A lawyer can engage in the practice of law when the lawyer reviews a client's file, even if the lawyer never meets or speaks to the client. In 2008, Dawn Colonni, a Connecticut resident, contacted a debt management company and was referred to Persels & Associates, a law firm in Maryland. Persels & Associates provided Colonni with a retainer contract. Allegedly, Heidi Saas, a Connecticut attorney, reviewed Colonni's file and left a voice mail message, indicating that she worked as an attorney at Persels & Associates and would handle Colonni's matter. They did not meet or speak, although Colonni allegedly called Saas back and left messages. In or about May 2009, a paralegal at Persels & Associates negotiated a settlement. Saas allegedly reviewed and approved the proposed settlement. In 2010, a local grievance panel in Connecticut found probable cause that Attorney Saas violated Practice Book §2-27, which governs IOLTA accounts, and Rules 1.5(b) and 5.5 of the Rules of Professional Conduct. In 2011, Connecticut's Statewide Grievance Committee found that there was no evidence that Saas supervised the paralegal or reviewed the settlement contract, and that her routine review of the file did not constitute the practice of law. The Statewide Grievance Committee ordered that Attorney Saas take a continuing legal education course, because she permitted Persels & Associates to practice law in Connecticut when she provided her name as local counsel, in violation of Rule 5.5. Saas appealed. Rule 5.5 provides, "A lawyer shall not practice law in a jurisdiction in violation of the regulation of the legal profession in that jurisdiction, or assist another in doing so." The court found that because Saas applied legal judgment when she reviewed Colonni's matter, she practiced law, and there was no violation of Rule 5.5 when she permitted Persels to use her name in order to serve a client in Connecticut. Because Saas practiced law, the real question was whether she failed to supervise the Persels paralegal, in violation of Rule 5.3. The court remanded, to permit Connecticut disciplinary counsel and the Statewide Grievance Committee to consider whether Saas violated Rule 5.3.

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