Law Offices of Sumner Lipman, LLC v. Rapelye

CourtSuperior Court of Maine
DecidedMarch 22, 2021
DocketCUMcv-20-250
StatusUnpublished

This text of Law Offices of Sumner Lipman, LLC v. Rapelye (Law Offices of Sumner Lipman, LLC v. Rapelye) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Law Offices of Sumner Lipman, LLC v. Rapelye, (Me. Super. Ct. 2021).

Opinion

(

STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss CIVIL ACTION DOCKET NO CV-20-250 \

LAW OFFICES OF SUMNER LIPMAN, LLC, Plaintiff V. ORDER

MARY LINDA RAP ELYE, Defendant V.

SUMNER LIPMAN, ESQ., et al., Third-Party Defendants

Before the court are three motions: (1) a motion by Sumner Lipman, Esq., Lipman &

Katz, P.A., and Law Offices of Sumner Lipman LLC to disqualify Attorney Jeffrey Bennett

from representing Mary Linda Rapelye , (2) a motion by third party defendant Trafton

Matzen Belleau & Frenette LLP to dismiss counts I and IV- VII of the third party complaint

as against Trafton Matzen., and (3) a motion by Rapelye to amend her third-part complaint

as against Trafton Matzen.

The court heard oral argument on March 15, 2021.1

At the outset, as the court suggested to counsel at the March 15 hearing, it appears

that Sumner Lipman, Esq., Lipman & Katz, P.A., and Trafton Matzen are more properly

considered as additional parties on Rapelye's counterclaim pursuant to M.R.Civ.P. 13(h)

than as third-party defendants. It is the court's understanding that at the hearing none of

the parties objected to reconfiguration of the status of those parties as additional

1 Like many cases, this case has been delayed by the pandemic. Although the motion to disqualify was fully briefed by October 21, 2020 and the motions relating to the claims against Trafton Matzen were fully briefed by November 16, 2020, the court has had almost no time in the ensuing period to devote to civil proceedings due to the pandemic and the need to focus on criminal cases. counterclaim defendants. If that is incorrect or if counsel have had any second thoughts,

they should notify the court. In this order, the Law Offices of Sumner Lipman LLC, Sumner Lipman, Esq., and

Lipman & Katz, P.A. will be referred to as the "Lipman parties."

Motion to Disqualify

At this time, the Lipman parties' motion to disqualify Attorney Bennett is denied

without prejudice to renewal for the reasons set forth on the record at the March 15

hearing and in this order.

Under Morin v. Maine Educational Association, 2010 ME 36 ,r,r 9-10, 993 A.2d 1097,

a party moving to disqualify an opponent's attorney must show that there is or will be an

affirmative violation of the ethics rules and that the violation will result in actual prejudice

to the party seeking disqualification. 2 In this case an ethical violation will occur if Attorney

Bennett represents Rapelye at a trial in which he is likely to be a necessary witness. M.R.

Prof. Conduct 3.7.

There is an exception under Rule 3.7 if disqualification would work a substantial

hardship on the client. Attorney Bennett argues that lawyers would be reluctant to replace

him because of general unwillingness to pursue legal malpractice claims, perhaps

especially against a lawyer of Lipman's prominence. However, the court is aware that there

are lawyers who are willing to prosecute such claims.

In addition, although Morin requires a showing of actual prejudice, prejudice will

exist in this case if Attorney Bennett is both an ·advocate and a witness at trial because of

2 That showing is required because of the possibility that disqualification motions will be abused for tactical reasons. 2010 ME 36 ,r,r 8'9.

2 the confusion that will exist between his dual roles as a witness testifying under oath from

personal knowledge and an advocate characterizing the facts in the manner most helpful to

his client. See Comments [1] and [2] to Rule 3.7. 3 In the court's view, therefore, the

outcome of the motion to disqualify will depend on whether the Lipman parties are correct

that Attorney Bennett will be a necessary witness.

Attorney Bennett states that he will not be called as a witness for Rapelye and that

the fact that he was not representing Rapelye during the relevant time period is clearly

established in an exchange of emails. The Lipman parties, however, state that they

anticipate calling Attorney Bennett as a witness because they believe his testimony will

support an argument that, after the Lipman parties informed Ms. Rapelye that they were

going to seek to withdraw from representing her in a pending probate proceeding, she and

Attorney Bennett had enough time to protect her interests. 4

At this point the court cannot determine that Attorney Bennett is likely to be a

necessary witness. However, there is certainly a possibility that on a more complete record

he may be found to be a necessary witness.

Future discovery will presumably shed light on the extent to which the argument

made by the Lipman parties is viable and whether Attorney Bennett is potentially a

necessary witness. The court understands that this will also certainly involve a dispute as

to whether Attorney Bennett's communications with Rapelye during the relevant time

3 As Comment [3] to Rule 3. 7 points out, the issue of prejudice may depend to some extent on

whether a bench or jury trial is involved.

4 Attorney Bennett points out that on January 6, 2020 he wrote an email stating that he was not yet

in the case. He and his firm did appear in the probate proceeding for Rapelye at a later point. Exactly when he accepted the case and whether he did so in time to take action before the discovery deadline is unclear and may be disputed.

3 period are privileged - an issue on which the parties disagree and which it is premature for

the court to consider at this point. Further information may also be available on such

subjects as the date when Attorney Bennett accepted Rapelye's case, on what actions

Rapelye took in response to the Lipman parties' motion to withdraw, and on whether, if

testimony from Legal-Ease is needed, testimony from Attorney Glass instead of from

Attorney Bennett would suffice.

Trafton Matzen's Motion to Dismiss

Trafton Matzen's motion to dismiss counts I and IV-VII of the claims against Trafton

Matzen and Rapelye's motion to file a second amended complaint against Trafton Matzen

will be considered together. Rapelye's motion to amend states that it was filed to cure

potential deficiencies in counts I, IV, VI, and VII in her prior pleading, and Trafton Matzen

argues that the deficiencies in those counts have not been cured.s

For purposes of a motion to dismiss, the material allegations of the complaint must

be taken as admitted. Ramsey v. Baxter Title Co., 2012 ME 113 ,r 2, 54 A.3d 710. The

complaint must be read in the light most favorable to the plaintiff to determine if it sets

forth elements of a cause of action or alleges facts that would entitle plaintiff to relief

pursuant to some legal theory. Bisson v. Hannaford Bros. Co., Inc., 2006 ME 131 ,r 2, 909

A.2d 1010. Dismissal is appropriate only when it appears beyond doubt that the plaintiff is

not entitled to relief under any set of facts that she might prove in support of her claim.

5 In her proposed second amended third party complaint, Rap el ye has withdrawn her defamation claim as against Trafton Matzen, and the defamation claim in Count V of the first amended third party complaint is therefore dismissed as against Trafton Matzen.

4 Moody v. State Liquor & Lottery Commission, 2004 ME 20 ,r 7, 843 A.2d 43. However, a

plaintiff may not proceed if the complaint fails to allege essential elements of the cause of

action or is legally unavailing. See Potter, Prescott, Jamieson & Nelson P.A. v. Campbell, 1998

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Related

Moody v. State Liquor & Lottery Commission
2004 ME 20 (Supreme Judicial Court of Maine, 2004)
Morin v. Maine Education Ass'n
2010 ME 36 (Supreme Judicial Court of Maine, 2010)
Bisson v. HANNAFORD BROTHERS COMPANY, INC.
2006 ME 131 (Supreme Judicial Court of Maine, 2006)
Potter, Prescott, Jamieson & Nelson, P.A. v. Campbell
1998 ME 70 (Supreme Judicial Court of Maine, 1998)
Garland v. Roy
2009 ME 86 (Supreme Judicial Court of Maine, 2009)
Ramsey v. Baxter Title Co.
2012 ME 113 (Supreme Judicial Court of Maine, 2012)

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Law Offices of Sumner Lipman, LLC v. Rapelye, Counsel Stack Legal Research, https://law.counselstack.com/opinion/law-offices-of-sumner-lipman-llc-v-rapelye-mesuperct-2021.