of govemnance in San Juan County. Because of our long history over the last 24 years (and even longer if you include my time at DNA-Peoples' Legal Services in Halchita, Utah from 1983 through 1991), I agreed to reestablish our attomney/client relationship. This has been on a voluntary, unpaid basis (to the chagrin of my law partners) ‘After discussing issues with the two of you and understanding your goals, I was the principal author of the resolutions, including the resolutions conceming the Bears Ears National ‘Monument, that are the subject of the GRAMA requests. There is nothing wrong or prohibitedMarch 12, 2019 Page 2 about your use of an outside attorney to assist you. It is common for legislators to have the help of attorneys in drafting legislation and navigating legislative processes. ‘There are also good and sufficient reasons why you would not trust advice from Mr. Laws and would seek separate legal counsel. First, as the Utah Supreme Court has made abundantly clear, the County Attomey represents the County, not the individual Commissioners. Salt Lake County Commission v. Salt Lake County Attorney, 985 P.2d 899 (1999). But pethaps more importantly, Mr. Laws has a history that is a fertile source of doubt about his advice: he tried to persuade the Davis County Attomey, Troy Rawlings, to bring a baseless criminal proceeding against Commissioner Grayeyes; there is an open question about his role, if any, in the creation and dissemination of a fraudulent public document concerning Commissioner Grayeyes; he has not yet, to my knowledge, complied with clear and lawful directives of his client to withdraw the ‘County from the Bears Bars litigation; and his father, Kelly Laws, brought an election contest suit against Mr. Grayeyes that remains pending and which includes a fees claim against his father for $271,271. Taken together, these facts and circumstances raise a very reasonable need for you to secure outside legal counsel. ‘And this brings us back to the GRAMA requests. Attomey/client communications are exempt from disclosure under GRAMA. UCA §63G-2-305(17). You have no duty to share the substance of our conversations or any written communications we have had concerning these resolutions. If you share this letter with Mr. Laws, it will become a County record subject to GRAMA Sisclosure and perhaps the County Records Officer can then send it to the GRAMA requestors to satisfy their curiosity about how the resolutions were written, Sincerely, “ORD, SHIPPS & SHEFTEL, LLP Dura Ofte sobnow MB S S ar OOH ES Sennen eer ANDREW HARE > a = mens scout bwioeenme pace sacereL RED sate Ye) aS 984280) shoos@mbsalip.com April 4, 2019 John David Nielson, San Juan County Cletk/Auditor Kelly Pehrson, San Juan County Administrator Monticello, Utah Re: GRAMA requests for attomey/client privileged documents Gentlemen: |As you know, I represent Kenneth Maryboy and Willie Grayeyes. I am a partner with Maynes, Bradford, Shipps and Sheftel, LLP, a firm with offices in Durango and Denver, Colorado. | often ‘work with an associate ofthe firm, Rhonda Tuni, who is a former judge of the Navajo Nation courts and is licensed in New Mexico and the Navajo Nation. | am writing to the two of you in your capacities as the San Juan County Records Officer and as the County Administrator, respectively. In recent weeks, there have been a number of requests submitted to the County, pursuant to the Utah Government Records Access and Management Act (GRAMA), for records pertaining to my clients. Several of the requests lave asked for copies of correspondence, itichuding email atid text messages, between me and my clients. Most recently, Bill Keshlear has asked for a mediation with the Government Records Ombudsman for the Utah State Archives, Rosemary Cundiff, in an effort that seems to be focused on obtaining correspondence between me and my clients. There has also been a request from Kim Henderson for correspondence between me and my clients, which also goes so far as to request communications between me and my associate, Rhonda Tuni (misidentified in the request as “R. Atene”), Tam waiting this letter to advise you that my communications with my clients and my fellow attomeys are not subject to disclosure under the GRAMA. I have advised my clients to not provide such private, privileged correspondence to the County, nor will I provide copies of such correspondence. You may wish to discuss this matter with the San Juan County Attorney, Kendall Laws, but I would recommend you send a copy of this leter to future GRAMA requestors who are seeking copies of correspondence between my clients and me.April 4, 2019 Page 2 If you consult with Mr, Laws, he will likely tell you that the first question in any GRAMA analysis is whether a document is a “record.” I'm sure he will then tell you that my correspondence with my clients does not fall within the definition of “record” or “public record” found at Utah Code sections 63G-2-103(21) and 63G-2-103(22), because my correspondence with my clients and my fellow attorneys are not “prepared, owned, received, or retained by a governmental entity or political subdivision” and, more importantly, are not “public” because they are exempt from disclosure as being “subject to the attomey client privilege” pursuant to 63G-2-305(17). Consequently, my correspondence with my clients is not subject to disclosure under GRAMA and you should explain this to all requestors secking those documents. I realize that some of the requestors might wish to pursue their efforts to obtain this clearly exempt material, despite being advised that itis not subject to GRAMA disclosure. This would, of course, raise legitimate question as to whether the requests are being pursued in bad faith and solely for the purposes of harassment, especially ifthe requestors pursue the requests through litigation. You may wish to discuss with Mr. Laws whether such litigation would make the requestors liable for an award of attomeys’ fees against them pursuant to Utah Code 78B-5- 825 or whether the County would have a claim against the requestors for wrongful use of civil proceedings, as discussed in Hatch v. Davis, 2004 UT App 378 (2004). I will certainly be discussing that option with my clients. Please let me know if you have any questions. ), SHIPPS & SHEFTEL, LLP Durango fee Steven C. Boos: sseb xe: Kendall Laws Kenneth Maryboy Willie Grayeyes=- MBSS = SOT EE MAYNES, BRADFORD, SHIPS & SHEFTEL LL? ANDMENT HANSEN Giese sence aaa ‘nae € MECAR, cee Ppelemnpicheiond Ti asic sHErTa-RFMRED ssa0N'Y BRADFORD 1907156) auNe eS NES 985200) soos@nbsslp.com MEMORANDUM To: Willie Grayeyes FROM: Steven C. Boos RE: Status of Sen Juan County Attomey; direction by County Commission DATE: November 29, 2018 One of the concerns regarding the transition to a new San Juan County Commission has bbeen the legal authority of the Commission over other elected officials in the County, and the County Attorney in particular. This concer has been highlighted by language contained in a recent email message from the County Attorney, Kendall Laws. Laws referred to County elected officials, including himself, as “pseudo independent elected officials.” This language suggests that the County Attorney, and perhaps other County elected officials, are thinking about taking a position that they are not subject to direction fom the Commission. It is therefore important to understand the lines of authority between the Commission and these officials, I. The County Attorney has an attorney-client relationship with the County and is obligated to follow the Commission's instructions when it acts as an entity on behalf of the County. The attorney-client relationship between a County Commission and a County Attorney are stated in Chapter 18(a) of Title 17 of the Utah Code. This chapter is entitled “Powers and Duties of County and District Attorney.” Section 17-18a-802 states that when a County Attomey is acting as civil counsel, he represents the County as an entity pursuant to Utah Rule of Professional Conduct 1.13. This section also states that the County Attorney receives direction from the county through its elected officers, which means the County Commission acting as a body, UCA section 17-53-101(1)(@). It is important to understand that the direction must come from the Commission in the form of an official action, such as a resolution, of the Commission as an entity; individual Commissioners do not to direct the actions of the County Attorney. Salt Lake County Commission v. Salt Lake County Attorney, 985 P.24 899, 905 (1999). wis pote “GANGA BANK BUND (or 20.088. in RET ACSI (cam 4500") NOT ACSINovember 29, 2018 Page 2 ‘The County Attomey must follow the direction of the County Commission on legal ‘matters as expressed in an official action, even if the County Attorney disagrees with the wisdom of the direction. As explained by the Utah Supreme Court in the Salt Lake County decision, “nothing in Rule 1.13 gives an elected attomey representing an entity the right to question the entity's choice of legal options. Furthermore... . Rule 1.2 of the Rales of the Rules of Professional Conduct, to which the County Attorney is bound to adhere, instructs that ‘{a] lawyer shall abide by a client’s decisions concerning the objectives of representation .. . and shall consult with the client as to the means by which they are to be pursued.’ [citation omitted] Section 17-5- 219 {currently codified as 17-53-315] of the [Utah] Code reiterates this rule, stating that the Commission has the right to ‘control and direct the prosecution and defense of all actions to which the county is a party.” Consequently, the County Attomey must follow the direction of the County Commission on legal matters where that direction is contained in a duly adopted official action of the County Commission. IL, _ Remedies if the County Attorney refuses to follow the direction of the County Commission. It is clear that the County Attorney is required to follow the direction of the County Commission on legal matters when the Commission places that direction in an official action, such as a resolution. What remedies does the Commission have if the County Attomey, after receiving a resolution, refuses to follow the direction of the County Commission? This scenario was discussed at length in the Salt Lake County decision. The Utah Supreme Court stated that a County Commission was not at liberty to hire outside counsel as a substitute for the County Attorney until itis clear that the County Attomey is unable or unwilling to perform his duties, including following the lawful direction of his client, The simplest way to dotermine whether the County Attorney is unwilling to follow the lawful direction of the County Commission would be to pass a resolution containing a direction and request a written response from the County Attorney regarding whether he will follow that direction. However, the ‘Supreme Court recognized that there may be situations where “the County Attorney will never admit he is unable or unwilling to perform his duties, thereby paralyzing county government.” Salt Lake County at 908. ‘The Utah Supreme Court identified three avenues to resolve such a conflict with a | ‘County Attomey. First, it suggests that the parties consult the Utah Rules of Professional ‘Conduct and attempt to settle the matter among themselves. A solution to the conflict might take { 1 The Comments to Rule 1.13 state “when constituents of the organization make decisions for it, the decisions ordinarily must be accepted by the lawyer even if their utility or prudence is doubtful.” |November 29, 2018 Page 3 the form of the County Attomey agreeing to withdraw his appearance in a given case and then allowing the County Commission to retain outside counsel to take his place and implement the direction of the Commission.2 Second, the County Commission can appeal to the Utah Attomey General “to intervene where the proper role of a county attorney is at issue.” Salt Lake County at 908, The precise form of the intervention is unclear The decision refers only to a written opinion from the Attomey General and does not clarify whether such an opinion can force the County Attomey to take direction from the County Commission or whether it would merely serve as evidence that the County Attorney is, in fact, unwilling to do his job, thus freeing the Commission to hire outside counsel. Finally, the Supreme Court notes that the Commission could file a declaratory judgment action in the District Court. The exact goal of such litigation is not clarified, although the Supreme Court does note that such an action would be cumbersome, divisive and slow. II. Conclusion and Recommendations ‘The County Attorney is not a “pseudo independent elected official.” Rather, he is the County's attomey and must accept direction from his client, in much the same manner as any attomey must accept direction from his client. The County issues such direction through official actions, that is, through resolutions of the County Commission. The County Attomey cannot ignore the direction he receives in such resolutions. If he does decline to take such direction, he risks being found in violation of the Utah Rules of Professional Conduct and may be sanctioned. It is also possible that he could be displaced by the Utah Attorney General or the state District Court. To ensure the County Attomey complies with the direction ofthe Commission on particular issues, the following steps should be taken: 1. Aresolution should be adopted by the Commission that identifies the case with specificity (that is, with the case name and case number); states with specificity the action to be taken in the case (for example, filing a motion to dismiss); and specifies a precise date by which time the County Attomey must take the specified action, 2. The resolution must be placed on an agenda of the Commission and approved by a majority of the Commissioners. 3. The resolution must be delivered to the County Attomey. It should be accompanied by a cover memorandum asking the County Attorney to confirm in writing whether he is willing to comply with the direction contained in the resolution. 2 Although not stated by the Supreme Court in the Salt Lake County decision, this could also involve filing a professional ethics complaint against the County Attorney for a violation of the Rules ifthe refuses to cooperate on any level and follow the lawful direction of the County Commission, although this ean be a time-consuming process.‘November 29, 2018 Page 4punoy eney am ‘sseeyouoN “sseo0rd onjeByserul o43 Buejduioo Jo} seullpeap ayjoads ani6 jou op yorum ‘(.q74,) Ailigesiq pue eulidiosig Jake Jo seiny uy Aq pauono aie siepeW suIjdiosip Kewony “sainy au} Jo ONEIOIN 2 useq sey e/oy) JeyJoYM ouILUE}ep 0} eoRId Bye} JsNWI Jey} ssed0Id queyiodu ue si JonpucD JeuOISsejo1q Jo seiMy 94} YM eoUePI0d0e ul wey Burzsjeue pue sje} ey Bululeieose ‘own aye} Kew q yBnowy ueAny ‘sseooid ey Bulinp Buipueysiopun pue eouaned snof ayefoaidde am pue ‘yoreeses pue ajeBysonu! 0} ewin oye} siyeUI asoyy ‘suoneBaije ayy Jo ainjeu snouies Ajjequajod ely Jo esneoeg “sseooid ey) Buunp Bulpueysiapun pue eouaned snof aeloadde om pue ajaidwos 0) aun see} ssa00id siyy “suoNoUeS Jehmey Bulsoduy| 40} Splepueyg ey} 0} JUeNsiNd pesodw! eq uoNoUes syeudoidde ue yey Japlo uaLR AewW y ‘JONPUOg JeuOISSeJo1g JO SeINY OY pareIO!A ABWORe SY JeUI SPUY “UNED JOUISIG YeIN e JO yNOg eweidng UeIN au} Jo eanIUWIOD auIJdjosiq PUe sola oY} JoMpIE ‘JeuNqUI e J] JNPUOD [eUOISSEJo1g JO SaINY atp Jo SUONEIOIN 10} SKoWIORE a;noasod ‘seseo ejeudoidde ul ‘pue yonpuoosiM jeuoIssejod jo suoyeBale ayeBysenul 0} a1e saniiqisuodses s,ddO ey, ‘Aewoye ue uodn auljdiosip asodu 0} AouIne ou sey DdO EU) Jey) a1eMe Og yayew sly} Ul NOA juaseida you sBop OdO ou Jy) B1EMe aq eseaIq ‘mo!ne! aU} Jo SyNse: oy) BuIpleBe! payse]uoo |q IM MOA pue AewoNe (,0dO,) YONPUCD [UOISse}OId Jo 20ljQ ue Aq pamela) aq jIIm Jaye! si) “Soog UeNeIS BulpreBas PaHIWIGNS NOK UoREUIOU! 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