Bowler v. Alcazar; Costanzo v. Alcazar
Rule 1.15(e) provides that lawyers must promptly deliver, to clients and third parties, any funds that the clients and third parties are entitled to receive. A local grievance panel found probable cause that the respondent attorney violated Rules 1.15(b)(d)(e) and 8.4(4) of the Rules of Professional Conduct. The respondent, Ramiro Alcazar, was admitted to the practice of law in Connecticut in December 2002 and has no prior history of discipline. The respondent, who was represented by Attorney William Dow, waived his right to a full evidentiary hearing. He admitted that he commingled personal and client funds, in violation of Rule 1.15(b), and that he failed to promptly deliver funds to a complainant, in violation of Rule 1.15(e). Rule 1.15(e) provides, "Except as stated in this Rule or otherwise permitted by law or by agreement with the client or third person, a lawyer shall promptly deliver to the client or third person any funds or other property that the client or third person is entitled to receive and, upon request by the client or third person, shall promptly render a full accounting regarding such property." The Statewide Grievance Committee reprimanded the respondent attorney and ordered the respondent to hire a bookkeeper and to submit to quarterly audits.