Opinion
No. 1921 Disciplinary Docket No. 3 No. 136 DB 2013 Attorney Registration No. 95048
03-31-2014
OFFICE OF DISCIPLINARY COUNSEL, Petitioner v. MICHAEL JAMES DONOHUE, Respondent
Respectfully submitted, OFFICE OF DISCIPLINARY COUNSEL PAUL J. KILLION, Chief Disciplinary Counsel BARBARA BRIGHAM DENYS Disciplinary Counsel District II Office Attorney Registration No. 78562 MICHAEL JAMES DONOHUE Respondent ROBERT E. J. CURRAN, ESQUIRE Attorney for Respondent
(Delaware County)
ORDER
PER CURIAM:
AND NOW, this 31st day of March, 2014, upon consideration of the Recommendation of the Three-Member Panel of the Disciplinary Board dated December 19, 2013, the Joint Petition in Support of Discipline on Consent is hereby granted pursuant to Rule 215(g), Pa.R.D.E., and it is
ORDERED that Michael James Donohue is suspended on consent from the Bar of this Commonwealth for a period of one year, with eight months stayed and four months served, and he shall comply with all the provisions of Rule 217, Pa.R.D.E.,
IT IS FURTHER ORDERED that Michael James Donohue is placed on probation for a period of one year, subject to the following conditions:
1. Respondent shall abstain from using alcohol, drugs, or any other mood-altering or mind-altering chemicals;
2. Respondent shall regularly attend Narcotics or Alcoholics Anonymous meetings on a weekly basis;
3. Respondent shall obtain a sponsor in Alcoholics Anonymous and maintain weekly contact with that sponsor;
4. A sobriety monitor shall be appointed to monitor Respondent in accordance with Disciplinary Board Rule §89.293(c);
5. Respondent shall furnish his sobriety monitor with his Alcoholics Anonymous sponsor's name, address and telephone number;
6. Respondent shall establish his weekly attendance at Narcotics or Alcoholics Anonymous meetings by providing written verification to the Board on a Board-approved form;
7. Respondent shall undergo any counseling, out-patient or in-patient treatment, prescribed by a physician or alcohol counselor;
8. Respondent shall file with the Secretary of the Board quarterly written reports;
9. With the sobriety monitor, Respondent shall:
a) meet at least twice a month10. The appointed sobriety monitor shall:
b) maintain weekly telephone contact
c) provide the necessary properly executed written authorizations to verify his compliance with the required substance abuse treatment; and
d) cooperate fully.
A True Copy Patricia Nicolaa) monitor Respondent's compliance with the terms and conditions of the order imposing probation;
b) assist Respondent in arranging any necessary professional or substance abuse treatment;
c) meet with Respondent at least twice a month, and maintain weekly telephone contact with him;
d) maintain direct monthly contact with the Narcotics or Alcoholics Anonymous chapter attended by the Respondent;
e) file with the Secretary of the Board quarterly written reports; and
f) immediately report to the Secretary of the Board any violations by the Respondent of the terms and conditions of the probation.
As Of 3/31/2014
Attest: __________
Chief Clerk
Supreme Court of Pennsylvania
BEFORE THE DISCIPLINARY BOARD OF THE
SUPREME COURT OF PENNSYLVANIA
OFFICE OF DISCIPLINARY COUNSEL Petitioner
v. MICHAEL JAMES DONOHUE Respondent
No. 136 DB 2013
Attorney Registration No. 95048
(Delaware County)
RECOMMENDATION OF THREE-MEMBER PANEL
OF THE DISCIPLINARY BOARD OF THE
SUPREME COURT OF PENNSYLVANIA
The Three-Member Panel of the Disciplinary Board of the Supreme Court of Pennsylvania, consisting of Board Members David E. Schwager, Brian John Cali, and Stephan K. Todd has reviewed the Joint Petition in Support of Discipline on Consent filed in the above-captioned matter on November 18, 2013.
The Panel approves the Petition consenting to a one year suspension, with eight months stayed and four months set forth in the Joint Petition and recommends to the Supreme Court of Pennsylvania that the attached Joint Petition be Granted.
The Pane! further recommends that any necessary expenses incurred in the investigation and prosecution of this matter shall be paid by the respondent-attorney as a condition to the grant of the Petition.
_______________
David E. Schwager, Panel Chair
The Disciplinary Board of the
Supreme Court of Pennsylvania
OFFICE OF DISCIPLINARY COUNSEL, Petitioner
v. MICHAEL JAMES DONOHUE, ResDondent
No. 136 DB 2013
Board File No. C2-12-1032
Attorney Reg. No. 95048
(Delaware County)
JOINT PETITION IN SUPPORT OF
DISCIPLINE ON CONSENT
PURSUANT TO Pa.R.D.E. 215(d)
Petitioner, the Office of Disciplinary Counsel (hereinafter, "ODC") by Paul J. Killion, Chief Disciplinary Counsel, and Barbara Brigham Denys, Disciplinary Counsel, and Respondent, Michael James Donohue (hereinafter "Respondent"), by and through his counsel, Robert, E. J. Curran, Esquire, respectfully petition the Disciplinary Board in support of discipline on consent, pursuant to Pennsylvania Rule of Disciplinary Enforcement ("Pa.R.D.E.") 215(d), and in support thereof state:
1. ODC, whose principal office is situated at Pennsylvania Judicial Center, 601 Commonwealth Avenue, Suite 2700, P.O. Box 62485, Harrisburg, Pennsylvania 17106, is invested, pursuant to Pa.R.D.E. 207, with the power and duty to investigate all matters involving alleged misconduct of an attorney admitted to practice law in the Commonwealth of Pennsylvania and to prosecute all disciplinary proceedings brought in accordance with the various provisions of the aforesaid Enforcement Rules.
2. Respondent, Michael James Donohue, was born on January 8, 1980, and was admitted to practice law in the Commonwealth of Pennsylvania on September 13, 2005. Respondent is on active status and his current registered public access address is Donohue & Donohue, PC, 8513 West Chester Pike, Upper Darby, Pennsylvania 19082. Respondent is subject to the disciplinary jurisdiction of the Disciplinary Board of the Supreme Court of Pennsylvania.
3. Respondent's affidavit stating, inter alia, his consent to the recommended discipline is attached hereto as Exhibit A.
SPECIFIC FACTUAL ALLEGATIONS ADMITTED
4. Respondent served as a Delaware County, Pennsylvania, Assistant District Attorney from 2006 until November 9, 2011.
5. On Friday, November 4, 2011, Respondent was operating a Jeep Cherokee, registered in Respondent's name and bearing vehicle identification number 1J4HR48N05C565669, on Township Line Road in Upper Darby, Pennsylvania, and struck a pedestrian.
6. The pedestrian Respondent struck was a fourteen-year-old boy named Jake Vantrieste.
7. The boy was rendered unconscious as a result of the accident and remained laying in the roadway until medics arrived and transported him to Children's Hospital of Philadelphia for treatment.
8. It was later determined that the boy suffered injuries to his head, two fractures on his hip, and numerous lacerations about his body.
9. After striking the boy, Respondent fled the scene before police or emergency personnel arrived.
10. Respondent rendered no assistance to the injured boy and failed to report the incident to police.
11. On November 6, 2011, based upon information supplied to the Upper Darby Police Department linking Respondent to the hit and run, Criminal Investigators Brad Ross and Matthew Rowles went to Respondent's residence at 5403 Quentin Street, Philadelphia, Pennsylvania 19128,
12. Respondent's Jeep Cherokee was not parked on the street in front of his residence or in the driveway.
13. The investigators knocked on the door of Respondent's residence and Respondent answered.
14. They explained to Respondent why they were there and requested that Respondent come with them to the Upper Darby Police Headquarters.
15. Respondent refused the investigators' request, stating that he would make arrangements to go to the Upper Darby Police Headquarters at a later date.
16. Respondent did, however, give his consent to the investigators to search the garage attached to Respondent's residence.
17. Located inside the garage was a dark grey Jeep Cherokee, registered to Respondent, with damage on the front driver's side consistent with the November 4, 2011 incident on Township Line Road.
18. Respondent gave consent for his Jeep Cherokee to be towed to Upper Darby Police Headquarters, which it was.
19. On November 7, 2011, a search warrant was prepared and issued for Respondent's Jeep Cherokee.
20. On November 8, 2011, Criminal Investigator Brad Ross executed the search warrant at the Upper Darby Police Headquarters.
21. The investigation confirmed that Respondent's Jeep Cherokee was the vehicle involved in the November 4, 2011 hit and run and that Respondent was the driver.
22. The investigation also revealed that Respondent had been drinking beer at Sligo, a Media bar located near the Delaware County Courthouse, on the evening of November 4, 2011, before Respondent struck the boy.
23. On November 14, 2011, Respondent came to the Upper Darby Police Headquarters with his criminal defense attorney and was arrested and charged in the matter captioned Commonwealth v. Michael J, Donohue, Criminal Docket Number MJ-32134-CR-0000104-2011, with the following offenses:
a) Reckless Driving (75 Pa.C.S.A. §3736), graded a summary offense;
b) Accidents Involving Death or Personal Injury (75 Pa.C.S.A. §3742), graded a felony of the third degree;
c) Failure to Give Information and Render Aid (75 Pa.C.S.A. §3744), graded a summary offense;
d) Failure to Give Notice of Accident to Police (75 Pa.C.S.A. §3746), graded a summary offense;
e) Careless Driving (75 Pa.C.S.A. §3714), graded a summary offense;
f) Simple Assault (18 Pa.C.S.A. §2701(a)(1)), graded a misdemeanor of the second degree;
g) Aggravated Assault (18 Pa.C.S.A. §2702(a)(1)), graded a felony of the first degree; and
h) Recklessly Endangering Another Person (18 Pa.C.S.A. §2705), graded a misdemeanor of the second degree.
24. On February 3, 2012, the Commonwealth amended the charges against Respondent to add the following offenses:
a) DUI: General Impairment / Incapable of Driving Safely (75 Pa.C.S.A. §3802 (a)(1)), graded a misdemeanor of the third degree;
b) Aggravated Assault by Vehicle While DUI (75 Pa.C.S.A. §3735.1), graded a felony of the second degree; and
c) Aggravated Assault by Vehicle (75 Pa.C.S.A. §3732.1(a)), graded a felony of the third degree.
25. On February 15, 2012, a criminal information was filed against Respondent charging Respondent with the following offenses:
a) Aggravated Assault (18 Pa.C.S.A. §2702(a)(1)), graded a felony of the first degree;
b) Aggravated Assault by Vehicle While DUI (75 Pa.C.S.A. §3735.1), graded a felony of the second degree;
c) Aggravated Assault by Vehicle (75 Pa.C.S.A. §3732.1), graded a felony of the third degree;
d) Simple Assault (18 Pa.C.S.A. §2701(a)(1)), graded a misdemeanor of the second degree;
e) DUI: General Impairment (BAC .08-. 10) - First Offense (75 Pa.C.S.A. §3802(a)(2)), graded a misdemeanor;
f) Reckless Driving (75 Pa.C.S.A. §3736(a)), graded a summary offense;
g) Failure to Give Information and Render Aid (75 Pa.C.S.A. §3744), graded a summary offense;
h) Failure to Give Notice of Accident to Police (75 Pa.C.S.A. §3746), graded a summary offense;
i) Careless Driving (75 Pa.C.S.A. §3714(a)), graded a summary offense; and
j) Accidents Involving Death or Personal Injury (75 Pa.C.S.A. §3742(a)), graded a felony of the third degree.
26. During the course of Respondent's criminal trial, held from November 13, 2012, to November 19, 2012, Respondent was acquitted of the aggravated assault and DUI-related charges.
27. At the conclusion of Respondent's criminal trial, the jury found Respondent guilty of violating 75 Pa.C.S.A. §§3742(b)(1) (Accidents Involving Death or Personal Injury), graded a misdemeanor of the first degree, and the summary offenses of Reckless Driving, Failure to Give Information and Render Aid, Failure to Give Notice of Accident to Police, and Careless Driving.
28. The charge of violation of 75 Pa.C.S.A. §3742(a) was amended by the jury's finding of the violation of 75 Pa.C.S.A, §3742(b)(1), a lesser included offense. The jury convicted Respondent of the violation of 75 Pa.C.S.A. §3742(b)(1) because the jury found that the victim had not suffered "serious bodily injury."
The penalty for violation of 75 Pa.C.S.A. §3742 (Accidents Involving Death or Personal Injury) is dependent upon the severity of the injuries suffered by the victim. Unless the victim dies or is found to have suffered "serious bodily injury," the crime is graded a misdemeanor of the first degree. If there is a finding of "serious bodily injury," the crime is graded a felony of the third degree and carries a minimum term of imprisonment of not less than ninety days, and if the victim dies, the crime is graded a felony of the second degree and carries a minimum term of imprisonment of not less than one year. See 75 Pa.C.S.A. §3742(b).
29. At the sentencing, the Commonwealth offered expert testimony of a neurologist certified by the American Board of Psychiatry and Neurology who had reviewed Jake Vantrieste's medical records and recently examined him. The expert testified based upon his review of the medical records that Jake had been found unconscious at the scene by emergency medical services, was transported to the hospital where he regained consciousness "with a mild depression of awareness," was admitted to the intensive care unit for neurological observation due to two intracranial hemorrhages, a scalp laceration, pelvic fractures and leg fractures, and was released six days later. The expert described his examination of Jake to be "essentially a normal examination" with "ongoing complaints which were reasonably related by way of headaches and variable difficulty with focus and concentration" and "some balance difficulty."
30. By letter dated December 3, 2012, a representative of Respondent notified ODC of Respondent's criminal conviction.
31. Respondent's sentencing was held on December 20, 2012. Before Judge John L. Braxton imposed the sentence, Respondent offered an apology to Jake Vantrieste and his family. He also apologized to the Court, to the District Attorney's Office, and to the fire service, for which had served as a volunteer dating back to 1997, "for the embarrassment that [he] caused them" and to the bar of the Commonwealth "for whatever negative impact [his] conduct ha[d] caused it."
32. Judge Braxton sentenced Respondent to confinement at the Delaware County Prison for a minimum of four months, with credit for time served from November 19, 2012, to December 20, 2012, and a maximum of eight months in connection with the misdemeanor conviction, and imposed fines of $500 each in connection with the summary offenses. A specific condition of Respondent's sentence required compliance with the general rules and regulations governing probation and/or parole.
33. Respondent served his prison sentence at the Delaware County Prison from November 19, 2012, through February 23, 2013.
34. On July 19, 2013, Respondent completed his parole obligations and was discharged from supervision.
35. Respondent is now 33 years old and lives with his wife in Philadelphia, Pennsylvania.
36. Respondent maintains the continued support of his family and close friends.
37. Although Respondent has represented that he suffered from alcohol dependence at the time of the November 4, 2011 collision, Respondent has asserted no claim of Braun mitigation.
38. Respondent is currently involved with Lawyers Concerned for Lawyers on a voluntary basis and has begun alcohol counseling with a psychologist.
39. Respondent has not consumed alcohol since the night of the incident and has expressed his commitment to abstaining from alcohol in the future.
40. Respondent is currently working at Donohue & Donohue, PC, as an administrative assistant. Following the November 4, 2011 collision, Respondent resigned from his position as an Assistant District Attorney in Delaware County and has not engaged in the practice of law.
41. Respondent acknowledges the seriousness of his misconduct and its negative impact on the legal profession.
42. Respondent has fully cooperated with ODC in connection with its investigation, and, through his attorney, has expressed his willingness to accept the proposed discipline arising from the criminal conviction.
43. Respondent had no history of discipline in Pennsylvania prior to his criminal conviction, and has no history of discipline after his criminal conviction.
SPECIFIC RULES OF PROFESSIONAL CONDUCT AND
RULES OF DISCIPLINARY ENFORCEMENT VIOLATED
44. Respondent violated the following Rules of Professional Conduct and Rules of Disciplinary Enforcement:
a. RPC 8.4(b), which provides that it is professional misconduct for a lawyer to commit a criminal act that reflects on the lawyer's honesty, trustworthiness or fitness as a lawyer in other respects; and
b. Pa.R.D.E. 203(b)(1), which provides that conviction of a crime shall be grounds for discipline.
SPECIFIC RECOMMENDATION FOR DISCIPLINE
ODC and Respondent jointly recommend that an appropriate discipline for Respondent's admitted misconduct is a suspension from the practice of law for a period of one year, eight months stayed and four months to be served, accompanied by a one year period of substance abuse probation governed by Disciplinary Board Rules §89.291 and § 82.293.
Precedent establishes suspension of Respondent's license as an appropriate form of discipline due to the nature and circumstances of the criminal behavior for which Respondent was convicted. See In re Anonymous No. 22 DB 89, 2 4 Pa. D. & C.4th 354 (1995). In In re Anonymous No. 22 DB 89, the respondent was driving his vehicle at a speed in excess of the posted limit when he struck two pedestrians and fled the scene without stopping and rendering aid. The respondent then abandoned the vehicle in another state after removing the license plate. The two pedestrians died as a result of the collision. The respondent was tried and found guilty on two counts of homicide by vehicle and two counts of accidents involving death or personal injury (75 Pa.C.S. §3742), and received consecutive sentences which included serving eleven and one half months to two and one half years in county prison. In its recommendation to the Pennsylvania Supreme Court, the Disciplinary Board found in that matter that the respondent had violated Rule of Professional Conduct 8.4(b) by "failing to fulfill his legal obligation to stop at or near the accident scene and render assistance to the other parties, and attempting to conceal his involvement in the collision." Respondent had no history of discipline. The Pennsylvania Supreme Court accepted the recommendation of the Disciplinary Board and ordered that the respondent's license be suspended for four years.
Justices Papadakos and Castille dissented.
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The facts presented here are similar to those presented in In re Anonymous No. 22 DB 89, such that they support the appropriateness of public discipline in the form of a suspension. Respondent struck a pedestrian, fled the scene without notifying authorities, and obscured his damaged vehicle in a closed garage. Though Respondent allowed detectives into his home and garage and released the vehicle involved in the accident, Respondent took no steps at any time following the accident to report his involvement to authorities. As a result, Respondent was convicted of violating 75 Pa.C.S.A. §3742. Under the circumstances of this case, Respondent's violation of 75 Pa.C.S.A, §3742 was graded a misdemeanor of the first degree because it did not involve death or serious bodily injury. Respondent admits that his conduct adversely reflected upon his honesty, trustworthiness, or fitness, to practice law and acknowledges that the misconduct is aggravated by the position Respondent held as a prosecutor at the time he committed the crime. See ODC v. Cappuccio, 48 A.3d 1231, 1241 (Pa. 2012).
This case, however, is distinguishable from In re Anonymous No. 22 DB 89, in a key respect. This case involves a victim who fortunately was not killed as a result of the collision and suffered bodily injury not found by the jury to have been "serious bodily injury." Respondent's crime qualified as a misdemeanor of the first degree in marked contrast to the series of felony convictions addressed in In re Anonymous No. 22 DB 89. As such, a lengthy suspension is not required. A suspension for at least some period of time, however, is required to best serve the interests of both the public and the bar because Respondent betrayed the faith and trust of the public through his violation of the laws he was charged with prosecuting.
Considering all of the circumstances, ODC and Respondent recommend a one-year suspension, eight months stayed and four months to be served, accompanied by a one-year period of substance abuse probation governed by Disciplinary Board Rules §89.291 and §82.293. A violation of the terms of probation would be grounds for further action pursuant to Enforcement Rule 208(h).
WHEREFORE, ODC and Respondent respectfully pray that Your Honorable Board:
A. Approve this Joint Petition.
B. File with the Supreme Court of Pennsylvania a recommendation that the Supreme Court enter an Order imposing a one-year suspension, eight months stayed and four months to be served, accompanied by one year of probation subject to the following conditions:
1. Respondent shall abstain from using alcohol, drugs, or any other mood-altering or mind-altering chemicals;
2. Respondent shall regularly attend meetings of Alcoholics Anonymous on a weekly basis;
3. Respondent shall obtain a sponsor in Alcoholics Anonymous and maintain weekly contact with that sponsor;
4. A sobriety monitor shall be appointed to monitor Respondent in accordance with Disciplinary Board Rule § 89.293(c);
5. Respondent shall furnish his sobriety monitor with his Alcoholics Anonymous sponsor's name, address and telephone number;
6. Respondent shall establish his weekly attendance at Alcoholics Anonymous meetings by providing written verification on a Board approved form to the Board;
7. Respondent shall undergo any counseling, outpatient or in-patient treatment, prescribed by a physician or alcohol counselor;
8. Respondent shall file with the Secretary of the Board quarterly written reports;
9. With the sobriety monitor, Respondent shall:
(a) Meet at least twice a month;
(b) Maintain weekly telephone contact;
(c) Provide the necessary properly executed written authorizations to verify his compliance with the required substance abuse treatment; and
(d) Cooperate fully.
10. The appointed sobriety monitor shall:
(a) Monitor Respondent's compliance with the terms and conditions of the order imposing probation;
(b) Assist Respondent in arranging any necessary professional or substance abuse treatment;
(c) Meet with Respondent at least twice a month, and maintain weekly telephone contact with Respondent;
(d) Maintain direct monthly contact with Respondent's Alcoholics Anonymous sponsor;
(e) File with the Secretary to the Board quarterly written reports; and
(f) Immediately report to the Secretary to the Board any violations by the Respondent of the terms and conditions of the probation.
C. Enter an order for Respondent to pay all necessary expenses incurred in the investigation and prosecution of this matter as a condition to the grant of the Petition, pursuant to Enforcement Rule 215(1).
Respectfully submitted,
OFFICE OF DISCIPLINARY COUNSEL
PAUL J. KILLION,
Chief Disciplinary Counsel
BY: _______________
BARBARA BRIGHAM DENYS
Disciplinary Counsel
District II Office
Attorney Registration No. 78562
BY: __________
MICHAEL JAMES DONOHUE
Respondent
BY: __________
ROBERT E. J. CURRAN, ESQUIRE
Attorney for Respondent
VERIFICATION
The statements contained in the foregoing Joint Petition In Support of Discipline on Consent are true and correct to the best of ray knowledge or information and belief and are made subject zo the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities.
BY: __________
BARBARA BRIGHAM DENYS,
Disciplinary Counsel
BY: __________
MICHAEL JAMES DONOHUE,
Respondent
BY: __________
ROBERT E. J. CURRAN, ESQUIRE
Attorney for Respondent
OFFICE OF DISCIPLINARY COUNSEL, Petitioner
v. MICHAEL JAMES DONOHUE, Respondent
No. 136 DB 2013
Board File No. C2-12-1032
Attorney Reg. No. 95048
(Delaware County)
AFFIDAVIT
UNDER RULE 215 (d) Pa.R.D.E.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DELAWARE
MICHAEL JAMES DONOHUE, being duly sworn according to law, deposes and hereby submits this affidavit in support of the Joint Petition in Support of Discipline on Consent Pursuant to Pa.R.D.E. 215(d), and and further states as follows:
1. He desires to submit a Joint Petition in Support of Discipline on Consent ("Joint Petition") pursuant to Pa.R.D.E. 215(d).
2. His consent is freely and voluntarily rendered; he is not being subjected to coercion or duress, and he is fully aware of the implications of submitting the consent.
3. He is fully aware of his right to consult and employ counsel to represent him in the instant proceeding. He has retained, consulted and acted upon the advice of counsel, Robert
Exhibit A
E. J. Curran, Esquire, in connection with his decision no consent to discipline.
4. He is aware that there is presently pending an investigation into allegations that he has been guilty of misconduct as set forth in the Joint Petition.
5. He acknowledges that the material facts set forth in the Joint Petition are true.
6. He consents because he knows that if charges predicated upon the matter under investigation were filed, or continued to be prosecuted in the pending proceeding, he could not successfully defend against them.
It is understood that the statements made herein are subject to the penalties of 18 Pa.C.S.A. §4904 (relating to unsworn falsification to authorities).
_______________
MICHAEL JAMES DONOHUE
Sworn to and subscribed before me this 6th day of November 2013 _______________
Notary Public
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
ANNE E. LAURENCE, Notary Public
Haverford Twp., Delaware County
My Commission Expires April 10, 2015
OFFICE OF DISCIPLINARY COUNSEL, Petitioner
v. MICHAEL JAMES DONOHUE, Respondent
No. 136 DB 2013
Board File No. C2-12-1032
Attorney Reg. No. 95048
(Delaware County)
CERTIFICATE OF SERVICE
i hereby certify that i am this day serving the foregoing document upon all parties of record in this proceeding in accordance with the requirements of 204 Pa. Code §89,22 (relating to service by a participant).
First Class Mail, as follows:
Robert E. J. Curran, Esquire
P.O. Box 30
8 West Front Street
Media, PA 190 63
BY: __________
BARBARA BRIGHAM DENYS
Disciplinary Counsel
District II Office
Attorney Registration No. 78562
Suite 170, 820 Adams Avenue
Trooper, PA 19403
(610) 650-8210