In re Paul

CourtDistrict of Columbia Court of Appeals
DecidedApril 20, 2023
Docket22-BG-0457
StatusPublished

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In re Paul, (D.C. 2023).

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 22-BG-457

IN RE DANA A. PAUL, RESPONDENT.

A Member of the Bar of the District of Columbia (Bar Registration No. 490142)

On Report and Recommendation of the Board on Professional Responsibility (Disciplinary Docket No. 2019-D199) (Board Docket No. 19-BD-63)

(Submitted January 24, 2023 Decided April 20, 2023)

Dana A. Paul, pro se.

Hamilton P. Fox and Myles V. Lynk were on the brief for the Office of Disciplinary Counsel.

Before HOWARD and ALIKHAN, Associate Judges, and FISHER, Senior Judge.

ALIKHAN, Associate Judge: After respondent Dana A. Paul disclosed client

confidences in a disciplinary complaint that he filed against his former client, N.E.,

the District of Columbia Office of Disciplinary Counsel investigated him for

violating multiple District of Columbia Rules of Professional Conduct. The Board

on Professional Responsibility concluded that he had violated D.C. R. Prof.

Conduct 1.6(a) and recommended that we impose a 90-day suspension. Before this 2

court, Mr. Paul argues that D.C. Bar R. XI, § 19(a) immunizes him from disciplinary

action stemming from his complaint, that his disclosures do not fall under Rule 1.6’s

protections and were necessary to defend himself against an earlier disciplinary

action that N.E. had filed against him, and that the Board’s recommended 90-day

suspension was unwarranted. We disagree that he is immune from discipline,

conclude that he violated Rule 1.6(a), and order a 30-day suspension.

I. Factual Background and Procedural History

A. Factual Background

The Hearing Committee and the Board made the following findings of fact,

most of which are undisputed. In 2014 and 2015, Mr. Paul, a member of the D.C.

Bar, represented N.E. and her husband in a matter in a Maryland court. He

represented them again in 2017 when they sued their realtor and others, also in a

Maryland court, alleging a “botched” real estate deal.

Mr. Paul and his clients began to disagree about the case, and, a few months

later, he resigned. In April 2018, N.E. and her husband reported Mr. Paul to the

Attorney Grievance Commission of Maryland and the District of Columbia Office

of Disciplinary Counsel. They alleged that he had improperly retained an expert

witness, had failed to communicate with N.E. and her husband, had not prepared

them for depositions, and had entered unauthorized stipulations on their behalf. 3

In May 2018, Mr. Paul responded to both complaints. In his response to

N.E.’s complaint in the District and at Disciplinary Counsel’s request, Mr. Paul

submitted his entire client file for N.E. Three months later, while Disciplinary

Counsel was investigating N.E.’s complaint against Mr. Paul, he filed a disciplinary

complaint against N.E., who is also a member of the D.C. Bar. Mr. Paul included

the case number of the matter against him in his disciplinary complaint, and he

disclosed information that N.E. had shared with him when he was her attorney. The

Office of Disciplinary Counsel eventually dismissed N.E.’s complaint against

Mr. Paul and requested that N.E. respond to Mr. Paul’s complaint against her. After

N.E. responded, Mr. Paul replied, noting: “I am only filing this grievance because

of the grievance [N.E.] filed against me.” In his reply, Mr. Paul included additional

information that he had learned during his 2017 representation of N.E. and her

husband.

B. Procedural History

In June 2022, the Office of Disciplinary Counsel instituted disciplinary

proceedings against Mr. Paul, alleging that he had violated D.C. R. Prof. Conduct 1.6

and 8.4(d). First, the Office of Disciplinary Counsel alleged that in his response to

N.E.’s grievance, his disciplinary complaint against N.E., and his reply to N.E.’s

response, Mr. Paul had disclosed client confidences or secrets, which had been

unnecessary to establish a defense to the disciplinary charge against him and 4

therefore violated Rule 1.6. Second, it alleged that Mr. Paul’s retaliatory disciplinary

complaint against N.E. seriously interfered with the administration of justice in

violation of Rule 8.4(d).

After a hearing in March 2020, an Ad Hoc Hearing Committee concluded that

Mr. Paul had violated both rules and recommended that he receive a 90-day

suspension. As to Rule 1.6, the Hearing Committee determined that Mr. Paul had

knowingly revealed N.E.’s confidences when he intentionally gave private

information about her—information he only knew because he had represented her—

to Disciplinary Counsel. It reached this conclusion only with respect to Mr. Paul’s

disciplinary complaint against N.E. and his subsequent reply in that matter, finding

that those disclosures were offensive (rather than defensive) in nature and not

reasonably necessary for Mr. Paul to defend himself against N.E.’s accusations. The

Hearing Committee did not find a Rule 1.6 violation with regard to the disclosures

that Mr. Paul had made in response to N.E.’s complaint against him, concluding that

those were necessary for him to defend himself. See D.C. R. Prof. Conduct 1.6(e)(3)

(allowing reasonable disclosures to defend against a disciplinary action).

As to Rule 8.4(d), the Hearing Committee concluded that Mr. Paul’s retaliatory

complaint seriously interfered with the administration of justice because it was

improper, bore directly on the judicial process, and affected the process “in more 5

than a de minimis way.” In re Hopkins, 677 A.2d 55, 61 (D.C. 1996). The Hearing

Committee recommended a 90-day suspension after considering (1) the seriousness

of Mr. Paul’s conduct; (2) prejudice to the client; (3) whether the conduct involved

dishonesty; (4) violation of other disciplinary rules; (5) Mr. Paul’s disciplinary

history; (6) whether Mr. Paul had acknowledged his wrongful conduct; and

(7) mitigating circumstances. See In re Daniel, 11 A.3d 291, 300 (D.C. 2011).

Mr. Paul filed exceptions to each of these conclusions. In June 2022, the

Board issued its report and recommendation. The Board agreed with the Hearing

Committee’s conclusion that Mr. Paul had violated Rule 1.6 when he disclosed

N.E.’s confidences in his complaint against N.E. and his subsequent reply in that

matter. The Board also determined that D.C. Bar. R. XI, § 19(a) did not provide Mr.

Paul absolute immunity from attorney discipline—as opposed to civil liability—for

complaints submitted to Disciplinary Counsel, because such immunity was not

consistent with the plain text of the rule, and because a contrary reading would

conflict with other D.C. Rules of Professional Conduct. Finally, the Board

concluded that Mr. Paul had not violated Rule 8.4(d) because his conduct did not

impact the judicial system “in more than a de minimis way.” In re Hopkins, 677

A.2d at 61. 6

Despite finding fewer violations than the Hearing Committee, the Board

adopted the Hearing Committee’s recommendation of a 90-day suspension. In so

doing, it explained that Mr. Paul’s disciplinary complaint against N.E.

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