HYPOTHETICALS FOR USE IN TRAINING OF LAWYERS ON THE ROLE OF THE PRO BONO LAWYER

HYPOTHETICAL FOR USE IN TRAINING OF LAWYERS ON PRO BONO, ETHICS AND TECHNOLOGY: PALAWHELP.ORG & PAPROBONO.NET

Is it Just Information Given a Non-client or Is the Person a Client? 

Providence Bono, an attorney in private practice known as "Pro" to her friends, has agreed to participate in her local bar association’s "Legal Information Phone-a-thon" by providing brief telephone information ("Information about the law, not legal advice" reads the Bar ad in the local paper) to individuals who have been screened for eligibility by the local legal aid office but whose cases fall in areas that are not among those "urgent" cases the local office handles as it performs civil legal aid triage with too many cases and too few resources. Ms. Bono is given the discretion through the local bar program to refer the person back to legal aid so that another attorney might be sought to handle the case on a pro bono basis if the telephone advice seems insufficient to help the caller handle the matter. Ms. Bono knows that the chances are small that a pro bono lawyer would be found if she refers the case back to legal aid, but the Phone-a-thon organizers emphasize to all of the lawyers who take calls that those lawyers are under no obligation to take the matter any further than providing information over the phone..

Obviously, if Ms. Bono so chooses, she may take the case as far as she believes is justified, including advice or full representation. However, she has already done 50 hours of direct pro bono representation on Peas this year and she wants to limit her role today to merely providing legal information, something the local pro bono coordinator still tells her counts as pro bono service. While waiting for her first call, Ms. Bono wonders if the local coordinator is correct on his definition of what counts for pro bono service?

Mr. Ned Needy has been screened and now calls the Phone-a-thon. Ms. Bono gets his call…

At what point in the following progression does Ms. Bono go beyond merely providing legal information to Mr. Needy? When does an attorney-client relationship form between Ms. Bono and Mr. Needy? What other ethical issues arise under this fact pattern?

* After Mr. Needy was found financially eligible by legal aid, he was referred to the Phone-a-thon. He was advised that the attorney will not be able to actually advise or represent him but will provide legal information to help him understand his rights and obligation. The receptionist also explained that Ms. Bono will walk him through certain resources available to the public on the www.palawhelp.org website, thanks to the good work of the Pennsylvania Bar Association and the Pennsylvania Legal Aid Network. After connecting Mr. Needy with Ms. Bono, one of the many lawyers waiting to take calls from the area poor, the receptionist—a first year night law student--wonders if the disclaimers he has provided are sufficient for Mr. Needy to know he is not being given a lawyer to handle his case?

* Mr. Needy is connected to Ms. Bono.

* Mr. Needy describes his landlord’s threat to evict him at some point in the future.

* Ms. Bono refers Mr. Needy to the www.PALawHelp.org website, where he can find information on tenant rights in eviction cases and she offers to mail him a copy of the pamphlet produced by the Pennsylvania Bar Association on Landlord/Tenant Law.

* Mr. Needy says that to put his mind at ease, he really needs more immediate information and asks Ms. Bono to tell him his rights.  Ms. Bono responds by saying that while she cannot advise him specifically as to how the law affects his circumstances, she can describe the basic rules of Landlord/Tenant law as they govern eviction, and she proceeds to do so. She is reading from material on the PALawHelp website and she offers to also print that out for Mr. Needy.

* Mr. Needy asks some more questions.  "Can my landlord evict me before the end of my lease?  Don't I have any rights, like the right to have enough heat for my family?  Can my landlord just show up and put a lock on the door?"

* Ms. Bono says that while she is not advising Mr. Needy in the matter, she can describe for him how the law generally treats these types of questions.  She goes on to talk about what the law says, as it governs eviction when there is a lease; she describes the principles of the warranty of habitability; and she describes the legal process for eviction.  She says to Mr. Needy that she cannot comment on exactly how the law would apply to Mr. Needy's particular circumstances but she can describe how the law works generally.

* Mr. Needy and Ms. Bono talk some more.  Ms. Bono becomes very concerned after hearing about Mr. Needy's young children and Mr. Needy's fears of possibly being homeless.  She then offers some specific advice as to how the law applies to Mr. Needy’s situation and how he should respond to the landlord. 

Questions:

1)  Is there ever an attorney-client relationship? If so, when did an attorney-client relationship come about?

2) Is it ethically permissible for Ms. Bono to limit her services to just informing Mr. Needy about resources available or to just providing brief advice? If so, what must Ms. Bono do to make sure Mr. Needy agrees to her limited representation of him?

3) Should anything between these two people be reduced to writing?

4) Should Ms. Bono have done a conflict check before even beginning the call from Mr. Needy or at any time during their conversation? What happens if it turns out that her law partner has represented the landlord in the past, before Ms. Bono joined the firm?

5) If an attorney-client relationship exists, what are Ms. Bono's obligations once the relationship has been created?   Is she required to represent him in the unemployment case he has pending that is, in Mr. Needy’s view, the source of his problem with the landlord?

Posted to the PBA web site June 2007


General Pro Bono Hypothetical

1. Maxine Ability is an attorney in private practice in Keystone, the largest city in Barrister County. She is known by local legal services providers as an attorney who takes particularly difficult pro bono cases, especially in the areas of housing and landlord-tenant law. Today, Maxine received a fax from the legal services provider referring a case involving an elderly couple facing eviction proceedings because their nephew, who has lived with them in their public housing apartment, has been arrested and charged with drug dealing on the other side of town. Maxine has handled a number of such cases. Recent revisions to federal regulations for public housing have imposed stricter eviction requirements for sale or use of illegal drugs, and the legal services program has come to rely a great deal on Maxine because of her success in this area. The housing authority knows only too well that Maxine’s sophistication and negotiating skills have succeeded in avoiding evictions, where several less-experienced lawyers have failed.

Recently, Keystone’s voters elected a new mayor from the opposition party. In the past, Maxine’s firm represented the mayor in her business affairs and now she rewards the firm by hiring it to represent Keystone in real estate law and tax matters. Keystone’s housing authority is an independent agency whose director is appointed by a state board, but its leaders are closely aligned with the new mayor’s party. There is no technical conflict, and in fact, Maxine is fairly confident that if, as in the past, she can settle the clients’ case without going to court, the housing agency would accept that result without protest and might even be grateful since it does not want media attention for evicting the elderly.

On the other hand, if Maxine is required to go to court, she fears that the housing agency’s in-house counsel will notify Keystone’s city solicitor of her role in the case. For this reason, Maxine would prefer not to represent the clients. Maxine is uncomfortable not taking this case since she has an ongoing commitment to the referral staff person at the local legal services program and knows it will be difficult for him to find another attorney to take this matter. Maxine received the referral on Wednesday and the evictions proceedings are scheduled for 10:00 a.m. on Monday morning.

  • What are Maxine’s options? Is she required to take the case? Is she able to just say no?
  • What should she do? What additional information would help to assess what Maxine should do?

2. Andrea Jones was appointed by the federal Court of Appeals to represent a prisoner, Alex Green, on appeal of his civil rights claim against the state department of corrections and various officials and corrections officers. The District Court had dismissed the client’s claims of deliberate indifference to medical needs, retaliation for filing a grievance and other misconduct on the grounds that the client had failed to exhaust administrative remedies. The Court of Appeals reversed, finding that the client had exhausted and remanded the case to the District Court.

Six weeks later, the client writes to Andrea to say that nothing has happened in the District Court since the case was remanded and asks Andrea to represent him in his civil rights claims against the department of corrections and others. The client is concerned that the District Court “will ignore” his case unless he has counsel. In order for Andrea to represent him, the client would have to file a petition for appointment of counsel and specifically request that the District Court appoint Andrea as his counsel. Local rules require that even though Andrea was appointed by the Court of Appeals, she would still have to file this petition in District Court to remain in the case.

Although Andrea is very busy, she would like to take the case because of the relationship she has developed with the client, her familiarity with the legal issues and her belief that she and other lawyers in her firm have experience that will enhance the client’s chances on remand.

On the other hand, Andrea has some doubts because she knows that some of the client’s claims are weak. The client believes that all his claims are quite strong. Andrea is concerned that the client may become difficult if she tries to convince him to drop some claims. She also worries that the trial judge might have some resentment over her victory in the Court of Appeals. In addition, Andrea knows that this case will require more work than the appeal did and that she will need another attorney to help. Although her firm handles a number of prisoner cases each year, it is at or near the limit of the number of cases it is willing to handle.

  • What are Andrea’s options?
  • Is she obligated to represent the client on remand?
  • Should there have been a representation agreement in the Court of Appeals matter? Does it matter what this agreement said?

What issues should Andrea discuss with the client?

3. As part of the current flurry of school reform initiatives, a group of “concerned citizens” recently approached Ed Hooks, a third-year associate in a three person firm, and asked if he and his firm would handle — pro bono — the incorporation of a new nonprofit charter school and its application for tax-exempt status. The school would be located in one of the poorest sections of the county and would focus on the arts and music as its “specialties,” along with the traditional academic subjects. Two of the concerned citizens are prominent community leaders and high-level managers in businesses that are clients of Ed’s firm. They tell Ed that three other firms were asked to handle this work, but declined and that the project will fail without Ed’s help.

Ed and another associate agree to do the work both because of the client connection and because Ed knows that the charter school proposal has received a lot of media attention. Ed believes that he and his firm would look good for taking this work on. In addition, this work fits very neatly into the growing practice in Ed’s firm representing school districts in a variety of legal matters.

Ed is on a tight deadline because the school must be incorporated and its tax-exempt application must be filed within a month if it is to be ready to open its doors in time for the next semester when it is scheduled to open. After Ed and his colleague have drafted the articles of incorporation and by-laws, but before application for tax-exempt status has been finalized, Ed learns from the business leaders in the third meeting that the school will be affiliated with a major private university in town. He also learns that start-up costs will be underwritten by $10 million in donations from private citizens and foundations and that the university has donated another $10 million for an endowment for the school. As Ed review this data, Ed realizes that the school and its backers could easily pay his firm’s legal fees and do not meet the firm’s definition of pro bono clients.

Ed also knows that his firm represents other charter schools and school districts on a fee basis. Ed fears that if any of these fee clients learn that the firm is representing the proposed school on a pro bono basis, they may demand that the firm represent them pro bono as well.

  • What should Ed do with this information?
  • Should there have been a representation agreement? If so, what are the elements of this agreement that might help under the present circumstances?
  • What will/should happen if the senior partner advises Ed that the client is no longer eligible for pro bono treatment and tells Ed he cannot continue to represent the client pro bono?
  • What issues should Ed discuss with the client? What obligations does Ed’ law firm have under the circumstances?

4. Sandy Isaacs has accepted a referral to represent a pro bono client in a child support dispute. In accepting the referral to represent the mother, Sandy realizes that the matter is likely to result in a detailed hearing. The mother advises Sandy that the father has had several jobs in the last few years, usually working at least two jobs at any given time and that she strongly suspects that he has not reported the fact that he has had some of these jobs or the income he has earned from them. The mother offers Sandy some pay stubs and other records the father inadvertently left at her home while he was visiting the children.

In the course of representing the mother, Sandy attended a mediation conference and learned that the father is represented by an attorney Sandy knows from prior complex financial litigation. In the prior litigation, Sandy strongly suspected that the other attorney fabricated or altered some financial memos and records produced by his client in discovery, although Sandy was not completely sure. She was able to work around the “altered” documents and win the case anyway. Thereafter, she reported this attorney to the Disciplinary Board, but she does not know what happened to her complaint.

Sandy has a visceral dislike for this attorney and does not want to handle any case in which he is involved. Sandy believes she will have trouble dealing with this attorney. At the same time, Sandy is concerned that if she withdraws and the client’s case is randomly assigned to another lawyer, that lawyer may not be able to recognize any unethical conduct relating to financial records by opposing counsel. As a result, the client’s case may suffer. She is also worried that if she withdraws now, no attorney will be appointed to fill in for her. She knows that many clients go without representation because there is so much need for civil legal aid for the poor and so few resources available. She wonders whether she can just provide the client with the forms and show her how to pursue her matter pro se.

  • Does it matter whether there is a retainer agreement and what it says?
  • Is Sandy free to withdraw at this point?
  • Is there a process Sandy would need to follow in order to withdraw?
  • Should Sandy discuss her concerns with her client?
  • If the client says she wants Sandy to continue to represent her, does that matter?
  • If Sandy does continue, are there any other steps she should take?
  • If Sandy drops out and no other attorney is appointed, should she pursue her idea to provide forms and advice?



PFA Ethical Hypotheticals

Created by Joseph A. Sullivan, Esquire of Schnader Harrison Segal & Lewis LLP for the 2003 Pennsylvania Bar Association Pro Bono Conference. Reviewed and edited by Samuel W. Milkes, Esquire, Executive Director, Pennsylvania Legal Services and David Keller Trevaskis, Esquire, PBA Pro Bono Coordinator.

HYPOTHETICAL FOR USE IN TRAINING OF LAWYERS ON PRO BONO, ETHICS AND TECHNOLOGY: PALAWHELP.ORG & PAPROBONO.NET

2006

Is it Just Information Given a Non-client or Is the Person a Client? 1

Providence Bono, an attorney in private practice known as “Pro” to her friends, has agreed to participate in her local bar association’s “Legal Information Phone-a-thon” by providing brief telephone information (“Information about the law, not legal advice” reads the Bar ad in the local paper) to individuals who have been screened for eligibility by the local legal aid office but whose cases fall in areas that are not among those “urgent” cases the local office handles as it performs civil legal aid triage with too many cases and too few resources. Ms. Bono is given the discretion through the local bar program to refer the person back to legal aid so that another attorney might be sought to handle the case on a pro bono basis if the telephone advice seems insufficient to help the caller handle the matter. Ms. Bono knows that the chances are small that a pro bono lawyer would be found if she refers the case back to legal aid, but the Phone-a-thon organizers emphasize to all of the lawyers who take calls that those lawyers are under no obligation to take the matter any further than providing information over the phone..

Obviously, if Ms. Bono so chooses, she may take the case as far as she believes is justified, including advice or full representation. However, she has already done 50 hours of direct pro bono representation on PFAs this year and she wants to limit her role today to merely providing legal information, something the local pro bono coordinator still tells her counts as pro bono service. While waiting for her first call, Ms. Bono wonders if the local coordinator is correct on his definition of what counts for pro bono service?

Mr. Ned Needy has been screened and now calls the Phone-a-thon. Ms. Bono gets his call…

At what point in the following progression does Ms. Bono go beyond merely providing legal information to Mr. Needy? When does an attorney-client relationship form between Ms. Bono and Mr. Needy? What other ethical issues arise under this fact pattern?

* After Mr. Needy was found financially eligible by legal aid, he was referred to the Phone-a-thon. He was advised that the attorney will not be able to actually advise or represent him but will provide legal information to help him understand his rights and obligation. The receptionist also explained that Ms. Bono will walk him through certain resources available to the public on the www.palawhelp.org website, thanks to the good work of the Pennsylvania Bar Association and the Pennsylvania Legal Aid Network. After connecting Mr. Needy with Ms. Bono, one of the many lawyers waiting to take calls from the area poor, the receptionist—a first year night law student--wonders if the disclaimers he has provided are sufficient for Mr. Needy to know he is not being given a lawyer to handle his case?

* Mr. Needy is connected to Ms. Bono.

* Mr. Needy describes his landlord’s threat to evict him at some point in the future.

* Ms. Bono refers Mr. Needy to the www.PALawHelp.org website, where he can find information on tenant rights in eviction cases and she offers to mail him a copy of the pamphlet produced by the Pennsylvania Bar Association on Landlord/Tenant Law.

* Mr. Needy says that to put his mind at ease, he really needs more immediate information and asks Ms. Bono to tell him his rights. Ms. Bono responds by saying that while she cannot advise him specifically as to how the law affects his circumstances, she can describe the basic rules of Landlord/Tenant law as they govern eviction, and she proceeds to do so. She is reading from material on the PALawHelp website and she offers to also print that out for Mr. Needy.

* Mr. Needy asks some more questions. “Can my landlord evict me before the end of my lease? Don't I have any rights, like the right to have enough heat for my family? Can my landlord just show up and put a lock on the door?”

* Ms. Bono says that while she is not advising Mr. Needy in the matter, she can describe for him how the law generally treats these types of questions. She goes on to talk about what the law says, as it governs eviction when there is a lease; she describes the principles of the warranty of habitability; and she describes the legal process for eviction. She says to Mr. Needy that she cannot comment on exactly how the law would apply to Mr. Needy's particular circumstances but she can describe how the law works generally.

* Mr. Needy and Ms. Bono talk some more. Ms. Bono becomes very concerned after hearing about Mr. Needy's young children and Mr. Needy's fears of possibly being homeless. She then offers some specific advice as to how the law applies to Mr. Needy’s situation and how he should respond to the landlord.

Questions:

1) Is there ever an attorney-client relationship? If so, when did an attorney-client relationship come about?

2) Is it ethically permissible for Ms. Bono to limit her services to just informing Mr. Needy about resources available or to just providing brief advice? If so, what must Ms. Bono do to make sure Mr. Needy agrees to her limited representation of him?

3) Should anything between these two people be reduced to writing?

4) Should Ms. Bono have done a conflict check before even beginning the call from Mr. Needy or at any time during their conversation? What happens if it turns out that her law partner has represented the landlord in the past, before Ms. Bono joined the firm?

5) If an attorney-client relationship exists, what are Ms. Bono's obligations once the relationship has been created? Is she required to represent him in the unemployment case he has pending that is, in Mr. Needy’s view, the source of his problem with the landlord?

1 And other ethics questions you were afraid to ask!



TOOLS & TIPS FOR PRO BONO ATTORNEYS: THE PFA CASE

2006

Hypothetical Case #1:  1

Patricia Plaintiff has been referred to you by your local pro bono program for representation in a PFA that she filed. Two days before the PFA hearing, Patricia leaves you a phone message in which she states that she wants to drop the case and that she doesn't plan to appear at the final hearing. You have never spoken to her or had any contact with her other than the phone message. You try to contact her, but you are unable to reach her before the date of the hearing.

What do you do?

Consider:
  • Attorney Client Relationship - Is she your client?
  • Rule 1.2 Scope of Representation and Allocation of Authority Between Client and Lawyer - do you have any authorization to act on behalf of potential client?
  • Rule 1.18 Duty to Prospective Clients
  • "Rule 3.3 Candor Toward the Tribunal - what, if anything, can you tell the court?

In the alternative, assume that you had talked to Patricia on the telephone the day before she left the phone message. During your phone conversation, she told you that she wanted to proceed and you told her you would handle the case for her. She has not signed a retainer agreement. After receiving the phone message, you try to reach her but you are unsuccessful. What do you do?

Consider:
  • Attorney Client Relationship - Is she your client?
  • Rule 1.2 Scope of Representation and Allocation of Authority Between Client and Lawyer
  • Rule 1.6 Confidentiality of Information

Hypothetical Case #2:


You are representing a woman in a Protection From Abuse Action she filed against her husband. On the morning of the final hearing, she arrives at the courthouse very upset and crying. She keeps repeating that she wants to have the defendant "stay away." The defendant's attorney approaches you and proposes resolving the case by dropping the PFA and amending an existing custody order to include standard PFA language. He points out that these new provisions of the custody order would be enforceable by civil contempt and not indirect criminal contempt or mandatory police arrest.

What do you do?

Consider:
  • Rule 1.3 Diligence
  • Rule 1.4 Communication -What would you need to communicate to client about how custody order would differ from PFA?
  • Rule 1.2 Scope of Representation - Would you continue to handle her case to complete the entry of the custody order?

The defendant's attorney then tells you that the defendant will not enter into a standard PFA consent agreement because the plaintiff has MH/MR problems, drinks, and is unstable. He/she hands you a copy of a report from a Rehabilitation Center that shows that your client was an in-patient there six months ago. The defendant's attorney also tells you that he/she is personally certain that the defendant is a good and non-abusive person and that the plaintiff, your client, is the problem. How do you handle this?

Consider:
  • RPC 1.3 Diligence
  • RPC 3.4 Fairness to Opposing Party and Counsel - To what extent is the opposing counsel's opinion relevant? Does their attitude violate the rules?
  • Discuss relevance to the actual hearing & issue of hearsay.
  • RPC 1.14 Client with Diminished Capacity

Your client becomes more upset as the morning negotiations drag on. Her sister and mother, who have accompanied her to court, insist on being involved in all of your discussions with your client. A staff member from the domestic violence program, who is not an attorney, asks to join the discussion also. What do you do?

Consider:
  • RPC 1.6 Confidentiality
  • RPC 1.7 Conflict of Interest
  • 23 Pa. C.S.A. § 6116 - Confidential communication between DV advocate/counselor and client

Hypothetical Case #3:

Again, you are representing a plaintiff in a Protection From Abuse Action. The defendant is not represented by an attorney and does not want one, preferring to represent himself. How much communication can you have with him?

Consider:
  • Rule 4.3 Dealing with Unrepresented Person
  • Rule 4.1 Truthfulness in Statements to Others

If the defendant agrees to a consent agreement PFA order, how much do you have to explain to him? Do you have any obligation to ensure that he understands the enforcement implications? The impact of federal firearm prohibitions? The state police registry of PFA orders? Any custody provisions?

Consider:
  • Rule 4.3
  • Rule 4.1
  • What does the Court require?
  • Read what is in the order: notices include much of this information. If questions refer him to seek legal counsel.

Hypothetical Case # 4:

One of the PFA plaintiffs you are representing is served with a cross-petition for PFA relief. In preparing your case, you discover that, although your client was punched in the face on one occasion, your client may be the true aggressor and abuser in the intimate partner relationship. In fact, your client was arrested for assaulting the defendant in the past. How do you handle this?

Consider:
  • RPC 3.1 Meritorious Claims and Contentions

As you continue to prepare your case, your client tells you that he/she was punched in the face only after he/she choked and threatened to kill the other party. Your client also tells you that he/she will deny this initial assault if called to testify in court. How do you handle this information?

Consider:
  • RPC 1.6 (c)(1) Confidentiality of Information )- lawyer may reveal confidential information where necessary to "prevent reasonably certain death or substantial bodily harm."
  • RPC 3.3 Candor toward the Tribunal
  • RPC 1.2(d) Scope of Representation
  • RPC 1.16 Declining or Terminating Representation

Hypothetical Case # 5:

You are representing a PFA plaintiff who has fled from her abusive live-in boyfriend and is now staying in a confidential location at a domestic violence shelter. She is in the process of renting a new apartment and does not want the defendant (her ex-boyfriend) to know where she is now or her new address.

Defendant's attorney tells you that the defendant will consent to a final PFA order, but only if an address for the Plaintiff's residence is written into the order. Defendant's attorney goes on to say that, if the address is not written into the order, that will create problems with enforceability. What do you do?

Consider:
  • RPC 1.6 Confidentiality of Information
  • 23 Pa. C.S.A. §6112 PFA Act - provides for confidential addresses.

Hypothetical Case # 6

A while back, your local pro bono program referred a woman to you for representation in a PFA she had filed against her husband. You represented her at the PFA hearing, which was two or three months ago, and at that hearing a final PFA Order was granted for a period of 36 months. You did not have her sign a retainer agreement. You receive a call from her today in which she tells you the following:

  1. Her husband has been arrested and charged with indirect criminal contempt for allegedly violating the PFA Order. A hearing on the indirect criminal contempt charges is scheduled for later in the week.
  2. In the course of the incident on which the PFA was based, a tussle had occurred between the parties, as a result of which the husband had claimed that your client had assaulted him. Your client recently learned that criminal charges have been filed against her based on that incident and a preliminary hearing on those charges is scheduled for next week.
  3. Shortly before his arrest, your client's husband filed a custody action in which he is seeking custody of the parties' children. A conciliation conference has been scheduled in that case.
  4. On top of all of her other problems, the client recently received an eviction notice from her landlord.

She tells you that she would like you to represent her, on a pro bono basis, regarding all of these matters. Are you obligated to represent her in any of these matters? Does it make a difference if the custody case is filed to the same docket number as the PFA? Does it make a difference if she tells you that, after the PFA hearing, she obtained a job that pays well, and as a result you think that it's unlikely that she's still financially eligible for pro bono representation. What difference would a retainer agreement have made?

What should you do?

Consider:
  • RPC 1.2 Scope of Representation
  • Rule 6.1 Voluntary Pro Bono Publico Service
  • Pa R.C.P. 1012 Entry of Appearance. Withdrawal of Appearance Notice.

1Hypotheticals 1 through 5 were adapted with permission from Ethical Issues in Protection from Abuse (PFA) Practice, for NLSA's 2005 Seminar "PFA Practice for the Non-Specialist" by Lorraine Bittner, Esq., and Beth Keenan, Esq., Hypothetical 6 is adapted with permission from 2006 Northeast PA Pro Bono Seminar: Handling the Pro Bono PFA Case: Ethical and Practical Issues, by Sylvia Hahn, Esq., Lackawanna Pro Bono, Inc.