Description: |
Erick A. Sabo (WSBA No. 24008, admitted 1994), of Port Ludlow, was ordered to receive a reprimand following approval of a stipulation by a hearing officer on August 9, 2011. This discipline is based on conduct involving failure to provide competent representation, failure to act with reasonable diligence in a client matter, and engaging in dishonest conduct.
Between March 2000 and July 2009, Mr. Sabo allowed a client to send out thousands of form collection letters on his letterhead bearing what appeared to be, but was not, his signature. Those letters contained statements of material fact that Mr. Sabo knew to be false and misleading. Mr. Sabo knowingly approved of the form collection letters and authorized the manner in which they were used by the client, but he failed to determine and to advise the client that the use of those letters could subject the client to liability under the Fair Debt Collection Practices Act.
Mr. Sabo’s conduct violated RPC 1.1, requiring a lawyer to provide competent representation to a client; RPC 1.3, requiring the lawyer to act with reasonable diligence and promptness in representing a client; RPC 8.4(a), prohibiting a lawyer from violating or attempting to violate the Rules of Professional Conduct, or knowingly assisting or inducing another to do so, or doing so through the acts of another; and RPC 8.4(c), prohibiting a lawyer from engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation. Scott G. Busby represented the Bar Association.
Mr. Sabo represented himself. Timothy J. Parker was the hearing officer. |