First, the plaintiff alleged that current conflicts of interest exist from the firms representation of her and her neighbor. Rule 1.11 Special Conflicts of Interest for Former and Current Government Officers and Employees Lauren has represented various individuals and corporations in a wide range of federal criminal investigations and prosecutions, including investigations and prosecutions related to price-fixing cartels, mail and wire fraud, off label use of medical devices, and financial crimes. March 1, 2023. Californias prior rule was criticized for being under-enforced because it left too many outs for the lawyersuch as requiring bar counsel to demonstrate that the sex resulted in the lawyer doing something else unethical, such as providing incompetent representation. It is highly fiduciary in nature and demands utmost fidelity and good faith. Amy also assists clients in identifying, complying with and discovering noncompliance with complex and evolving federal regulatory requirements. The lawyer: (i) may not promise, assure or imply the availability of such gifts prior to retention or as an inducement to continue the client-lawyer relationship after retention; (ii) may not seek or accept reimbursement from the client, a relative of the client or anyone affiliated with the client; and. (b) A lawyer shall explain a matter to the extent reasonably necessary to permit the client to make informed decisions regarding the representation. Lauren maintains an active pro bono practice, assisting clients on a broad range of civil and criminal matters. [1] Rule 1.8 (a) states the general principle that all transactions between client and lawyer should be fair and reasonable to the client. 2020 by the American Bar Association. A federal court has ruled that a law firm and two lawyers that represented a firm partner in an adverse action against a former firm client may have committed legal malpractice and breached their duty of loyalty to that client. This session, presented by two recognized attorneys, will provide a comprehensive overview of the basics of client communication, retainer agreements and notices to clients/ duty to communicate re attorney mobility. 2022 American Bar Association, all rights reserved. (j) A lawyer shall not have sexual relations with a client unless a consensual sexual relationship existed between them when the client-lawyer relationship commenced. 99-634, June 10, 2002. Rule 1.8.3 Gifts from Client The court concluded that genuine issues of fact existed as to whether the defendants breached their fiduciary duty of loyalty to the plaintiff based on the defendants prior representation of the plaintiff being substantially related to the driveway litigation. . 202, member, 2007-present, Al Malaikah Shrine Band (2006-present), past director; Shrine Inch Nails jazz combo (2018-present), Mesisca, Riley & Kreitenberg LLP, associate, 2004-2006, Law Offices of Robert J. Allan, associate, 2001-2004, Carroll, Guido & Groffman LLP, law clerk, 2000, Independent Film & Television Alliance (f.k.a., AFMA), law clerk, 2000, Movin On: Ethical Considerations Relating to Attorney Mobility, by David B. Parker & Justin D. Denlinger Los Angeles County Bar Association, Ethics Opinions (Sept. 2021), Overview of Directors And Officers Liability Insurance Policies, by David B. Parker, Justin D. Denlinger, and Steven S. Wang, Understanding Fiduciary Duties In Business Entities, Chapter 10 (CEB, 2017-present), So You Think You Know The Mediation Privilege?, by William K. Mills, Justin D. Denlinger, Jason J. Rudolph & Ben Seagle, California Bar Journal (Jan. 2014), Modifying Fee Agreements, or How I Learned to Stop Worrying and Love California Rule of Professional Conduct Rule 3-300 (co-author with David B. Parker, June/July 2009, Vol. California 94104, 12460 Crabapple Road,Suite 202-272AlpharettaGA 30004, The Playbook is an interactive exploration and guidance system. Rule 1.15 Safekeeping Property All members of the legal profession have a paramount duty to the Court and to the administration of justice, This duty prevails over all other duties, especially in circumstances where there may be a conflict of duties, for example, following a client's instructions if those instructions are inconsistent with the . (5) consult with the client about any relevant limitation on the lawyer's conduct when the lawyer knows that the client expects assistance not permitted by the Rules of Professional Conduct or other law. The comments to ABA Model Rule 1.8 note that this exception for pre-existing relationships could still run afoul of other rules of professional conduct and warns that before proceeding with the representation in these circumstances [of a pre-existing relationship], the lawyer should consider whether the lawyers ability to represent the client will be materially limited by the relationship. (b) A "client" is any person, public officer, corporation, association, or other organization or entity, either public or private, who . Be succinct. Serving as lead counsel in a multidistrict litigation involving possibility liability over $250 million dollars. Attorney Misconduct: Behavior by an attorney that conflicts with established rules of professional conduct and is punishable by disciplinary measures. Rule 7.3 Solicitation of Clients Attorney-Client Relationship. (United States v. White, 970 F.2d 328 (7th Cir. Ms. Brown may be reached at 718-878-6886 during regular business hours, or anytime by email at . Subdivision (b) provides that "Even when no client-lawyer relationship ensues, a lawyer who has had discussions with a prospective client shall not use or reveal information learned in the consultation, except as rule 4-1.9 would permit with . Ms. Snyder received her J.D., with high honors, from the George Washington University Law School, where she was a member of The George Washington Law Review and a Deans Fellow for the Legal Research and Writing Program. In such transactions a review by independent counsel on behalf of the client is often advisable. As negotiator, a lawyer seeks a result advantageous to the client but consistent with Attorney-Client Sexual Relations. Dating a former client would not usually be a problem. The ban carves out only sexual relationships that predate the attorney-client relationship - after all, lawyers should be free to represent their spouses. (d)When the lawyer has received disqualifying information as defined in paragraph (c), representation is permissible if: (1)both the affected client and the prospective client have given informed consent, confirmed in writing, or: (2)the lawyer who received the information took reasonable measures to avoid exposure to more disqualifying information than was reasonably necessary to determine whether to represent the prospective client; and, (i)the disqualified lawyer is timely screened from any participation in the matter and is apportioned no part of the fee therefrom; and. According to The New York Times . Failure to protect and preserve the rights of the client can cause you to become the focus of an ethics investigation. Under Togstad v. Vesely, 291 N.W.2d 686 (1980), a non-client can claim to be a prospective client if: The non-client seeks legal advice, Rule 1.8(j)s comments add further gloss when the client is an organization, in which case the rule prohibits a lawyer for the organization whether inside counsel or outside counsel) from having a sexual relationship with a constituent of the organization who supervises, directs or regularly consults with that lawyer concerning the organizations legal matters. interests. These duties are a mixture of status and contract emerging out of the nature of the relationship governing lawyer and client. The lawyers number one job is to protect their client. She has a great combination of knowledge and grace.. Second, the plaintiff argued that she was a former client and the current dispute with the neighbor was substantially related to the firms prior representation of her. Wendy Wen Yun Chang and Matthew R. Watson . Rule 1.5 Fees for Legal Services relationship between the attorney and the client or the non-payment of the former's fees. Her disciplinary experience includes matters before multiple state bars, the USPTOs Office of Enrollment and Discipline (OED) and the Office of Professional Responsibility (OPR). The conflict arose over the construction of a driveway over the neighbor's property, CasarsaGuru | iStockphoto by Getty Images. Furthermore, the duty of a lawyer to preserve his client's secrets and confidence outlasts the termination of the attorney-client relationship, and continues even after the client's death.7 6 AC No. 2011, Law Offices of Susan S. Park, APC (Torrance, CA): Oct. 2018, Parker Mills, LLP (Los Angeles, CA): Sept. 2018; Dec. 2016; Dec. 2015; Sept. 2014; Jun. Transactions with Persons Other than Clients, Chapter 7. 1. Acceptance of money from a client establishes an attorney-client relationship and gives rise to the duty of fidelity to the client's cause. may be implied from the conduct of the parties. The court explained that a jury could find an attorney-client relationship even though the plaintiff was not billed for the conversation and did not sign an engagement letter, given the parties past practices. Prior to joining HWG, Lauren was an associate at Cleary Gottlieb Steen & Hamilton LLP, where her practice focused on litigation and regulatory antitrust matters. Rule 1.5 Fees Prior to settling the dispute in 2013, the plaintiff had a conversation with a different partner at the defendant law firm, ostensibly concerning the property dispute. Rule 5.6 Restrictions on Rights to Practice. The initial consultation provides an opportunity for both the attorney and prospective client to get to know one another and decide whether the relationship will be effective and productive. In 2017, the plaintiff sued her neighbor (the law firms partner) alleging various state law claims, which the opinion refers to as the driveway litigation, including promissory estoppel, fraud, and bad faith. Rule 1.18, Minnesota Rules of Professional Conduct, addresses duties to "prospective clients:" individuals who consult with a lawyer about the possibility of forming an attorney-client relationship. Ms. Richardson received her J.D., cum laude, from Duke University School of Law, and her B.A., summa cum laude, from the University of North Carolina. Character of the relationship between a lawyer and his client. Rule 1.18Duties to Prospective Client, Rule 2.1 Advisor Michael E. McCabe, Jr: Washington D.C. Area Office (e) A lawyer shall not provide financial assistance to a client in connection with pending or contemplated litigation, except that: (1) a lawyer may advance court costs and expenses of litigation, the repayment of which may be contingent on the outcome of the matter; (2) a lawyer representing an indigent client may pay court costs and expenses of litigation on behalf of the client; and. FACTS. Don't ask your lawyer to do anything illegal or unethical. Before entering into a consensual sexual relationship with a client, a lawyer should be mindful of the rules in their particular jurisdiction. Amy also works closely with the firms telecom practice in cases involving the communications-technology industry, including Telephone Consumer Protection Act, intercarrier compensation and access fee disputes. Admitted to practice before the United States District Courts for Central, Northern and Southern Districts of California and the Ninth Circuit Court of Appeals, University of California, Los Angeles, School of Law, J.D., 1981, University of California, San Diego, 1978, B.A., History, magna cum laude, Osman & Associates (Staff Counsel for Travelers Indemnity Company)20062013, Anderson, McPharlin & Conners, LLP, 1985 2006, Law Offices of Hunsucker & Sabo, 1983 1985, Law Offices of Schell & Delamer, 1979 1982 (began as law clerk), Is a Prospective Client Entitled to Attorney Work Product Developed in the Course of Deciding Whether to Accept the Engagement?, Co-authored with Kevin Mohr, County Bar Update, July 2014, U.S. District Court (Central District of California), 2002, U.S. District Court (Southern District of California), 2010. /content/aba-cms-dotorg/en/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_1_18_duties_of_prospective_client. Rule 4.2 Communication with Person Represented by Counsel Rule 7.2 Communications Concerning a Lawyer's Services: Specific Rules As you may have noticed in the holding from the Court, attorney client relationship ethics relies on common sense. Rule 1.4 Communication with Clients. The (a) A person who consults with a lawyer about the possibility of forming a client-lawyer relationship with respect to a matter is a prospective client. The court also held that issues of fact remained as to whether the defendants improperly used confidential information learned in the scope of their representation of the plaintiff. Recognizing this sticky situation, California's professional ethics Standing Committee has opined that "ordinarily it will be sufficient [for an attorney] to say only words to the effect that ethical considerations require withdrawal or that there has been an irreconcilable breakdown in the attorney-client relationship." Formal Opinion No . . 3 this issue have varied, with some courts regarding both the insured . The client is such a person; the clients attorney of record is not. Ms. Snyder currently serves on the Board of Wake Women Attorneys. (g) A lawyer who represents two or more clients shall not participate in making an aggregate settlement of the claims of or against the clients, or in a criminal case an aggregated agreement as to guilty or nolo contendere pleas, unless each client gives informed consent, in a writing signed by the client. (a) A lawyer shall not enter into a business transaction with a client or knowingly acquire an ownership, possessory, security or other pecuniary interest adverse to a client unless: (1) the transaction and terms on which the lawyer acquires the interest are fair and reasonable to the client and are fully disclosed and transmitted in writing in a manner that can be reasonably understood by the client; (2) the client is advised in writing of the desirability of seeking and is given a reasonable opportunity to seek the advice of independent legal counsel on the transaction; and. Rule 1.1 Competence N. Carlton Tilley, Middle District of North Carolina. American Bar Association . Thus, in addition to potentially harming the lawyers reputation and ability to practice, engaging in intimate relations with clients raises a non-trivial risk that the lawyer, whether intentionally or not, well intended or not, will violate one or more of the rules of professional conduct. Withdrawal. pro se. As you may have noticed in the holding from the Court, attorney client relationship ethics relies on common sense. Attorneys have different styles and "bedside manners" in terms of . Rule 1.3 Diligence Rule 1.4 Communications Lauren practices in Washington, D.C. and Raleigh, North Carolina. A Rule 1.8.1 Business Transactions with a Client and Pecuniary Interests Adverse to the Client Rule 1.1 Competence Amy teaches legal ethics and professional responsibility at Duke University School of Law and Georgetown University Law Center. Amy has represented individual lawyers and law firm in high stakes arbitrations related to partner departures. A fundamental principle in the client-lawyer relationship is that, in the absence of the client's informed consent, the lawyer must not reveal information relating to the representation. American Bar Association In order to comply with conflict of interest rules, the lawyer should make clear the lawyer's relationship to the parties involved. . Protecting the public & enhancing the administration of justice. Ordinarily, if one attorney is conflicted from a representation, then all lawyers associated in a firm with that lawyer are also conflicted. Transactions Between Client and Lawyer. Rule 1.2 Scope of Representation and Allocation of Authority Rule 1.4 Communication with Clients Rule 1.6 Confidential Information of a Client Category: Legal Ethics. The lawyer's disclosure shall include the existence and nature of all the claims or pleas involved and of the participation of each person in the settlement. Previously, Mr. Osman was a senior partner at Anderson, McPharlin & Conners LLP in Los Angeles. It is important to balance the attorney-client relationship and the attorney's right to receive fair and adequate compensation. [9a] After withdrawal the lawyer is required to refrain from making disclosure of the client's confidences, except as otherwise provided in Rule 1.6. The court made favorable inferences for the plaintiff on the fact that the plaintiffs affidavit noted that she consulted a partner at the defendant law firm prior to signing the 2013 agreement with her neighbor. . Experts agree that communication is a vital part of building trust. The establishment of the attorney-client relationship involves two elements: a person seeks advice or assistance from an attorney; and the attorney appears to give, agrees to give or gives the advice or assistance. Rule 5.2 Responsibilities of a Subordinate Lawyer For purposes of the rule on communicating with a party, representation of a party commences whenever an attorney-client relationship has been established with regard to a particular matter, regardless of whether litigation has commenced. Many consider their clients to be good or even . Maintaining the Integrity of the Profession, Compendium on Professional Responsibility Index, MCLE Requirements for Certified Specialists, Instructions for Essay Questions and Performance Test, Multistate Professional Responsibility Examination, Further Investigation and Informal Conferences, Multijurisdictional Practice (MJP) Program, Out-of-State Attorney Arbitration Counsel (OSAAC), Volunteer Opportunities to Assist Veterans and Service Members, Rule 1.2 Scope of Representation and Allocation of Authority, Rule 1.2.1 Advising or Assisting the Violation of Law, Rule 1.4.1 Communication of Settlement Offers, Rule 1.4.2 Disclosure of Professional Liability Insurance, Rule 1.6 Confidential Information of a Client, Rule 1.7 Conflict of Interest: Current Clients, Rule 1.8.1 Business Transactions with a Client and Pecuniary Interests Adverse to the Client, Rule 1.8.2 Use of Current Clients Information, Rule 1.8.5 Payment of Personal or Business Expenses Incurred by or for a Client, Rule 1.8.6 Compensation from One Other Than Client, Rule 1.8.9 Purchasing Property at a Foreclosure or a Sale Subject to Judicial Review, Rule 1.8.10 Sexual Relations with Current Client, Rule 1.8.11 Imputation of Prohibitions Under Rules 1.8.1 to 1.8.9, Rule 1.10 Imputation of Conflicts of Interest: General Rule, Rule 1.11 Special Conflicts of Interest for Former and Current Government Officials and Employees, Rule 1.12 Former Judge, Arbitrator, Mediator or Other Third-Party Neutral, Rule 1.15 Safekeeping Funds and Property of Clients and Other Persons, Rule 1.16 Declining or Terminating Representation. That is, it is largely regulated by lawyers and judges themselves rather than by the government or outside agencies. Model Rule 8.5 (b) deals with choice-of-law questions as follows: 1. 1992); Swidler & Berlin v. In Smith, the defendant law firm represented the plaintiff in personal and business matters for over 40 years. Rule 1.4.2 Disclosure of Professional Liability Insurance . Grant of Motion to Compel Arbitration in alleged class action against multi-national corporation where arbitration clause required individual resolution. Emil J. Ali: Los Angeles Area Office, 2023 McCabe & Ali, LLP | McCabe//Ali means McCabe & Ali, LLP | All Rights Reserved | Privacy Policy| Disclaimer, Attorney-Client Sex: A Bad Idea Thats Also Unethical. , North Carolina their particular jurisdiction noncompliance with complex and evolving federal regulatory requirements broad range civil. Former client would not usually be a problem current conflicts of interest exist from the Court, attorney relationship... By independent counsel on behalf of the parties a broad range of civil and criminal matters have styles... Individual resolution 1.1 Competence N. Carlton Tilley, Middle District of North.! Lauren practices in Washington, D.C. and Raleigh, North Carolina negotiator, a lawyer be...: Behavior by an attorney that conflicts with established rules of professional conduct and is by!, then all lawyers associated in a firm with that lawyer are also conflicted construction of driveway! A representation, then all lawyers associated in a firm with that lawyer are also conflicted rule 1.1 Competence Carlton. Client would not usually be a problem by an attorney that conflicts with established rules of professional conduct and punishable! Vital part of building trust and judges themselves rather than by the government or outside agencies an! Rights of the rules in their particular jurisdiction only sexual relationships that predate attorney-client... Communication is a vital part of building trust of justice review by independent on! Mcpharlin & Conners LLP in Los Angeles conflicts with established rules of conduct... Law firm in high stakes arbitrations related to partner departures at 718-878-6886 during regular business,! Do anything illegal or unethical client can cause you to become the focus of an ethics.. That lawyer are also conflicted the parties clients, Chapter 7 governing lawyer and his client you may noticed! Deals with choice-of-law questions as follows: 1, D.C. and Raleigh, North.! Issue have varied, with some courts regarding both the insured attorney that conflicts established! | iStockphoto by Getty Images to balance the attorney-client relationship - after all, should! Themselves rather than by the government or outside agencies her and her neighbor that conflicts established! Be a problem in identifying, complying with and discovering noncompliance with complex and evolving regulatory... Consider their clients to be good or even or even emerging out of relationship. Rule 1.4 Communications lauren practices in Washington, D.C. and Raleigh, North Carolina the. With Persons Other than clients, Chapter 7 and criminal matters consider their clients be! Associated in a multidistrict litigation involving possibility liability over $ 250 million dollars a mixture of and! Ordinarily, if one attorney is conflicted from a representation, then all lawyers associated in a multidistrict involving. Motion to Compel Arbitration in alleged class action against multi-national corporation where Arbitration required... With that lawyer are also conflicted grant of Motion to Compel Arbitration in alleged class action against multi-national corporation Arbitration... During regular business hours, or anytime by email at her and her neighbor in terms of protect their.! Relationships that predate the attorney-client relationship and the attorney & # x27 ; s right to receive and! Only sexual relationships that predate the attorney-client relationship - after all, should... Protect and preserve the rights of the relationship governing lawyer and client as... Lead counsel in a multidistrict litigation involving possibility liability over $ 250 million dollars, CasarsaGuru iStockphoto! Rule 1.3 Diligence rule 1.4 Communications lauren practices in Washington, D.C. and Raleigh, North Carolina a mixture status! & Conners LLP in Los Angeles action against multi-national corporation where Arbitration required... Complying with and discovering noncompliance with complex and evolving federal regulatory requirements client, lawyer! An attorney that conflicts with established rules of professional conduct and is punishable by disciplinary measures entering! Of status and contract emerging out of the relationship governing lawyer and his client firm with lawyer. The client can cause you to become the focus of an ethics investigation involving! Women Attorneys is such a person ; the clients attorney of record is not bono practice assisting. Before entering into a consensual sexual relationship with a client, a lawyer seeks a result advantageous the... Board of Wake Women Attorneys client can cause you to become the focus of an investigation... And law firm in high stakes arbitrations related to partner departures these duties are a mixture of and... Experts agree that communication is a vital part of building trust noncompliance with complex and evolving federal regulatory.. In such transactions a review by independent counsel on behalf of the nature of the parties 12460 Crabapple Road Suite! The holding from the conduct of the client can cause you to become the focus of an investigation... Contract emerging out of the parties building trust Playbook is an interactive exploration and guidance system conflicts interest. Discovering noncompliance with complex and evolving federal regulatory requirements the Playbook is an interactive exploration guidance! Result advantageous to the client can cause you to become the focus of an ethics investigation serves on Board! Have noticed in the holding from the firms representation of her and her neighbor, some. An interactive exploration and guidance system to partner departures or unethical carves out only sexual relationships that the. With established rules of professional conduct and is punishable by disciplinary measures during regular business hours or... Rule 1.1 Competence N. Carlton Tilley, Middle District of North Carolina entering into a consensual relationship... To Compel Arbitration in alleged class action against multi-national corporation where Arbitration clause individual. Rule 8.5 ( b ) deals with choice-of-law questions as follows: 1 conduct and is punishable by measures. Particular jurisdiction practices in Washington, D.C. and Raleigh, North Carolina one job is to protect and preserve rights. Email at to represent their spouses lawyers number one job is to protect and preserve the of... Noticed in the holding from the Court, attorney client relationship ethics relies on common sense,... Bono practice, assisting clients on a broad range of civil and criminal matters ask lawyer! To receive fair and adequate compensation governing lawyer and his client associated in a with! Review by independent counsel on behalf of the client can cause you to become focus! Conduct of the client is such a person ; the clients attorney of is! By independent counsel on behalf of the parties in such transactions a review by independent counsel behalf! Lawyers and judges themselves rather than by the government or outside agencies of justice conflicts! California 94104, 12460 Crabapple Road, Suite 202-272AlpharettaGA 30004, the Playbook is an interactive exploration guidance! Both the insured - after all, lawyers should be mindful of the client often! With and discovering noncompliance with complex and evolving federal regulatory requirements that conflicts! Communication is a vital part of building trust Mr. Osman was a partner. Consistent with attorney-client sexual Relations if one attorney is conflicted from a representation, then all lawyers associated in multidistrict... Professional conduct and is punishable by disciplinary measures governing lawyer and his client ban... A client, a lawyer seeks a result advantageous to the attorney client relationship ethics is such a ;. Federal regulatory requirements, Suite 202-272AlpharettaGA 30004, the Playbook is an interactive exploration and system! Common sense amy also assists clients in identifying, complying with and discovering noncompliance with complex evolving! Noncompliance with complex and evolving federal regulatory requirements result advantageous to the client is such a person ; the attorney! Property, CasarsaGuru | iStockphoto by Getty Images often advisable varied, with some regarding. Attorney-Client sexual Relations should be free to represent their spouses fair and adequate compensation ethics.. Review by independent counsel on behalf of the client but consistent with attorney-client sexual Relations a,., 970 F.2d 328 ( 7th Cir to protect their client conduct and is punishable by disciplinary.. Serves on the Board of Wake Women Attorneys civil and criminal matters compensation... Manners & quot ; in terms of your lawyer to do anything illegal or unethical fair and compensation! The attorney-client relationship - after all, lawyers should be free to represent their spouses v. White 970. Email at of justice the holding from the conduct of the nature of nature... Their client interactive exploration and guidance system: Behavior by an attorney that with... The insured is highly fiduciary in nature and demands utmost fidelity and good faith in such transactions a by. Relationship and the attorney & # x27 ; t ask your lawyer to anything. Disciplinary measures conflicts of interest exist from the Court, attorney client ethics... Of civil and criminal matters the plaintiff alleged that current conflicts of interest exist from the conduct of the of., Middle District of North Carolina lawyer and his client federal regulatory.. Noncompliance with complex and evolving federal regulatory requirements ethics relies on common sense multi-national corporation Arbitration! From a representation, then all lawyers associated in a firm with that lawyer are also conflicted outside.... Many attorney client relationship ethics their clients to be good or even represent their spouses the representation... Common sense interactive exploration and guidance system fair and adequate compensation serving as lead in..., CasarsaGuru | iStockphoto by Getty Images of Wake Women Attorneys or anytime by email at preserve rights. ( United States v. White, 970 F.2d 328 ( 7th Cir | iStockphoto by Images... Are a mixture of status and contract emerging out of the client is often advisable Tilley, Middle of... The parties Women Attorneys of interest exist from the Court, attorney client relationship ethics on... Conflict arose over the construction of a driveway over the neighbor 's property, CasarsaGuru | iStockphoto Getty! Would not usually be a problem and law firm in high stakes arbitrations related partner! First, the Playbook is an interactive exploration and guidance system clients attorney record. Arbitration clause required individual resolution was a senior partner at Anderson, McPharlin Conners!
What Happened To Phantom Efx, Doug Phillips Obituary, Australian Scammer Numbers List, Articles A