Ragusin, Andrew, 10 Sa 67032811

COloradO Supreme Court
101 West Colfax Avenue, Suite 800

Denver, CO 80202
'
Original Proceeding in Unauthorized Practice of Law 29 zon
09UPL116, 09UPL127, 09UPL128, 09UPL140, 09UPL142,
lOUPL2, and 10UPL7
, Petitioner:
The People of the State of Colorado, Supreme Court Case No:

201OSA67
v.
Respondents:,
T. Andrew Ragusin and Ragusin International Association,

LLC.
Upon consideration of Petitioner's Motion to Proceed, Petitioner's
Withdrawal of Motion to Proceed, and the Stipulation, Agreement and Affidavit
Consenting to a Finding of, and Entry of an Order Regarding Contempt as to Tullio
Andrew Ragusin, and Entry of an Order of Injunction as to Ragusin International
Association, LLC filed in the above cause, and now being sufficiently advised in
the premises,
IT IS ORDERED that said Request to Withdraw Motion to Proceed shall be,
and the same hereby is, GRANTED.

,
IT IS FURTHER ORDERED that said Stipulation, Agreement and Affidavit
is APPROVED. Respondent, T. ANDREW RAGUSIN is found in Contempt of
the March 7, 2005 Order of Injunction.
IT IS FURTHER ORDERED that T. ANDREW RAGUSIN is ordered to
pay restitution in the amount of $590,000 in accordance with the sentence entered
on August 27,2010 by Judge Bronfin in the consolidated criminal cases, plus
statutory interest accruing from August 27,2010, to date of payment; and that T.
ANDREW RAGUSIN is ordered to pay a fine of$5000.00 within one year from
the date of this order.
IT IS FURTHER ORDERED that RAGUSIN INTERNATIONAL is
ENJOINED from engaging in the unauthorized practice of law in the State of
Colorado.
IT IS FURTHER ORDERED that RAGUSIN INTERNATIONAL is
assessed costs in the amount of $3030.26. Said costs to be paid to the Office of
Attorney Regulation Counsel within one year from the date of this order.
BY THE COURT, MARCH 28, 2011.

Case Number: 2010SA67
Caption: People v Ragusin, T.
CERTIFICATE OF SERVICE
Copies mailed via the State's Mail Services Division on March 28, 2011 r-
Kim E Ikeler Ragusin International Association,
OFFICE OF ATTORNEY LLC
REGULATION 9564 Kalamere Court
1560 Broadway Ste 1800 Littleton, CO 80126
Denver, CO 80202
T. A Ragusin T. A Ragusin
151368 6281 S. Netherland Way
Skyline Correctional Center Aurora, CO 80016
P.O. Box 300
Canon City, CO 81215
i SUPREME COURT, STATE OF COLORADO
2 East 14 th Avenue, 4 th Floor
Denver, Colorado 80203
I ORIGINAL PROCEEDING IN THE

I UNAUTHORIZED PRACTICE OF LAW, I
109UPL127,09UPL140,09UPL142, I
09UPL116, 10UPL002, 10UPL007, I
! 09UPL128 ! I
, ~._~~~~_~_".___.__~~____~~_._______.' A. COURT USE ONLY A. I
I P e t i t i o n e r : _ 1I
THE PEOPLE OF THE STATE OF' I Case No: 10SA0067
I COLORADO I
I Respondent:
I T. ANDREW RAGUSIN and RAGUSIN
I INTERNATIONAL ASSOCIATION, LLC
I ."'--,---.
I Kim E. Ikeler, # 15590
I Assistant Regulation Counsel
1560 Broadway, Suite 1800
I Denver, CO 80202
I Telephone: (303) 866-6440
I Fax No.: (303) 893-5302
I E-Mail Address:[email protected]
I Attorney for Petitioner
I Tullio Andrew Ragusin

-DOC #151368
CMC - Skyline Correctional Center - C20
P.O. Box 300
Pro se
I STIPULATION, AGREEMENT AND AFFIDAVIT CONSENTING TO A'
FINDING OF, AND ENTRY OF AN ORDER REGARDING,
CONTEMPT AS TO TULLIO ANDREW RAGUSIN, AND ENTRY OF
AN ORDER OF INJUNCTION AS TO RAGUSIN INTERNATIONAL
~ _________________A_S_S_O_C_U\TION,LLC
~
On this day of ~ 2011, Kim E. Ikeler, Assistant
Regulation Counsel; and respondent Tullio Andrew Ragusin
("Ragusin"), enter into the following stipulation, agreement, and
affidavit consenting to a finding of, and order regarding, contempt
("stipulation") and submit the same to the Colorado Supreme Court
for a finding and order of contempt pursuant to C.R.C.P. 238-239.
Assistant Regulation Counsel Ikeler and Ragusin, as principal of
respondent Ragusin International Association, LLC ("Ragusin
International"), enter into a stipulation, agreement and affidavit
consenting to an order of injunction ("stipulation") and submit the
same to the Colorado Supreme Court for a finding and order of
injunction pursuant to C.R.C.P. 229-237.
1. Ragusin's address is CMC - Skyline Correctional Center -
C20, P.O. Box 300, Canon City, CO 81215. Ragusin is not licensed
to practice law in the State of Colorado or any other State of the
United States. Ragusin is not licensed to practice law in any other
country in the world. In particular, Ragusin is not licensed to
2
practice in the Netherlands, Luxembourg, Belgium, Austria, Italy
(Milan district, Veneto region, Toscana region, Puglia region,
Marsala district or Trapani district) or the Seychelles Islands.
2. Ragusin International is a delinquent Colorado limited
liability company. Ragusin International's last known address is
9564 Kalamere Court, Highlands Ranch, CO 80126. Ragusin
operated Ragusin International until his incarceration.
3. Respondents enter into this stipulation freely and
voluntarily. No promises have been made concerning future
consideration, punishment, or lenience in the above-referenced
matter. It is respondents' personal decision, and respondents
affirm there has been no coercion or other intimidating acts by any
person or agency concerning this matter.
4. Respondents are familiar with the rules of the Colorado
Supreme Court regarding the unauthorized practice of law.
Respondents acknowledge the right to a full and complete
evidentiary hearing on the above-referenced petition for contempt
and for entry of an order of injunction. At any such hearing,
respondents would have the right to be represented by counsel,
present evidence, call witnesses, and cross-examine the witnesses

presented by the petitioner. At any such formal hearing, the
petitioner would have the burden of proof and would be required to
prove the charges contained in the petition for contempt beyond a
reasonable doubt. Petitioner would be required to prove that
Ragusin International engaged in the unauthorized practice of law
by a preponderance of the evidence. Nonetheless, having full
knowledge of the right to such a formal hearing, respondents waive
that right.
5. Respondents and the petitioner stipulate to the following
facts and conclusions:
a. On March 7, 2005, Ragusin was permanently enjoined from
engaging in the unauthorized practice of law by the Colorado
Supreme Court. People v. T. Andrew Ragusin, 05SA70. The
March 7, 2005 Order of Injunction was a lawful order of the
Colorado Supreme Court.
b. Ragusin knew of the March 7, 2005, Order of Injunction,
including because he executed a stipulation for its entry.l A
copy of the Order of Injunction was mailed to Ragusin on
March 9, 2005. Ragusin also participated in a subsequent
I Ragusin's counsel, Michael Berger, Esq., also signed the stipulation.
4
matter in 2006, during which he acknowledged the stipulation
and his obligations thereunder.
c. Ragusin had the ability to comply with the March 7, 2005,
Order of Injunction issued by the Colorado Supreme Court.
Ragusin was only required by such order to stop engaging in
the unauthorized practice of law.
d. Ragusin willfully and repeatedly refused to comply with the
March 7, 2005, Order of Injunction, as described in detail in
the Claims set forth in the Petition for Contempt Citation and
Injunction filed in this case ("Petition" - a copy is attached
hereto as Exhibit A).
e. Ragusin - who is not a licensed attorney - and Ragusin
International held themselves out to members of the public as
being able to provide legal advice on international and
Colorado legal matters. Ragusin, and Ragusin International in
the person of Ragusin, provided legal advice to residents of
Colorado and a neighboring state. Ragusin, and Ragusin
International in the person of Ragusin, selected and prepared
legal documents for residents of Colorado and a neighboring
state. Ragusin, and Ragusin International in the person of

Ragusin, represented themselves as legal counsel to third
parties. Ragusin's and Ragusin International's victims
included Shannon Friel, Francesco Dorigo, Lee Ann Reynolds,
Robert Reynolds, Sandra Lemire, Josephine DeGaetano,
Rebecca Wiard, Catherine Harvey, Jan Schorr, and Albert
Rivera. See the Petition, Exhibit A hereto, pp. 6-55.
f. In addition to being the subject of this contempt proceeding,
Ragusin was arrested and charged with crimes by the Denver
District Attorney's Office. People v. Tullio Andrew Ragusin,
Denver County Court, Case No. 10CR381. The Complaint and
Information filed in that case charged Ragusin with criminal
impersonation in violation of C.R.S. §18-5-113(1)(e), a class 6
felony; theft in violation of C.R.S. §18-4-401(1) and (4), a class
4 felony; and theft in violation of C.R.S. §18-4-40 1 (1) and (4), a
class 3 felony. In a second case, People v. Tullio Andrew
Ragusin, Denver District Court, Case No. 10CR1322, Ragusin
was similarly charged with 18 counts of criminal
impersonation and theft. Hereinafter, Case No. 10CR381 and
IOCR 1322 are referred to collectively as the "consolidated
6
criminal cases". Ragusin pled guilty to two counts of felony
theft. 2
g. On August 27, 2010, the Honorable Edward D. Bronfin
sentenced Ragusin in the consolidated criminal cases. The
Judge sentenced Ragusin to ten years in the Department of
Corrections, followed by five years of parole. The Judge also
ordered Ragusin to pay $590,000 in restitution to his victims.
6. Pursuant to C.R.C.P. 237(a), respondent Ragusin
International agrees to pay the costs and administrative costs in the
sum of $3,030.26 incurred in conjunction with this matter within
one year after the acceptance of the stipulation by the Colorado
Supreme Court, made payable to Colorado Supreme Court Attorney
Regulation Offices. A copy of the statement of costs in this matter
is attached as Exhibit B.
7. Ragusin and Ragusin International expressly and
specifically agree that they are not permitted to practice law in the
State of Colorado, and that doing so would be in violation of the
Orders of the Colorado Supreme Court. People v. Bauer, 80 P.3d
896, 898 (Colo. App. 2003).
2 As part of a plea bargain, many of the counts were dismissed.
7
RECOMMENDATION FOR AND CONSENT TO ORDER OF
CONTEMPT
Based on the foregoing, the parties hereto recommend that an
order be entered finding Ragusin in contempt of the March 7, 2005
order of injunction; that Ragusin be ordered to pay restitution of
$590,000 in accordance with the sentence entered on August 27,
2010 by Judge Bronfin in the consolidated criminal cases,3 plus
statutory interest accruing from August 27, 2010, to date of
payment; and that Ragusin be required to pay a fine of $5,000
within one year following the acceptance of this stipulation by the
Colorado Supreme Court.
The parties further recommend that an order enter as to
Ragusin International, enjoining it from the unauthorized practice
of law, and requiring Ragusin International to pay costs of
$3,030.26 within one year following the acceptance of this
stipulation by the Colorado Supreme Court.
3Payment of the $590,000 of restitution ordered in consolidated criminal cases will

satisfy the restitution requirement in the within case.
Tullio Andrew Ragusin, individually and as the principal of
Ragusin International, and petitioner's attorney, Kim E. Ikeler,
acknowledge by signing this document that they have read and
reviewed the above.

-,
/:/
; >' //'" ,-,,-
_ ./ , __"/ ____( ~;,// . i1)4tCJ; ( -( 20 (I

tespondent TuUi6' Andrew Ragusi:n,
individually and as principal of
Ragusin International Association,
LLC
CMC - Skyline Correctional Center
C20
STATE OF COLORADO )
) ss.
COUNTY OF FREMONT ) ,
IJ;/vv.~
Subscribed and sworn to before me this - f - l - - day of .JaOOat=¥
2011, by Tullio Andrew Ragusin, known to Witness my hand
and official seal. My commission expires: ----+---+...,,-:z:---""'-~_--=~
Kim E. Ikeler
Assistant Regulation Counsel
Phone Number: (303) 866-6440
Attorney for Petitioner
Q
) )
SUPREME COURT, STATE OF COLORADO

2 East 14th Avenue, 4th Floor
Denver, Colorado 80203 :In
ORIGINAL PROCEEDING IN
UNAUTHORIZED PRACTICE OF LAW,
,
09UPL127, 09UPL140, 09UPL142, '.
09UPLl16, 10UPL002, 10UPL007,

09UPL128
.... COURT USE ONLy ....
Petitioner:
THE PEOPLE OF THE STATE OF Case Number:
I
COLORADO
vs.
Respondents:
T. ANDREW RAGUSIN and RAGUSIN
INTERNATIONAL ASSOCIATION, LLC
Kim E. Ikeler, #15590

Denver, CO 80202
Phone Number: (303) 866-6440
Fax Number: (303) 893-5302
Email: [email protected]
PETITION FOR CONTEMPT CITATION AND INJUNCTION
Petitioner, by and through the undersigned Assistant
Regulation Counsel, and under authorization pursuant to C.R.C.P.

238 (a) 1, respectfully petitions this Court pursuant to C.R.C.P. 238
to issue a contempt citation to the respondent, T. Andrew Ragusin
("Ragusin"), to show cause why he should not be held in contempt
of the Colorado Supreme Court and be subject to a fIne or
imprisonment pursuant to C.R.C.P. 107 for violation of a previous
court order enjoining this respondent from engaging in the
unauthorized practice of law in Colorado.
Petitioner, through the undersigned Assistant Regulation
Counsel. and upon authorization pursuant to C.R.C.P. 234(a},2
further respectfully requests that the Colorado Supreme Court
issue an order pursuant to C.R.C.P. 234 directing respondent
Ragusin International AssOCiation, LLC ("Ragusin International") to
show cause why it should not be enjoined from the unauthorized
practice of law.
As grounds therefor, counsel states as follows:
I The Unauthorized Practice of Law ("UPL") Committee authorized the filing of

this petition seeking a contempt citation against T. Andrew Ragusin on February
19,2010.
2 The Unauthorized Practice of Law ("UPL") Committee authorized the filing of
this petition seeking an injunction against Ragusin International Association, LLC
on February 19, 2010.
2
JURISDICTION
1. Ragusin is not licensed to practice law in the state of
Colorado or in any other jurisdiction in the United States.
2. Upon infonnation and belief. Ragusin is not licensed to
practice law in any other country in the world. In particular, upon
infonnation and belief, Ragusin is not licensed to practice in the
Netherlands, Luxembourg, Belgium. Austria, Italy (Milan district,
Veneto region. Toscana region, Puglia region, Marsala district or
Trapani district) or the Seychelles Islands.
3. Ragusin's last known office and residence address is 9564
Kalamere Court. Highlands Ranch, CO 80126. As of this writing,
Ragusin is incarcerated in the Denver County Jail. People v. Tulio
Andrew Ragusin, Denver County Court. Case No. 10CR381. 3 At all
times pertinent hereto, Ragusin was domiciled in Colorado and
operated and provided services from office locations in Colorado.
3 According to the Complaint and Information filed in that case, Ragusin is

charged with criminal impersonation in violation ofC.R.S. §18-5-113(l)(e), a
class 6 felony; theft in violation ofC.R.S. §18-4-40I(I) and (4), a class 4 felony;
and theft in violation ofC.R.S. §18-4-401(l) and (4), a class 3 felony.
3
..
4. Ragusin International is a Colorado limited liability
company. Its address is the same as Ragusin's. Ragusin is the
registered agent of Ragusin International. Upon information and
belief. Ragusin is the principal of Ragusin International. Ragusin
International was formed May lOt 2007. At relevant times t Ragusin
engaged in the unauthorized practice of law through Ragusin
International. Ragusin International did not employ any attorneys.
BACKGROUND OF CONTEMPT CITATION
5. On March 7 t 2005. Ragusin was permanently enjOined
from engaging in the unauthorized practice of law by the Colorado
Supreme Court. A copy of the Order of Injunction in People v. T.
Andrew Ragusint 05SA70 is attached hereto as Exhibit A. A copy of
the Petition for Injunction in that case (to which the parties
stipulated) is attached as Exhibit B.
6. The March 7, 2005 Order of Injunction was a lawful order
of the Colorado Supreme Court.

7. Ragusin knew of the March 7, 2005. Order of Injunction,
including because he executed a stipulation for its entry.4 A copy
of the Order of Injunction was mailed to Ragusin on March 9, 2005.
Ragusin also participated in a subsequent matter in 2006, during
which he acknowledged the stipulation and his obligations
thereunder.
8. Ragusin had the ability to comply with the March 7,
2005. Order of Injunction issued by the Colorado Supreme Court.
Ragusin was only required by such order to stop engaging in the
unauthorized practice of law.
9. Ragusin willfully and repeatedly refused to comply with
the March 7. 2005, Order of Injunction, as described in detail in the
Claims set forth below.
SUMMARY OF CLAIMS OF UNAUTHORIZED PRACTICE OF LAW
10. Ragusin - who is not a licensed attorney - and
Ragusin International - which did not employ any licensed
attorneys - held themselves out to members of the public as being
able to provide legal advice on international and Colorado legal
4 Ragusin's counsel, Michael Berger, Esq., also signed the stipulation.
5
matters. Ragusin. and Ragusin International in the person of
Ragusin. provided legal advice to residents of Colorado and a
neighboring state. Ragusin. and Ragusin International in the
person of Ragusin. selected and prepared legal documents for
residents of Colorado and a neighboring state. Ragusin. and
Ragusin International in the person of Ragusin. represented
themselves as legal counsel to third parties. The facts are as
follows.
CLAIM I
FRIEL MATTER
11. Shannon Friel ("Friel") is married to Francesco Dorigo
("Dorigo"). They are Colorado residents.
12. As Friel and Dorigo later told Ragusin. Dorigo's father at
his death left real estate in Italy and the Seychelles Islands.
DOrigo. his sister and the widow held interests in these assets.
13. Friel and Dorigo asked the honorary Italian Vice Consul
in Denver. Maria Scordo Allen, to refer them to someone who could
assist them with the division of the properties. Ms. Scordo referred
Friel and Dorigo to Ragusin. doing business through Ragusin
6
International. 5
14. Friel and Dortgo met with Ragusin in Colorado on
January 2, 2009. At the time, Ragusin was doing business from
his home in Highlands Ranch.
15. Ragusin held himself out to Friel and Dorigo as an
expertenced international lawyer licensed in Italy and Belgium who
could represent them in the Italian litigation concerning the
properties. These statements were false. As noted above, Ragusin
has never been licensed to practice law either in Belgium or in
relevant regions and districts of Italy.
16. Friel and Dorigo signed a retainer agreement with
Ragusin International to represent them in the division of the real
estate assets. The letterhead on the retainer agreement read:
"Ragusin International Association, LLC International Legal
Consulting". Friel and Dorigo paid a $5,000 retainer.6
17. Friel and Dorigo also authorized Ragusin International to
5 Ragusin had previously held himself out to Ms. Scordo Allen as an experienced
international attorney authorized to practice law in Italy.
6 The retainer and most of the subsequent payments for fees were made by wire
transfer from Friel to Transnational Legal Solutions Corp., another entity operated
by Ragusin.
7
engage an Italian law frrm. Bevilacqua Marrazato ("the Bevilacqua
law finn") as co-counsel. Friel and Dorigo were to pay Ragusin
International $250 per hour for work done by the Bevilacqua law
finn; Ragusin International was to pay the Bevilacqua law fInn
directly for its work.
18. On January 9,2009. Ragusin sent an e-mail to members
of the Dongo family introducing himself as a Denver lawyer who
would be representing Dongo in the Italian litigation. On January
14, 2009, Dongo executed a "Procura Speciale" ("Special Power of
Attorney"). which Ragusin had prepared. The Special Power of
Attorney authorized Ragusin to represent Dongo in any proceeding
for the division of the assets of the Dongo family. The Special
Power of Attorney also authorized Ragusin to act through the
Bevilacqua law finn.
19. During the Winter and Spring of 2009. Ragusin
communicated with Friel and Dongo bye-mail and other means,
advising them concerning how the Italian properties and income
therefrom could be divided. Ragusin drafted a preliminary
agreement for this division. and advised Friel and Dorigo about the
8
implementation of the legal mechanism he suggested. 7
20. On May 1 L 2009. Friel and Dorigo signed a revised
retainer agreement hiring Ragusin International to prepare complex
domestic and foreign corporate and estate planning structures to
handle their assets and interests in the United States. Italy and the
Seychelles Islands. 8 This retainer agreement bore the letterhead:
"Ragusin International Association. LLC International Legal
Consulting" . Ragusin planned to establish several United States
limited liability companies to hold Colorado real estate. a United
States parent company, several Italian limited liability companies to
hold Italian real estate, an Italian parent company, a Seychelles
Islands limited liability company, and a Luxembourg trust. 9 These
entities would be subject to and operate under management and
logistical services agreements. which Ragusin would draft. Ragusin
also proposed estate-planning measures to Friel and Dorigo
7 The Italian properties were located in or near Verona, in the Veneto region of
Italy. As noted above, upon infonnation and belief, Ragusin was not licensed to
practice law in the Veneto region.
8 As noted above, Ragusin is not licensed to practice law in Colorado or any other
jurisdiction in the United States. Upon infonnation and belief, Ragusin is not
licensed to practice law in the Seychelles Islands.
9 As noted above, Ragusin is not licensed to practice law in Luxembourg.
9
(governed by Colorado law). including a family trust and a post-
nuptial agreement.
21. During respondents' "representation" of Friel and Dorigo,
respondents engaged L. Matthew Johnson, Esq., to provide tax
advice to Friel and Dorigo. Ragusin represented himself to Mr.
Johnson as an attorney. Specifically, Ragusin told Mr. Johnson
that he was a barrister in Belgium and therefore authorized to
practice law in the European Union. Mr. Johnson was present at
meetings in which Ragusin explained Italian property law to Friel
and Dorigo.
22. On June 19. 2009. Ragusin wrote to Friel and Dorigo,
agreeing to indemnify them for any claims made by the Bevilacqua
law firm. Ragusin signed the letter"T. Andrew Ragusin, Esq.".
23. Ragusin drafted operating agreements for Colorado
limited liability companies called Lugiu US, LLC and 1425
Washington Street. LLC. Ragusin also drafted a logistical services
agreement between Lugiu US, LLC and Lugiu IT, SrI. Ragusin also
drafted management agreements between Lugiu US, LLC and two
Colorado limited liability companies. Ragusin also drafted a
10
management services agreement between Lugiu US. LLC and Lugiu
IT. SrI.
24. Ragusin represented to Friel and Dorigo that on July 14,
2009, Ragusin went to court in Verona, Italy and obtained a court
order for them. However, despite repeated requests from Friel,
Ragustn did not produce a copy of the order or provide a case
number. In fact, Ragusin did not appear in the Verona court or
obtain the court order.
25. On July 15, 2009, Dorigo and other members of his
family executed the "scrittura privata PRELIMINARE di divisione"
("preliminary private instrument of division"). which had been
drafted by Ragusin. This document set forth their agreement
concerning the sale of certain assets left by Dorigo's father.
concerning the division of the proceeds of such sales, concerning
the division of personal property, concerning the allocation of other
real estate interests between the family members, concerning the
assignment of income from the properties, concerning a life estate
in certain of the properties for the widow, concerning the deposit
into trust of income from certain of the properties for use in paying
II
the debts and managing the assets of the properties, and
concerning related legal matters.
26. In early September 2009, Ragusin prepared an affidavit
to be executed by the widow concerning her use of income from the
Italian properties between 2001 and 2008. Ragusin also advised
Friel and Dorigo concerning the legal and tax effect of the affidavit.
27. On September 16, 2009. Ragusin sent to two Italian
trust officers, Dr. Mauro Garnier and Dr. Umberto Strano, a
memorandum concerning a "Contratto di Escrow; Divisione Bern
Successione Dorigo" ("Escrow Agreement; Division of the Assets of
the Dorigo Succession"). The memorandum, prepared by Ragusin.
described the means by which income from certain of the Italian
properties would be directed into trust accounts for the benefit of
Dorigo and other family members, and the means by which funds
from the trust accounts would be used to pay expenses associated
with the properties.
28. In October 2009. Ragusin drafted an Irrevocable Trust
Agreement. This trust agreement would appoint a trustee to carry
out the provisions of the preliminary private instrument of division
12
having to do with the flow of income and sale proceeds from the
properties. management of the properties. and the payment of
obligations and distribution of profits therefrom.
29. Over the period from January through September 2009.
Ragusin International billed Friel and Dorigo for travel to Italy.
meetings with the Bevilacqua law frrm. work done by the
Bevilacqua law finn. meetings with others in the Dorigo family.
detennination of tax obligations and review of potential
encumbrances on the subject properties. meeting with the clients.
review of documents related to the sale and partitioning of the
properties. work regarding the corporate and tax structure to
receive the assets. meetings with a potential arbitrator. meetings
with a potential trustee. filing motions in an Italian court.
negotiating a settlement for partition of the properties, drafting a
partitioning agreement. preparing a detailed legal analysis of the
consequences of the failure to reach settlement, work on motions to
be filed in an Italian court for estate inventory. drafting and
implementing corporate structures, setting up a trust in
Luxembourg. meetings with trust companies and bankers.
i3
fmalizing and closing the property division agreement, attending a
hearing in the Italian court concerning the inventory, analysis of
pertinent Italian law provisions and cases dealing with usufruct,
work on an escrow agreement, work on a tax affidavit, and a myriad
of similar activities. Friel and Dorigo paid many of Ragusin
International's invoices, to their loss as discussed below.
30. On October 29.2009, Ragusin told Friel and Dorigo that
he was fmalizing the escrow agreement and the trust company and
corporate structure. At that point the relationship between
respondents and Friel and Dorigo broke down, after Dorigo learned
that Ragusin International had not paid the Bevilacqua law fIrm.
31. Friel and Dorigo paid respondents a total of
approximately $125,000. Despite the agreement to do so, Ragusin
International never paid the Bevilacqua law fIrm for its work. The
Bevilacqua law finn informed Friel and Dorigo that it considered
them liable for its legal services.
32. By holding himself out to Friel and Dorigo as licensed
to provide legal services, by representing Friel and Dongo in
negotiations concerning the division of the Italian and Seychelles
14
Islands real properties and related matters. by providing legal
advice to Friel and Dorigo. by preparing trust and corporate
documents. the property division agreement and other legal
documents (some under Colorado law). and by similar conduct
detailed above, Ragusin engaged in the unauthOrized practice of
law.
33. Each of Ragusin's above-described acts constitutes
the unauthorized practice of law, as do all of them together.
Ragusin knew at the time he committed each act that such conduct
was the practice of law, and was not authorized by any
jurisdiction's statute. case law. or other legal authority.
34. Ragusin knew that he had been enjoined by the
Colorado Supreme Court from engaging in further acts of
unauthorized practice of law at the time he engaged in the above
conduct. The respondent also had the ability to comply with the
Order of Injunction, but instead willfully refused to abide by the
Order of Injunction as described by the hereinabove acts.
35. The above-described conduct constitutes willful
contempt of the Colorado Supreme Court's Order of Injunction.
15
36. Through the acts of its principal, Ragusin
International also engaged in the unauthorized practice of law.
WHEREFORE. petitioner prays at the conclusion hereof.
CLAIM II
REYNOLDS MATTER
37. Lee Ann Reynolds and her husband Robert Reynolds are
Colorado residents. Lee Ann Reynolds' sister Sandra Lemire. is a
resident of Arizona.
38. As they later informed Ragusin, they wished to fonn a
business, named "Pure Solutions". They retained Daynel Hooker
("Hooker'), a Wisconsin lawyer, residing and practicing in Colorado.
The Reynolds and Ms. Lemire believed they had a claim against
Hooker based upon problems that arose during her representation.
39. In September 2007, Mr. and Mrs. Reynolds and Ms.
Lemire began communicating with Ragusin concerning trademark
registration and possible action against Hooker. At relevant times,
Ragusin was doing business out of his residence in Highlands
Ranch.
40. Ragusin implied that he was a licensed attorney; he did
16
not disclose that he was not licensed in Colorado. In particular,
Ragusin held himself out as qualified to provide advice and
assistance in the area of trademark registration and infringement.
Ragusin also held himself out as qualified to evaluate the strength
of a Colorado malpractice case against Hooker. The Reynolds paid
Ragusin an initial retainer of $3,000.
41. Thereafter, Ragusin told the Reynolds and Ms. Lemire
that he was conducting a trademark search in multiple
jurisdictions both domestic and international. Ragusin also offered
his assessment of a partnership agreement that Hooker had
drafted.
42. In early October 2007, Ragusin recommended that the
Reynolds and Ms. Lemire engage him to dissolve Pure Solutions
and fonn a new Colorado entity, in order to cut off potential liability
for trademark infringement. Ragusin further recommended that he
redraft a shareholder agreement and related documents. In
addition, Ragusin offered his seIVices to register the company's
trademark in the U.S .• Canada and Europe and to pursue a
Colorado malpractice claim against Hooker.
17
43. Under the mistaken assumption that Ragusin was a
licensed attorney. the Reynolds and Ms. Lemire hired respondents
to perform these tasks. The Reynolds paid Ragusin an additional
approximately $6.600.
44. Ragusin continued to give the Reynolds and Ms. Lemire
the impression that he was a Colorado lawyer. Over the next
thirteen months, the Reynolds and Ms. Lemire paid Ragusin
additional fees. eventually totaling approximately $40,000.
45. Ragusin took a number of actions as "counsel" for the
new Colorado entity. Opaline Solutions. LLC ("Opaline Solutions").
46. Ragusm engaged a law firm in New York to conduct a
trademark search for Opaline Solutions. Ragusin failed to pay the
law fIrm for its work. Ragusin also failed to fIle trademarks for
Opaline Solutions. Ragusin misled the Reynolds and Ms. Lemire
about his lack of action by telling them that he had prepared and
fIled the trademark applications.
47. Ragusin prepared organizational documents for the
Colorado limited liability company, Opaline Solutions. These
included an amended and restated Operating Agreement, which
18
included provisions for non-voting preferred units to be granted to a
member by the name of Lawrence Murphy. Ragusin also drafted a
consulting agreement between Opaline Solutions and Mr. Murphy.
48. Ragusin held himself out to a testing laboratory as
"counsel to Opaline Solutions, LLC". Ragusin drafted a proposed
confidentiality agreement and sent it to the testing laboratory.
49. Ragusin prepared a legal disclosure statement for the
Opaline Solutions website.
50. In connection with the effort to pursue Hooker. Ragusin
spent time investigating the claim against Hooker. Ragusin also
contacted John Astuno, a Colorado lawyer. Ragusin
misrepresented to Mr. Astuno that he was an attorney licensed in
Austria or Italy. Ragusin told Mr. Astuno that Ragusin practiced
international law. Ragusin stated that he was not licensed in
Colorado. Ragusin asked Mr. Astuno whether he would be
interested in taking the case against Hooker. Mr. Astuno decided
not to take the case. Ragusin failed to take any other action
against Hooker. Instead, Ragusin misled the Reynolds and Ms.
Lemire including by telling them he was having Mr. Astuno move
19
forward on the case by obtaining a certification of meritorious
action from another Colorado lawyer. Ragusin told the Reynolds
and Ms. Lemire that he had hired Mr. Astuno and that Mr. Astuno
was acting at Ragusin's direction. Ragusin offered advice as to
whom the proceeds of any malpractice settlement should be paid.
51. Ragusin held conferences with Mrs. Reynolds and Ms.
Lemire at which he discussed legal matters. Ragusin represented
himself to them as a "corporate/business/tax lawyer".
52. Ragusin prepared a Wholesaler/Distributor agreement
for Opaline Solutions. Ragusin wrote to the potential distributor
setting forth Opaline Solutions' legal position with regard to the
Validity and binding nature of a non-compete agreement that
Opaline Solutions and the distributor were negotiating in
connection with the Wholesaler/Distributor agreement. Ragusin
also wrote to the distributor terminating negotiations on the
Wholesaler /Distributor agreement. In this correspondence,
Ragusin held himself out as counsel for Opaline Solutions,
including by referring to the company as "my client".
53. Ragusin wrote to a third party who had inquired about
20
Opaline Solutions' trademark, stating: "I am counsel to Opaline
Solutions. LLC." Ragusin falsely stated: "Trademark applications
have been rued or are being filed in multiple jurisdictions with
respect to the Opaline Solutions products." Ragusin accused this
third party of defamation. demanded that the third party cease and
desist and publish a retraction. and threatened legal action.
54. Ragusin told Ms. Lemire that he would prepare and file
documents by which Pure Solutions would withdraw as a registered
entity in Arizona.
55. Ragusin offered advice to the Reynolds and Ms. Lemire
about the appropriate method to capitalize Opaline Solutions.
Ragusin prepared promissory notes. subordination agreements and
assumptions of debt required to evidence loans by the members to
the company. Ragusin also provided advice on how any funds
recovered from Hooker should be directed.
56. Ragusin prepared a lengthy legal memorandum on
"accounting. tax: and corporate issues". In the memorandum. he
referred to himself as "outside counsel to Opaline Solutions, LLC".
He also referred to himself as a "corporate practitioner".
21
57. On September 29.2008. Ms. Lemire as general manager
of Opaline Solutions wrote to Ragusin terminating his services as
outside counsel. As grounds, she expressed her dissatisfaction
with the organizational documents and promissory notes he had
prepared. She asked Ragusin to continue on as the company's
counsel in the malpractice action against Hooker. Ragusin asked
that his remaining fees be paid before he turned over his mes on
Opaline Solutions. Ragusin assured Ms. Lemire that there was not
yet a statute of limitations problem with regard to the Hooker case.
Subsequently, Ms. Lemire terminated Ragusin's services entirely.
58. In October 2009, Anita Blackman. Ragusin's assistant.
infonned Ms. Lemire that Ragusin was not licensed in Colorado.
Until they received this infonnation. Ms. Lemire and the Reynolds
understood that Ragusin was licensed here.
59. Eventually. the Reynolds and Ms. Lemire were required
to hire an attorney licensed in Colorado to prepare proper
organizational documents and to register their trademark. They
abandoned their efforts to recover any funds from Hooker on the
assumption that the statute of limitations had run.
22
60. By holding himself out to the Reynolds and Ms.
Lemire as authorized to provide legal services, by preparing
organizational documents and agreements for Opaline Solutions, by
providing the Reynolds and Ms. Lemire with legal advice about the
organization and capitalization of Opaline Solutions, by holding
himself out to third-parties as counsel for Opaline Solutions, by
negotiating with third-parties on behalf of Opaline Solutions
concerning legal matters, by offering advice concerning the
malpractice case against Hooker. and by similar conduct detailed
above. Ragusin engaged in the unauthorized practice of law.
was the practice of law, and was not authorized by any state's or
other jurisdiction's statute. case law, or other legal authority.
23
Order of Injunction. but instead willfully refused to abide by the
64. Through the acts of its principal, Ragusin
International also engaged in the unauthorized practice of law.
CLAIMUI
DeGAETANO MATTER
65. Josephine DeGaetano ("DeGaetano") is a Colorado
resident. She needed legal assistance with the transfer of a family
residence in Rutigliano, in the Puglia region of Italy (the
"residence").l0 The residence had been owned by DeGaetano's
father and aunt. Upon their deaths, ownership of the residence
was to pass to the heirs of the father. including DeGaetano. The
father and then the aunt passed on. DeGaetano wished to transfer
the title of the residence to her mother. She needed a licensed
international lawyer to assist with this.
10 As noted above, Ragusin is not licensed to practice law in the Puglia region.
24
66. DeGaetano learned of Ragusin through the honorary
Italian Vice Consul in Denver. Maria Scorda Allen. At the time.
Ragusin was doing business out of his Highlands Ranch residence.
Ragusin held himself out to DeGaetano as "European counsel to a
number of corporations and individuals in the Rocky Mountain
Region." In particular. Ragusin represented to DeGaetano that he
was licensed in the United States and Italy and was qualified to
search the title of the property and to transfer title through probate.
These statements were false. Unaware that Ragusin had
misrepresented his qualifications. DeGaetano retained respondents
to search the title of the residence and probate the property. On
October 1. 2007. DeGaetano entered into a retainer agreement. l l
She paid Ragusin a retainer of $2.200. DeGaetano also paid an
additional invoice of $2,767 in January 2008.
67. After supposedly having searched title, Ragusin reported
to DeGaetano that a fraud had occurred in connection with the
residence while DeGaetano's aunt was living there. Ragusin
11The retainer agreement bears the heading "Ragusin & Associates, LLC". This
entity apparently was a predecessor of Rag us in International.
25
claimed that the aunt had agreed to give one floor of the residence
and certain other properties to a caregiver in return for care while
the aunt was alive. Ragusin told DeGaetano that the caregiver had
mistreated the aunt. stolen her money, and placed her in a poorly-
run nursing home, where she died. The caregiver's fraud required
litigation (Ragusin said) in order to regain clear title to the entire
residence and the other properties prior to probating them.
68. On January 21, 2008, DeGaetano signed a second
retainer agreement. 12 The deSCription of the engagement recited
the purported evidence of fraud by the caregiver. To rectify
matters. it would be necessary for the father's estate to sue the
caregiver and others and to attach the transferred properties so
that they could not be sold during the litigation. Ragusin agreed to
undertake this litigation, assisted by Italian co-counsel. DeGaetano
paid respondent a $10,000 retainer.
69. Thereafter. Ragusin represented to DeGaetano that the
Italian litigation was progressing. including application for an
attachment order, service of process on the caregiver. issuance of
26
an attachment order, efforts to appoint a trustee to receive the
rents and profits of the residence and the properties, and
scheduling a trial on the merits of the estate's fraud claims. As of
October 2009. Ragusin reported that the probate had been
completed and that appropriate recordings had been filed with
regard to the residence and other properties.
70. In November 2009. DeGaetano received a call from
Ragusin's fonner assistant. The assistant told DeGaetano that she
had terminated her employment with Ragusin after learning that he
was not licensed to practice law either in Colorado or Europe.
Upon investigation. DeGaetano learned that Ragusin had never
commenced the Italian probate action. that the caregiver had never
been served with process, and that no orders had ever issued.
DeGaetano then reported this matter to the Colorado Supreme
Court and the Denver District Attorney's Office.
71. By holding himself out to DeGaetano as qualified to
advise her on Italian probate law and to investigate and prosecute a
probate action in Italy. and by advising DeGaetano on these
12 This agreement was with Ragusin International.
27
matters, Ragusin engaged in the unauthorized practice of law.
was the practice of law, and was not authorized by statute, case
law, or other legal authority.
75. Through the acts of its principal, Ragusin International
engaged in the unauthorized practice of law.
WHEREFORE, petitioner prays at the conclusion hereof.
28
CLAIM IV
WIARD MATTER
76. Ragusin employed Rebecca Wiard ("Wiard"), as a law
clerk whUe she was in law school. Mer she became a Colorado
attorney, Ragusin offered Wiard a position as his associate. At the
time, Ragusin was doing business out of his Highlands Ranch
residence.
77. During the time she was employed by him, Ragusin held
himself out to Wiard as a banister admitted to the bar in Brussels,
Belgium, thereby licensed in Europe and authorized to practice
international law. These statements were false. Ragusin told Wiard
that the Colorado Supreme Court had approved his practicing
international law in Colorado, as long as he did not practice
Colorado law. This statement was false. When Wiard learned that
these statements were false, she resigned her pOSition with Ragusin
InteITlational.
78. By holding himself out to Wiard as a banister
licensed with the bar of Brussels, Belgium and thereby able to
29
practice international law, Ragusln engaged in the unauthorized
practice of law.
the unauthorized practice of law. as do all of them together.
was the practice of law, and was not authorized by statute. case
Colorado Su preme Court from engaging in further acts of
81. The above-described conduct constitutes Willful
CLAIM V
HARVEY MATTER
82. Catherine Harvey ("Harvey") is a resident of Santa Fe,
30
New Mexico. As Harvey later told Ragusin, she wished to purchase
a horse accomplished in "dressage" .13 She contracted with two
buyer's agents. Heather Robinson (American) and Dana Hewett
(Dutch) (collectively. the "agents") to locate and purchase a suitable
horse for her. The agents informed Harvey of a stallion named
Donati, supposedly seven years old, performing well in
competitions, and approved for breeding. Harvey paid the agents
95,000 Euros to purchase Donati from his then-owner in The
Netherlands.
83. As Harvey later told Ragusin, upon delivery to Harvey.
Donati appeared lame. Harvey asked several veterinary specialists
to examine Donati. The specialists determined that Donati was
nine years old, not seven as the agents had represented. The
speCialists also determined that Donati was suffering from a
neurological disorder that rendered him unfit for dressage
competition. Harvey concluded that she had been defrauded.
84. Harvey conferred concerning this problem with Colorado
13Dressage is the execution by a horse of complex maneuvers in response to

barely perceptible movements of a rider's hands, legs and weight.
31
attorney Marc C. Patoile, with Folkestad Fazekas Barrick & Patoile.
P.C. On August 6. 2008. Mr. Patoile wrote to the agents, rescinding
the purchase and threatening a lawsuit. It appeared it might be
necessary for Harvey to bring suit against the seller.
85. Mr. Patoile contacted Ragusin. At the time. Ragusin was
doing business out of his Highlands Ranch residence. Ragusin
provided Mr. Patoile with an outline of his biographical information.
wherein Ragusin claimed inter alia to be "European counsel to a
number of corporations and individuals in Europe". Ragusin stated
that he had worked for major law firms and taught at the University
of Denver College of Law. While Ragusin did not state that he was
a licensed attorney. the extensive international legal experience
that he recited gave that impression. Ragusin did not reveal that
he had been enjoined from the unauthorized practice of law in
Colorado in 2005.
86. Mr. Patoile forwarded a copy of his file on Harvey's
problem to Ragusin. Mr. Patoile recommended to Harvey that she
retain Ragusin to research possible litigation in the Netherlands.
On August 11. 2008. Harvey retained Ragusin International to
32
represent her with regard to a civil action in Europe regarding the
purchase of the horse. The retainer agreement, drafted by Ragusin,
bore the letterhead of "Ragusin International Association, LLC
International Legal Consulting". Hanrey paid Ragusin International
an initial retainer of $500. When she retained him, Hanrey
understood that Ragusin was a lawyer licensed in Europe and in
Colorado.
87. On August 20, 2008, Ragusin sent Harvey an eight-page,
single-spaced memorandum entitled "Donati Dutch Recourse
Options". The memorandum bore the letterhead of "Ragusin
International Association, LLC International Legal Consulting".
Ragusin stated: "I am qualified to practice law as a conseiller
jurldique in Belgium, and by reciprocity in the Member Countries of
the European Union. including but not limited to the Kingdom of
the Netherlands, pursuant to the Treaty on European Union." This
statement was not true: Ragusin was not qualified to practice
international law in Colorado. Ragusin did not inform Hanrey that
he had been enjoined from the practice of law in Colorado in 2005.
88. In the memorandum, Ragusin provided an analysis of
33
the procedural advantages and disadvantages of bringing an action
in the Netherlands. Ragusin discussed principles of applicable
European and Dutch law. Ragusin evaluated possible claims
against the seller and the Dutch agent, Dana Hewett, including
based on Dutch law that required consumer goods to conform to
the particular purpose for which the consumer desired to purchase
them (here. a horse accomplished in dressage). Ragusin opined
that replacement or rescission were available as alternative
remedies. Ragusin analyzed the applicable statute of limitations.
Ragusin made recommendations as to what steps he could take to
protect Harvey's interests and advance her claims.
89. Based on the misconception that Ragusin was authorized
to represent her in a legal matter, Harvey authorized Ragusin to
research Donati's registry title history and to send demand letters
to the seller and the Dutch agent, Hewett. Ragusin reported to
Harvey that his investigation had revealed a fraud by Hewett: she
had substituted another horse (one that was healthy) for Donati at
the pre-sale veterinary inspection.
90. On September 16, 2008, Ragusin wrote to Hewett's
34
Dutch counsel. He announced himself as Harvey's "European
counsel". Ragusin set forth the results of his investigation of the
sale of Donati to Harvey. which Ragusin argued proved that Hewett
had made misrepresentations to Harvey. Ragusin demanded
rescission of the sale and legal action in the Netherlands if the
demand was not met.
91. When the demand went unanswered. Ragusin told
Harvey that he was moving forward to commence litigation in the
Netherlands. Ragusin stated that he would be hiring local Dutch
counsel to assist in this. Ragusin told Harvey that he (Ragusin)
would try the case, but that the local Dutch counsel would appear
with him at trial. Ragusin said he would me the case in Arnhem
District Court. He proposed a strategy of first seeking to attach
Hewett's bank accounts and other assets.
92. Ragusin's staff made inquiries of witnesses and gathered
evidence from various sources. Ragusin corresponded with
Hewett's counsel and informed Harvey about counsel's pOSitions.
Ragusin told Harvey that he had commenced an attachment
proceeding in the Amhem District Court and that he expected an
35
attachment order to issue by the end of 2008.
93. On January 7, 2009, Ragusin informed Harvey through
his assistant that a judge in Arnhem had entered an order
attaching Dana's assets. The assistant promised that Ragusin
would obtain a copy of the order and forward it to Harvey. The
assistant stated that Ragusin would be supervising the service and
enforcement of the order. Thereafter, Ragusin reported to Harvey
that Hewett was avoiding service.
94. Ragusin reported that a hearing in the Arnhem case was
set for June 26.2009. but vacated to allow settlement negotiations.
In September 2009. Ragusin contacted Harvey. requesting that she
provide information and documents to be used in an upcoming
hearing supposedly to be held in the Arnhem court.
95. In October 2009. Harvey learned that Ragusin was not a
licensed lawyer. She terminated respondents' services. From
contacting the Dutch lawyer Ragusin had retained. Harvey learned
that no attachment proceeding had ever been commenced.
96. Harvey paid Ragusin International over $81.000 during
its "representation" of her. None of this has been refunded.
36
97. By holding himself out to Mr. Patoile and Harvey as
authorized to provide legal services. by providing Harvey with legal
advice, by writing demand letters as Harvey's "European counsel".
and by similar conduct detailed above. Ragusin engaged in the
unauthorized practice of law.
was the practice of law, and was not authOrized by statute. case
37
also engaged in the unauthorized practice of law.
CLAIM VI
SCHORR MATTER
102. Jan Schorr ("Schorr"J is a Colorado resident. She was
involved in a bicycle-automobile collision while touring in Tuscany.
Italy. Schorr (who was on the bicycle) sustained personal injuries.
She retained an Italian lawyer. Stefania Vichi. but was unable to
reach a settlement with the driver.
103. Ragusin heard about Schorr's accident. He offered to
help her with her case. At relevant times, Ragusin was doing
business at offices in the Denver metropolitan area or at his
Highlands Ranch residence. Ragusin described himself as an
international business attorney. Schorr retained Ragusin in
December 2004. Ragusin was to assist Italian counsel in the filing
of necessary documents with the Italian court. make calls and. if
the parties were able to resolve the case, draft a settlement
agreement.
38
104. In April 2005, Ragusin reported to Schorr that a
prosecutor had brought a criminal indictment against the driver in
a proceeding lodged in Montepulciano, Italy. A trial was set for
October 2005. Ragusin asked Schorr to obtain an opinion from her
doctor concerning her injuries.
105. The driver's insurance company offered to pay Schorr a
relatively small amount. a few thousand Euros. Ragusin advised
Schorr that her claim was worth much more. He advised that
Italian law required the insurance company to consider U.S.
medical costs, pain and suffering damages and future costs Schorr
would incur as a result of her injuries. Ragusin (at the time doing
business as Ragusin & Associates, LLC) billed Schorr for writing to
a medical examiner and the driver's insurance company, and for
preparing a pleading to be flIed with an Italian court.
106. Ragusin supposedly took the lead in negotiations With
the driver's insurance company. In May 2007. Ragusin announced
he was prepared to try the case before the tribunal in
Montepulciano, Italy (with Ms. Vichi as local counsel) in November
2007 if the insurance company did not settle. In July 2007,
39
Ragusin reported that Ms. Vichi was withdra"...ing because she was
unwilling to advocate for the amount of damages Ragusin thought
appropriate. Based on Ragusin's advice. Schorr agreed to retain
another Italian law firm. Gianni. Orrigoni. Grippo and Partners. to
act as local counsel for her case. Ragusin told Schorr that he
would still be handling the bulk of the work and that the Gianni
frrm would back him up.
107. Ragusin reported that trial was set for June 9. 2008. and
on that date. Ragusin and a lawyer from the Gianni frrm attended
(Ragusin appeared by telephone). Ragusin reported that the judge
made favorable evidentiary TIllings. Ragusin told Schorr he had
spoken with the insurance company's lawyer and that he planned
to make a substantial counter-offer to the insurance company.
Trial was rescheduled for October 13, 2008 and then rescheduled.
108. In April 2009. Schorr's videotaped deposition was taken
in Denver. Ragusin advised Schorr that the videotape would be
admissible into evidence in lieu of her attending trial in Italy.
Ragusin prepared Schorr for her testimony.
109. In May 2009, Ragusin asked another Italian law finn,
40
Bevilacqua Marazzato (the "Bevilacqua frrm"). to represent Schorr in
the litigation. A new hearing was scheduled for November 2009.
110. In late October 2009, Schorr learned from an ex-
employee of Ragusin International that Ragusin was not a licensed
attorney. Schorr asked the Bevilacqua fInn to handle the upcoming
hearings.
111. Durtng the course of respondents' representation of
Schorr. Schorr paid Ragusin International apprOximately $10,000
for Ragusin's services. None of this has been repaid.
112. By holding himself out to Schorr as authorized to provide
legal services. by prOviding Schorr with legal advice about her
recovery of damages from the Italian drtver. by holding himself out
to third-parties as counsel for Schorr, and by similar conduct
detailed above, Ragusin engaged in the unauthorized practice of
law.
113. Each of Ragusin's above-descrtbed acts constitutes
41
was the practice of law. and was not authorized by statute. case
CLAIM VII
RIVERA MATTER
117. Complaining witness Albert Rivera ("Rivera"), a Colorado
resident. is the son of Maria Rosa Rivera. She owned real property
in Pantelleria. in the Trapani district of Italy. In the mid-2000's,
the mother died. Rivera was uncertain as to the status of the
42
properties. He endeavored to make inquiries of persons in Italy,
without success.
lIB. On August 21, 2006, Rivera and another member of his
family, Marisa Costabile. retained Ragusin & Associates, lLC. 14
They engaged Ragusin and his entity to investigate their interests
and those of other siblings in properties owned or formerly owned
by Maria Rosa Rivera. Ragusin also was to obtain an accounting
for the Estate of Maria Rosa Rivera (the "Estate"). 15
119. In a biographical summary that Ragusin provided to
Rivera, Ragusin portrayed himself as "European counsel to a
number of corporations and individuals in the Rocky Mountain
area". Ragusin did not disclose that he had been enjoined from the
unauthorized practice of law by the Colorado Supreme Court in
2005.
120. At relevant times, Ragusin did business from offices in
the Denver metropolitan area or out of his Highlands Ranch
14See footnote 2, above. Although Ragusin had been enjoined from the
unauthorized practice of law in 2005 and had agreed to shut down the office of
Ragusin & Associates, LLC, he continued to operate that entity. Eventually, the
entity transfonned into Ragusin International.
43
residence.
121. Ragusin contacted an Italian real estate agency to look
for properties that were owned or had been owned by the mother
and to research title to those properties. Communications from
Ragusin to the real estate agency bore the heading "Ragusin &
Associates. LLC International Legal Consulting".
122. On September 20. 2006. Ragusin e-mailed Rivera and
his sister with the results of the title search of the properties.
Ragusin said: "[W]e are faced with an incredible situation of fraud.
forged documents and civil and criminal proceedings." Ragusin
claimed that two Italians. using powers of attorney. "fraudulently
and surreptitiously conveyed the properties to 'empty shell'
companies (such as Bonsulton SrI) owned and controlled by
themselves. for nominal consideration ... some properties were
conveyed to members of the Valenza family through the illegal
exercise of apparent eminent domain powers by members of the
family who are also public officials". Ragusin reported that certain
ISAs noted above, Ragusin was not licensed to practice law in the Trapani district
or the Marsala district.
44
banks had enjoined the sales of the properties on grounds that they
were mortgage lenders and defrauded as part of the sales. One
bank was alleging that the two Italians had engaged in forgery and
a criminal investigation was pending. Ragusin estimated that the
value of the properties was in the millions of Euros. Ragusin
recommended that he "take legal steps with urgency to adequately
protect you", including a pre-judgment attachment of the assets of
the two Italians.
123. On September 28. 2006, Ragusin provided Rivera and
his sister with a memorandum entitled "Summary of Findings and
Phase II Engagement Memorandum". Ragusin summarized a
report on the title history of the properties. He reiterated his
suspIcions that the two Italians had fraudulently conveyed property
in which the mother had an interest, thereby depriving her Estate
of sizeable sums. Ragusin made recommendations including that
he be authorized to represent the Estate in conducting further
investigation of the transfers of the properties. Ragusin also
recommended seeking a pre-judgment attachment of the assets of
the two Italians and their entity.
45
124. Ragusin prepared powers of attorney giving him
authorization to proceed. Rivera family members executed the
powers of attorney. Ragusin reported that he was obtaining copies
of deeds to the properties. He estimated their worth in the
$10,000,000's. He promised to prepare a demand letter to the two
Italians. He said he would be meeting with a lawyer for one of the
banks involved in challenging the transfers of the properties.
125. In early 2007, Ragusin announced that the bank had
agreed to join forces with the Estate. Ragusin claimed that the two
Italians had built a large villa on one of the properties. Ragusin
opined that this made attachment of the properties an attractive
avenue of recovery for the Estate.
126. On January 19,2007, Ragusin met with Rivera. Ragusin
recommended filing a criminal complaint against the two Italians.
He explained the procedural and cost benefits of doing so. Ragusin
also explained to Rivera that the banks were joining forces with the
Estate because the Estate's beneficiaries would make sympathetic
witnesses. Ragusin told Rivera he was filing a motion in the Italian
court for pre-judgment attachment of the interests of the two
46
Italians in the properties.
127. In March 2007, Ragusin reported that his associate had
met with a witness in Italy who also was a Rivera relative. The
witness had provided documents related to title to the properties
and would be swearing out an affidavit. Ragusin promised to
provide a detailed report on the title and value of the properties by
May.
128. In June 2007, Ragusin sent Rivera and his siblings a
lengthy report with attached documents. Ragusin explained that
the criminal complaint - which he promised to present shortly - set
forth the steps by which the two Italians had fraudulently conveyed
the properties pursuant to a power of attorney from Rivera's
mother. Ragusin stated that the power of attorney was ineffective
because the mother had died before the properties were
transferred. The complaint also included a request for pre-
judgment attachment of the properties.
129. In July 2007, after delays Ragusin blamed on Sicilian
counsel, Ragusin reported that the criminal complaint had been
tendered to the district attorney's office in Marsala, Italy, with the
47
anticipation that it would be assigned to an assistant district
attorney and filed with the court. Ragusin transmitted a copy of
the first page of the complaint, bearing a date stamp. On July 17,
2007, Ragusin sent a detailed memorandum to Rivera and his
siblings, recommending the formation of a limited liability company
to oversee the Italian litigation. In late July. Ragusin met with
Rivera and his sister Marisa Costabile. Ragusin discussed
switching Italian law frrms, explained the status of the criminal
case, and recommended that the limited liability company handle
the flow of funds from resolution of the litigation.
130. In August 2007, Ragusin informed Rivera and his sister
that substituted Italian counsel was preparing a civil complaint, to
be used to commence a civil action in Marsala paralleling the
criminal case. Ragusin's associate. Matt Johnson, fmalized an
operating agreement for the limited liability company.
131. On September 4, 2007, Ragusin provided to Rivera a
memorandum entitled "Summru:y and Explanation of Civil
Complaint". Ragusin explained that the civil Complaint alleged
facts supporting theories of fraud and breach of flduciru:y duties in
48
connection with recent transfers of the properties among persons in
Italy. The Complaint sought to recover the properties from the
transferees or to recover sale proceeds that should have been paid
to the Estate. The Complaint also sought a pre-judgment
attachment.
132. On September 19, 2007, Ragusin told Rivera that the
assistant district attorney handling the criminal case had requested
a hearing. Ragusin planned to attend telephonically. Ragusin
provided Rivera with a flow chart detailing the procedural steps
involved in the criminal case and the civil case. In October,
Ragusin provided advice on how to handle a renewed attempt to
sell the properties in which the Estate had an interest. Ragusin
prepared an attachment petition to be used to commence a civil
case in Marsala. Ragusin met with Rivera and his sister. They
discussed litigation strategy and the possible formation of an Italian
limited liability company to handle the claims of family members
living in Italy.
133. Ragusin's associate Matt Johnson prepared and Ragusin
reviewed a confidentiality agreement between the American branch
49
of the family and the Italian branch related to the conduct of the
Marsala litigation. In mid-November 2007. Ragusin reported to
Rivera and his sister that he had spoken by telephone with the
assistant district attorney in Marsala and was planning to meet
with her to persuade her to file a criminal case related to the
transfer of the properties. In late November. Ragusin transmitted a
receipt for the filing of an attachment petition (which he had
drafted) with the Marsala court. Ragusin announced that he would
be attending an attachment hearing in Marsala in early 2008. along
with his Italian co-counsel.
134. In January 2008. Ragusin offered a legal opinion as to
the authority of the executor of an estate. operating under the law
of the State of Georgia, to initiate and prosecute a legal proceeding
to recover assets of the estate. Ragusin's opinion was presented to
the Marsala court by Italian co-counsel. Ragusin reported that he
participated in a teleconference with the Marsala judge and Italian
co-counsel on this legal point.
135. In April 2008, Ragusin informed Rivera that the two
Italians who had transferred the properties were being indicted.
50
Ragusin planned to meet In Rome with Italian counsel for one of
the defendants, to discuss settlement. Ragusin reported that the
judge had granted the attachment request, making favorable
fmdings for the plaintiffs. A trustee was appointed to take
possession of the properties. RagusIn prepared to file a civil
complaint in the Marsala court. He announced that trial was set
for November 10.2008.
136. In July 2008, Ragusin met with the Marsala assistant
district attorney. RagusIn reported that she had uncovered
additional evidence of fraud, that could be the subject of expanded
civil and criminal complaints. For economic reasons, Ragusin
recommended against Rivera and his siblings expanding the
litigation. Ragusin forwarded to Rivera and his sister Marisa the
report of the trustee of his inspection of the properties. Ragusin
explained and commented on the report. Ragusin also forecast
future litigation costs and possible settlement amounts.
137. In Fall 2008, Ragusin told Rivera and his sister that he
was preparing for trial. RagusIn prepared motions for filing with
the Marsala court. He discussed these motions with Rivera and his
51
sister. Ragusin told them that he would be paying fees due to the
trustee. Ragusin forwarded a settlement offer of 19 million Euros.
Because it had not been paid. the Rome law frrm that was assisting
with the litigation withdrew and threatened to sue for its fees.
138. In early 2009. Ragusin conducted further settlement
negotiations. He reported on a trip to the court in Marsala at which
he met with the assistant district attorney and the president of the
local bar.
139. In March 16. 2009. Ragusin sent a memorandum to
Rivera and his siblings regarding the strategy and tactics being
employed and the costs being incurred in the Marsala litigation.
The memorandum appeared under the heading "Ragusin
International Association. LLC International Legal Consulting".
There followed disputes between Ragusin and Italian counsel. The
trustee drew the Marsala court's attention to the fact that he had
not been paid.
140. In mid-July 2009. Ragusin announced that his
settlement negotiations were close to an end. The opposing parties
had agreed to pay for the trustee's services. Ragusin also contacted
52
the trust departments of several European banks as potential
repositories of any settlement funds. Ragusin told Rivera and his
siblings that he was handling these discussions "as your lawyer".
Ragusin drafted a settlement agreement. However. he then related
further delays. In Fall 2009. Ragusin drafted an escrow agreement
and circulated it among the siblings for comment.
141. On November 9, 2009. the judge in Marsala entered an
order which (translated into English) states: "Mr. Albert Rivera
should be represented by his attorney. Andrew Ragusin from
Denver. who holds power of attorney previously registered with this
court; however, such power of attorney cannot be taken into
account because there Is no proof that Mr. Ragusin is allowed to
practice law within the Italian Republic and therefore cannot validly
exercise the ability to represent someone else in court."
142. During the course of the events described above, Rivera
and his siblings paid fees and costs to Ragusin International of
approximately $100.000. They also paid Ragustn International
approximately $10,000 to pay the fees of the trustee, which
Ragusin International did not pay to the trustee.
53
143. By holding himself out to Rivera and his siblings as
able to practice international law. by offering advice concerning the
Italian litigation, by preparing legal documents including court
pleadings for that litigation. by holding himself out to third parties
as the lawyer for the Estate, by negotiating settlement of the Italian
litigation, and by similar acts discussed above, Ragusin engaged in
the unauthorlzed practice of law.
was the practice of law. and was not authorized by statute. case
law. or other legal authority.
54
147. Through the acts of its principal. Ragusin International
REQUEST FOR RELIEF AS TO RAGUSIN
148. Ragusin has engaged in the unauthorized practice of law
in violation of this Court's March 7, 2005. Order of Injunction as
described above. Ragusin's pattern and practice of knowingly
failing to abide by the Court's Order of Injunction, and willful
disregard of such Order of Injunction. is an affront to the dignity of
this Court and represents an immediate threat to the public. The
most effective way to deal with this conduct is by a finding of
contempt and the imposition of a fme and/or a jail tenn of less
than 180 days. Ragusin also should be ordered to provide full
restitution to the victims listed above.
WHEREFORE. the petitioner prays that this Court issue a
citation to Ragusin to show cause why the Court should not find
him in contempt of this Court and impose a fine and/ or
55
imprisonment. and order full restitution to his victims. If a citation
is issued, the citation need also state that a fme of not less than
$2000 per incident or imprisonment may be imposed to vindicate
the dignity of the Supreme Court (see C.R.C.P. 238(c)).
REQUEST FOR RELIEF AS TO RAGUSIN INTERNATIONAL
149. Through the acts of Ragusin described in detail above,
Ragusin International engaged in the unauthorized practice of law.
The unauthorized practice of law includes acting as a
representative in protecting, enforcing or defending the legal rights
and duties of another and/or counseling advising and assisting
that person in connection with legal rights and duties. See, People
v. ShelL 148 P.3d 162 (Colo. 2006); and Denver Bar Assn. v. P.U.C .•
154 Colo. 273. 391 P.2d 467 (1964). Ragusin International does
not fall within any of the statutory or case law exceptions.
WHEREFORE. the petitioner prays that this Court issue an
order directing Ragusin International to show cause why it should
not be enjoined from engaging in any unauthorized practice of law;
thereafter that the Court enjoin Ragusin International from the
practice of law. or in the alternative that this court refer this matter
56
to a hearing master for determination of facts and
recommendations to the Court on whether Ragusin International
should be enjoined from the unauthorized practice of law.
Furthermore. petitioner requests that the Court assess the costs
and expenses of these proceedings, including reasonable attorney
fees against Ragusin International; order the refund of any and all
fees paid by clients to it; assess restitution against Ragusin
International for losses incurred by clients or third parties as a
result of the respondent's conduct; impose a fme for each incident
of unauthOrized practice of law. not less than $250.00 and not
more than $1.000.00; and any other relief deemed appropriate by
this Court.
Respectfully submitted this -zsr~f February 2010
Kim E. Ikeler
57
SUPREME COURT, STATE OF COLORADO CASE NO. 05SA70
TWO EAST 14TH AVENUE
DENVER, COLORADO 80203
:j7
ORIGINAL PROCEEDING IN UNAUTHORIZED PRACTICE OF RECEIVED
LAW, 03UPL65
MAR 072005
Petitioner:
nm PEOPLE OF nm STATE OF COLORADO.

v.
RespoJldeJlt:
T. ANDREW RAGUSIN.
OlUJBR 01' INJOHC'l'ION
Upon consideration of the Petition for Injunction (pursuant

to stipulation OL the parties) filed in the above cause, and now
being sufficiently advised in the premises,
IT IS THIS DAY' ORDERED that said Respondent, T. ANDREW
RAGUSIN shall be, and the same hereby is, ENJOINED from further
engaging in the unauthorized practice of law.
BY THE COURT, MARCH 07, 2005.
Copies mailed via the State's Mail Services Division on 31ftoS'" 7lOt.I!
Charles Mortimer, Jr. T. Andrew Ragusin

Assistant Regulation Counsel 400 Inverness Pkwy., Suite 265
Englewood, CO 80112
• EXHIBIT
1!1
I
• 1
SUPREME COURI', STATE OF COLORADO
2 East 14th Avenue. 4th Floor
FILED IN THE
Denver, Colorado 80203 SUPREME COURT _
ORIGINAL PROCEEDING IN UNAUIHORIZED

PRACTICE OF LAW 1 MAR-221l5
THE
l0 F
1
STATE Of COLORADO
Petitioner: SUSANJ.FESTAG CLERK
TIlE PEOPLE OF mE STA'IE OF COLORADO
.t. COURr USE ONLY ..t.
vs.
Case Number: 03UPW65
Respondent:
T. ANDREW RAGUSIN
Charles E. Mortimer, Jr., #16122

600 17th Street, Suite 200-South
Denver. Colorado 80202
Phone Number: (303) 866-6443

Fax Number: (303) 893-5302
PETITION FOR INJUNCTION (PURSUANT TO STlPUlATlON OF THE

PARTIES)
Petitioner, by and through Charles E. Mortimer, Jr., Assistant Regulation

Counsel, respectfully requests that the Colorado Supreme Court issue an order
of injunction pursuant to C.R.C.P. 234 enjoining the respondent from the
unauthorized practice of law within the state of Colorado. As grounds therefor,
counsel states as follows:
1. The respondent, T. Andrew Ragusin, is not Ucensed to practice law

in the state of Colorado. The respondent's last known bUSiness address is 400
Inverness Parkway, Suite 265, Englewood, Colorado 80112.
2. On January 5, 2005, the respondent entered into a Stipulation.

Agreement, and Affidavit Consenting to an Order of Injunction. A copy of that
document, and all attachments thereto and referenced therein, is attached
hereto as Exhibit A
• EXHlBlT
I JJ
I
3. On February 18. 2005, the filtng of this petition requesting
approval for ft1Jng a Stipulation. Agreement and Affidavtt Consenting to an
Order of Injunction. attached as Exhibit A. was authorized by the Unauthorized
Practice of Law Committee of the Colorado Supreme Court.
4. As set forth in Exhibit A. the respondent previously entered into an

informal agreement with the Unauthorized Practice of Law Committee of the
Colorado Supreme Court in which he admitted that he had engaged in the
Unauthorized Practice of Law and he agreed to refrain from doing so in the
future. In fact. the respondent breached the agreement and continued to
engage in the unauthorized practice of law in the state of Colorado by solidting
clients and perfonning services for clients through an office located in
Englewood. Colorado.
5. The respondent has paid the costs referenced in paragraph 5 of

ExhibitA.
WHEREFORE. the petitioner requests the entry of an order approving

Exhibit A and entering an order of injunction against the respondent as set
forth therein.
Respectfully submitted this ~ of March. 2005.
Charles E. MoY"rl"''''-
Assistant Re n Counsel
2
SUPREME COURT, STATE OF COLORADO
2 East 14th Avenue, 4th Floor
ORIGINAL PROCEEDING IN UNAUTHORIZED

PRACTICE OF LAW
Petitioner:
THE PEOPLE OF THE STATE OF COLORIffiO
vs. ACOURT USE ONLY A
Respondent: Case Number:03UPL065

T. ANDREW RAGUSIN
Charles E. Mortimer, Jr., 1# 16122

600 17th Street, Suite 200-South
Phone Number: (303) 866-6443
Fax Number: (303) 893-5302
STIPULATION" AGREEMENT AND UJ'lDAVlT CONSEnlNG TO AX ORDER

OF INJUNCTION
On this 5th day of January, 2005, Charles E. Mortimer, Jr., Assistant

Regulation Counsel and T. Andrew Ragusin, the respondent, enter into the
following stipulation, agreement, and affidavit consenting to an order of
injunction ("stipulation' and submit the same to the Colorado Supreme Court
for a fmding and order of injunction pursuant to C.R.C.P. 229-237.
1. The respondent has a professional office located at 400 Inverness

Parkway, Sui~ 265, Englewood, Colorado 80112. The respondent is not
licensed to practice law in the State of Colorado.
2. The respondent enters into this stipulation freely and voluntarily.

No promises have been made concerning future consideration, punishment, or
lenience in the above-referenced matter. It is the respondent's personal
decision, and the respondent a.:ff'ums there has been no coercion or other
intimidating acts by any person or agency concerning this matter.
3. The respondent is familiar with the rules of the Colorado Supreme

Court regarding the unauthorized practice of law. The respondent
acknowledges the right to a full and complete evidentiary hearing on the
matters addressed herein. At any such hearing, the respondent would have
the right to be represented by counsel, present evidence, call witnesses, and
cross-examine the witnesses presented by the petitioner. At any such formal
hearing, the petitioner would have the burden of proof and would be required
to prove the charges contained in the petition for injunction by a
preponderance of the evidence. Nonetheless having full knowledge of the right
to such a fonnal hearing, the respondent waives that right. The parties agree
that this Stipulation resolves all matters of difference between them existing as
of the date this Stipulation is signed by the parties.
4. The respondent and the petitioner stipulate to the following facts

and conclusions:
a. On January 31. 2002, the respondent and the Unauthorized

Practice of Law Committee of the Colorado Supreme Court entered into an
agreement pursuant to C.R.C.P. 232.S(d)(3) to refrain from the unauthorized
practice of law. A complete copy of that agreement, with attachments, is
attached hereto as BJehibit l.
b. After entering into Exldbf.t l, the respondent breached the

agreement and engaged in the unauthorized practice of law. Specifically, the
respondent entered into a joint venture agreement with an entity known as
Studio Legale Padovan ("Padovan"), an Italian law fum. Pursuant to the
respondent's agreement with Padovan, the respondent was to open a branch
office for Padovan in Denver. The respondent did open and maintain such an
office in Denver, Colorado. The respondent, through the Padovan website, held
himself out as an attorney available to consult with clients in the areas of
corporate acquisitions and mergers, international trade, international finance,
insolvency law, international arbitrations and project financing. The
respondent asserts that no legal services were perfonned in Colorado, and that
he never intended to perform legal services until he is admitted to the Colorado
Bar. At no time while the respondent held himself out as a member of Padovan
was the respondent licensed to practice law in the state of Colorado or any
other state, nor was the respondent authorized under the law of any other
jurisdiction to hold himself out as a recognized or licensed legal professional.
Further, during the time that the respondent held himself out as a member of
Padovan, the respondent failed to comply with ABA Formal Opinion 01-423
(September 22,2001), a copy of which is attached as BJehfbit B to B:ddbft l to
this Stipulation:
c. The respondent has now taken measures to close his

Colorado office, and he has requested in writing that his name be removed
from the Padovan website. The respondent will use his best efi'orts to take
such further action as may be necessary to have his name removed from the
Padovan website.
P.04
'. .
;' _
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l-
....:,
\.
I'
.
S. Putawmt to C.R.CoP. 251.32. the respondent agrees to PQ' the
COlta and administrative costs in the 8'LlIU of $231.00 incurred In OOI'ljunedon
with this matt.aP' within thirty (30) daya afttJr the acceptance of the atipulatlOD
by the Colorade Supreme Court. A copy of the Statement 01 Costa is attached
hereto as ~.2. .
"
uco'MM!imA'ftOIl roB AIm COlI-lIT 10 ORDR 0, !lI'JQICTJOI
Based o~ the fO-~ the pa,\'1ica hereto recommend an order be
entered eJU~ ~ respondent &om the unauthorized pra.Ctice ot law. and
ti-t
requiring that tpe respondent pay costs in the amount 01 $231.00.
T. An~ Ragusin, the n::spondent and. Chart.. E.' Mortimer, ~r'J

attorney for ~tioner, acknowledge by einain8 this docnmen~ that they have
read and rmef the above. ./ /1 ,..~:
. ·f:
s~
l/I1"V .:
;: T. ADdrew Raguain
~ Respondent
STATE OF COqlRADO ) ~.. ~.

. r' , ) ._......
COUlfIY OF t}0?:(1c...ha:. ) . . .~; ; .
Su~ and swom to before me this 2day of J~uUy. 2005,' bY
T. Andrew ~t reepo.ndent. .'
WitnClS ~ hand and oftJdal aaJ.

My co~ufon expiru: q I t(p lo(p
,.
~.
I"Irf:tlrrw11f1". Jr. J '16122

Reg\~1~ CouDael
600 17* Streeti' te 200-s0utb
Denver. Colorac:io 80202
(303) 866-6443~~
A~fbr ~tioDer
j'
.,
.'
.'
.'
• to
• •
." SUPREME COURT, STATE OF COLORADO
CASE NOS. OlUPLll, OlUPL35
BEFORE THE UNAUTHORIZED PRACTICE OF LAW COMMI'ITEE
AGREEMENT PURSUANT TO C.R.C.P. 232.5(d)f3) TO REFRAIlf

FROM UNAUTHORIZED PRACTICE 0,. LAW
THE UNAUTHORIZED PRACTICE OF LAW COMMITTEE, \1

COLORADO SUPREME COURT, '9
Petitioner.
v.
T. ANDREW RAGUSIN,
Respondent.
T. Andrew Ragusin, the respondent, and the Unauthorized Practice of Law

Committee, pursuant to C.R.C.P. 232.5(d)(3), enter into the following agreement
requiring the respondent to refrain from the unauthorized practice of law. This
agreement shall become effective when accepted by the Unauthorized Practice of
Law Committee, but not earlier than February 15,2002.
1. The respondent acknowledges and agrees to the following:
a. The respondent is not licensed to practice law in the State of Colorado,

any other jurisdiction within the United States, or any other jurisdiction in the
European Union or the world.
b. The Colorado Supreme Court and its Unauthorized Practice of Law

Committee have exclusive jurisdiction to detemrine what constitutes the
unauthorized practice of law in Colorado. The unauthorized practice of law
includes but is not limited to an un1icense~ person's actions as a representative in
protecting, enforcing or defending the legal rights and duties of another and/or
counseling, advising and assisting that person in connection with legal rights and
duties. See Denver Bar Ass'n II. P.U.C., 154 Colo. 273, 391 P.2d 467 (1964).
Whether a person gives advice as to local law, federal law, the law of a sister state,
. eg w c
c. The respondent understands that these restrictions exist, regardless

of whether a fee is accepted for the services rendered and even if the respondent
discloses that he is not a Colorado attorney.
;m
of
1
• 1
2.
• •
The respondent engaged in the unauthorized practice of law in
Colorado by operating and maintaining a foreign legal consulting practice from
August 1997 through May 31, 2001, in Denver, Colorado and from June 1, 2001
through January 31, 2002 in Greenwood Village, Colorado. The fum was called
Ragusin International Associates, LLC, employed lawyers licensed in Colorado and
other jurisdictions, represented clients based in Colorado and other jurisdictions
on issues involving laws of foreign jurisdictions (but also sometimes affected by
Colorado law).
3. The respondent has acted under the belief that he was a member of a
recognized legal profession in Belgium and was thus entitled to provide legal
advice about Belgium law, and was authorized under the May 2, 1996 European
union reciprocity provisions to act as European counsel in European union
countries, and therefore believed at all times relevant hereto that he was not
engaging in the unauthorized practice of law in Colorado. The respondent
acknowledges, however, that he is not a licensed member of any of the 28 local bar
associations of Belgium, any of the 29 orders of advocates in Belgium, and is not a
member of the Belgium Bar Association. The respondent also recognizes that he
has not taken any "Oath of Lawyer'" before anyone of Belgium's courts of appeal
as required for licensed lawyers in Belgium. The respondent acknowledges that he
is not subject to sanctions by the General Council of the Belgium Bar Association
or any other licensing disciplinary authority in Belgium for any violation of Belgian
rules of professional conduct. The respondent also acknowledges that he would
have to submit to additional requirements, including a three-year internship with
a licensed Belgian lawyer, before he could be a licensed lawyer in Belgium.
Nevertheless, the respondent states that a candidate of law degree that he received
from the Free University of Brussels, and a license in criminological sciences that
he received from the same university, allows him to be a member of a non-
licensed, but legally recognized. legal consulting profession in Belgium; the
respondent states that this educational background allows him to advise clients on
Belgian law. The respondent has also received a Master of Comparative Law
(1981) and a Juris Doctor (1983) from Southern Methodist University.
4. In mitigation~ the respondent states that he did not hold himself out
to be a Colorado lawyer and that he did not render legal advice concerning
Colorado law. The respondent states that his activities were that of acting as
European counsel, and that he associated with Colorado lawyers who handled any
matters involving Colorado law. The respondent further states that he engaged in
oral conversations with the executive director of the Board of Law Examiners in
1991 and based upon such conversations, he believed that as long as he did not
hold himself out to be a Colorado admitted lawyer and did not render Colorado
legal advice, his conduct did not fall within the confines of unauthorized practice
of law in Colorado. The respondent states that his past belief is demonstrated by
his written communications to the Colorado State Board of Law Examiners
regarding an application for admission to the bar by one of the respondent's
associates, Timothy Langley. See statement of mitigation submitted by this
respondent attached hereto as exhibit A.
2
-.
r 5.
•
The respondent specifically agrees to refrain from operating and
maintaining a foreign legal consulting fmn in Colorado and from engaging in any
other activity constituting the practice of law in Colorado until and unless he
becomes licensed to practice law in Colorado or otherwise complies with ABA
Formal Opinion 01-423 (September 22, 2001), a copy of which is attached to this
agreement as exhibit B. The respondent now agrees that being a -member of a
recognized legal profession in a foreign jurisdiction,· as that phrase is used in ABA
Formal Opinion 01-423, requires that he possess a license to practice law from
that foreign jurisdiction, be subject to standards of professional conduct in that
foreign jurisdiction, and be subject to a system of sa.1"lctions for violations of those
standards. Furthermore, the respondent agrees that once he meets the above
criteria, he still must be associated with a Colorado lawyer in order to provide any
foreign legal consulting in Colorado. These requirements shall remain in effect
until and unless the Colorado Supreme Court or its Unauthorized Practice of Law
Committee adopt a different definition for the phrase "member of a recogni?.ed legal
profession in a foreign jurisdiction," or otherwise modify Colorado law involving the
status of non~licensed foreign legal consultants. In exchange, the People agree not
to take any further injunctive or legal action on this matter under C.R.C.P. 228, et
seq.
6. The respondent agrees that Ragusin International Associates, L.L.C., will
be completely shut down on or before February 15,2002. The respondent agrees
that he will notify each client that he has shut down his practice in Colorado and
advise the client to seek legal services elsewhere. The respondent agrees that he
shall deliver to each client all papers and property to which each client is entitled
no later than February IS, 2002.
7. The responden.t un.derstands that any failure to comply with the

term. of tlli. agreement may .ubject him to civil injunction proceedinp
purSUB.Dt to C.R.C.P. 234·240.
8. The respondent understands that he has the right to consult with

counsel of his choosing (at his own expense) before signing this agreement, and
that he has had ample opportunity to do so.
9. The respondent shall pay the costs of this investigation, iucurred up

to the date of the signing of this agreement by respondent and his counsel, within
thirty (30) days of the committee's acceptance of this agreement.
10. The respondent affmns that he enters this agreement freely and
voluntarily. No promises have been made to the respondent by any person or
agency concerning this agreement. He understands that this written agreement
constitutes the full agreement between the parties without outside promises, limits
or qualifications. The respondent's acceptance of this agreement is completely
voluntary. The respondent further understands that signing this agreement will
not prevent or replace any civil or other proceedings that any of his clients may
bring in the courts of Colorado.
3
.. ..
"
.
• •
11. This agreement constitutes an offer of settlement or compromise, and
is tendered to the Unauthorized Practice of Law Committee for approval and
acceptance. Should the Committee reject this agreement, this agreement (and any
of the statements contained herein) can not be used in this proceeding or any
other proceeding.
DATED this 3),~t= day of January, 2002.
T. Andrew Ragu' espondent

~
Subscribed and sworn to before me this ...;}
I s't day of .January, 2002, by
T. Andrew R
APPROVED AND ACCEPTED
UNAUTHORIZED PRACTICE OF LAW COMMITTEE

OF THE SUPREME COURT OF COLORADO
By: AMiI£: ~
David A. Mestas
Chair
Koff, Corn & Berger, p.e.
~~~
Michael Berger, #6619
Attorney for Respondent
303 E. 17th Street, Suite 940
Denver, CO 80203
4
• STATEMENT IN MmGAnON
•
Upon moving to Colorado in Man:h of 1997, 1 was referred by Holland &. Hart to
the Slate Board of Law Examiners for putposes of inquiring about the requirements for a
foreign legal consultant 10 provide foreign legal advioe in Colo~o. When I called the
Colorado Supreme Court phone number given to me, I generically described the gist of
my inquiry to the individual answering my call and was referred to Mr. Alan Ogden. I
then spoke to Mr. Ogden. I described with specificity to Mr. Ogden my intended scope
of activity, in particular the fact I intended to act as "European counscl." Mr. Ogden
advised me that (i) the Colorado Supreme Court had elected not to regulate the activities
of foreign legal consultants, and (ii) as long as I did not hold myself as a Colorado
admitted l~wyer and' did not render advice with respect to Colorado law, the intended
scope of practice did not constitute the "unauthorized practice of law· in Colorado.
I commenced and conducted my activities in Denver in reliance upon such advice.

When my (then) colleague Timothy Langley (a Far East Asia specialist) applied to take
the February 2000 Colorado Bar Exam.. the Slate Board of Law Examiners raised the
issue of the nature of" and potentiallaek of authorization for his (and our) praetice. The
affidavits attached hereto were forwarded to Ms. Susan Gleeson,. Assistant Executive
Director, State Board of Law Examiners, on January 11,2000. Subsequent to receipt and
review of such affidavits by the Slate Board of Law Examiners. Mr. Langley was allowed
to proceed and take the bar exam. I believed that the State Board's treatment of Mr.
Langley's bar application was consistent with what Mr. Ogden told me earlier and I
continued to act accordingly.
Based on the foregoing, I believed in good faith that as long as the foreign
lawyers or jurists in my firm (0 continued to scrupulously confule their activities to their
field of expertise. (ii) did not hold themselves as Colorado lawyers, (iii) did. not advise
clients in matters of Colorado or U.S. law, and (iv) fully disclosed such limitations to
clients, that neither the finn nor I were engaged in the unauthorized practice of law in
Colorado.
J..S·2oc:fi.
Date
T.~~··
nA EXHIBIT
I
• AFPIQAvrT •
BEFORE ME, the uilde.rsigned authority, this day personally appeared Timothy P.
'Langley. from Ragusin Intemational Associates. LLC of707 SeventeCSJth Street, Suile2900,
Denver, Colorado 80202, \Yho being by me duly SWD~ stated IS follows:
.
''My name is Timothy. P. Langley (the ''Undeniped''). from ,hgusin International
Associates, LLC of701 Seventeenth Street, Suite 2900, Denver, Colorado 80202. I am a citizea
of the State of Colorado, United ~tatcs ofAmerica, over the age of eighteen (18) yean, hav,
never been convicted of I crime and uq competent to testify to the fad! contained ber. SIUDC
being bued upon my pcrsQnal knowledge. I bereby certify and attest to the followins facti
regarding Ragusin International Associates. ~ and myself: .
1. 1 am a member of Ragusin lntematiorial.ASBociates, LLC, a limited liability corporation

duly fOIDled and incorporated under the laws of the State ofeoJar.aD (""RIA',.
2 RIA is 8 "small group of consultants that advises clients with respect to 'overseas
transactions or cperaDODs. A number of the oonsultants are admitted to practice law in
foreign jurisdictions, and are advising clients in their reapectivc ueu of qullificaticm. I
wu recruited l:!Y RlA in my capacity as ~ormer General Counsel of Apple Computer for
Japan. to assist R1A clientll wishing to CODduct business in Far East Asia, with reprds to
matters whoUy unrelated to Colorado law. I have not tieen aiked to by RIA, nor have I at
any time rendered advice pertaining to Colorado law. At no time h. any member or
associate of RIA rendered Colorado law advice and the nature of the Ictivitia ofRlA hu
strictly complied with this requircme:nl The few clicots wmdihave approached RIA
with incidental mattm ~t deal with Colorado law bllve been referred appropriately to
outside cmmscl authorized to pncdcc Colorado law.'·
Further. affiant sayeth not
WITNESS MY HAND this It
SEAL
- AFFIDAvrr
BEFORE ME, the undersisn~ authority, this day perso~allY appeared T. Andrew
Ragusin of RagU5in Intemationll AssoclatCII. LLC of707 Seventeenth Street. Suite 2900.
Dci1ver. Colorado 80202. who
being by me duly sworn, stated 81 foUows:
"My ~ame is T. Andrew Rapam (tha ''Undersigned"), of :Ragusin International

Associates, LLC of 707 Seventeen1h Street, Suite 2900, Denver, Colorado 80202. I am a citizen
of the Slate of Colorado, United States of America, over the age of eighteen (18) yean, have
never been convicted of a crime and am competent to testify to the facta contained herein, lame
, bemg based upon my' pcrsonallcnowledge. [hereby certify and attest to the fol1owina facts
regBrding $e.sfiidavit attached hereto by Mr. T~thy Langley (tho "Affidavit"):
:
.
I
. ~ •
L I am the Principal and ChiefExewuvc: Officcir ofRagusin International Alaociatel, LLC.

a limited liability corporation duly formed and incorporated under the lawa of the State of
Colorado. .
2. . All rijc: infonnation and stalemc:nts given by Mr. Timothy Langley in the Affidavit 81.1lI
truthfUl and ac:::curBte.··
~I ~ffimt 'sayeth DOt

WITNESS MY HAND this ,. ~ day of January, 2000.
:: . /
t 7- ~~
Su~'W"cd and affumcd before m.1hit ./.I!l::.. day o}9jICoe~:!!!3~~ 2000, in the
count)' of I!J..'-e;d~ • State of Colorido.
SEAL
·My couimission expircll: .3 ../I-~

() ~~£fjL~~~!laa~§~QQJ&J~nN
Forma. 0pIa1oa .1 ....23 September n.2001
FormID. 'artDenld.,.
Wltll Fordp Lawyen
,- shJp.r or 01.
I, I.r permwlbk undu tlw Modd RrtIu.for U.s. itnttJwn for", pdr"""
'0
,,,,I,la prtJC,b Itzw 'n "ltkltlorelgn ~ tin pan".,."
or ownen. QJ 10", as ,n.foreign I~n ore _",ben tja recClJIlltud l.gaI
'0
prq{,:mtJII In a len/gil JurUdktl"" tJIIf:i 'M tllTtuJ._nt II /n eOlllP(Ianr:.
willt ,n.law q{jw&dit:tiOM wlNtre 1.1"'" prat:llcu. u'''''''n olaproJu-
sloll ,,. U IIDI r,caenizcd m (J l,goI prqfuslon by 'M Jorelgn jvrIuIictiDli
'WOuld. hOlllftWlr. hi II',IMII "nOltimvyttn .. such ,1IIlI1JI.inti"Ing,M""O pan-
Mr6ltlp would .,'olfll. Rill. S.4 (Profou/tJIIIJIlnd,penMm:a DI J.mvyu).
Bfflore ocuptlng aJoreign It:rWJIfU' tU II pori"'" ,1M FUPtJIIII6l. IlI'W)'tIn In II
U.s. lIN f".", htlN tJII "hklll obllgllll"" 10 , . rwuOlltlb,. s'ttp6 'MIIN '0
,hOI'M foreign- lQ'W)W" IfIMlliftu . " . ,,," sltJlldt:rll tJIId IIIIlIIIw tln'DIIJ(I-
_ I l l II .''' eornplltJlll:' 'With ,1M ItnIf of'M jur&dit:tI"". w".,. ,1Mfinn pI'tIIC-
lieu. n. rUpoMl6,. Imv,yen In II u.s. law}inltt abo IttzIfI!I .1hkaI obi/po
,I"". 'D , . rfftUtJllQ6M s"P' to fflWll"e '1ItAI mlIll.n Ilf ,1M" U.s. oJ/icu
- -
IIIWJM", npr'.JIIIIlIII'tJII 'n (J lenip jlll'WklltJII tin IIIDIfUJ.d tlt:t:DI'"- 'If
dQllCfl with IIpplkDbl••,mem rulu. and IhtAt D11lt1'11f)'U'6 ,1Mfinn eomplp'If
with DlMr tJpplbrbl. ,lIabIll'IlIu
*")
./
As business has become more inlematioMl in IIcopc.. American business om-
ciaas wish to be repr=sented by law firms capable' of advilina them c::onc:cmq the
laws of foreign cotm1rics. To meet lhese expcctadoas. mon: U.s. law firms have
souBht 10 sain international lepl expertise. Some of Ihcse fll"lllS have formed
partnerships and similar affiliations with lawyers ftam oIber counIries. 1
".:.. ~ ....... *:",";:,,",+~.:.,.
1i
I
I. Law firms senei'll'" conduct ttacir iDeem.lienai ""ices in one of several
I
moc:lc:s: (I) Ihe global fll'll'l c....vGlS to llllintain an oKa in eacb major jurisdicliao
! IIDd same minar jurisdic:doas, providq in-dcpCh. lacallaw ccwenae; (2) the intcma-
tiona! fum seeks a-presenc:e in mo. major juri!ldicdcms IIIId a few minor ones ira which
clients need lheit prese:acc, but with litde cmpIIasis on IoaIIaw eapabililia; (3) Ihe
inlemational network calls for exclume or nonexclusiw cross-rcfaraIs and 100000law
f capabilities 11l11OIII rums ira each major jurisdidioa and many minor oaa, with firms
t-
I
ThIll opInIOn II baIecI on .,. Model RuIeII vi PnIfeuIclrIII COnduct .... ID . . UlllnlII'IcIIrI:aIId. III
-' precIeceucIf MadII Code 01 PmessIonII ~ 01.,. AmeIicaft ... MlK'Ci Ie L 'file .....
I•
I
CIIUl . . . . raguIaIcnI, _ _ 01 ptOfe8sIanIII~..... opInIaIII ~ n"liIIdIwId-
IlllljuridC.Ili. . . CiOi. . . . . .
AMEAICNI BAA ASSCJQA110N STANDING CCUMIiTEE ON mtICS AJIIIJ PADFlSSIOtW. ~
! BUrl. 141 NIdI Fa_M CauIt. 141'1 Floor. CIIIc:iIgo. ..... 1IG81'I-U'. T. . . . . (312)111-
11300 CHAIR: I:IonaId a. .... ChIcago, IL a L _ c. AIVnII. w.... _ .. DC Q .IaII!:bGn ill
sn-. Jr" ........... Wi a WIIIiIIn I. DuM. DaiIIIl. MI a ..... w. ~ PIlIItodrIIpNa. PA Q
'\ aMI'II I. HMiIon" PIIoenk, IZ. a DanIel W. HIIdebraftd. MacIIIon. Wi Q WiIIIIm H. ....... Jr~
; WItIIIngfr.In, DC a M. PeIIr . . . . IaiIIImDrIt. MD a ctN'I"ER FOR PI'lllFEl!lSlOtW RESPONSIBIUTY:
-' GeaIge A. Kuhlman, EIhIc:I CounIII; Eleen a. LIbIIor. AIIodIIIt EI\IcI CcIItIIIeI
02ClO1 by"~ ... Alaclc:flllCft.M ............
..
II IXHIBIT
~;::,
... :~
.. - :-
o!
:
I B
·.
: ..
,-- ---------- . -...... _.. . ............ - .-

~-.. ... ~
I
I ;
01-423 Formal Opinion 2
I
Growing numbers of foreign-based raw firms have acquinld expertise ia the
law and practices of jurisdictions foreisn to lhem by hirinl locally-licensed
1
la~ to help advise their cliems. Some oflhese forcip-bated law rmas eida
haw: hired US. lawyers or mcraed with U.s. law fums in onIc:r 10 ~ 1_
advice mmailers dependent upon U.s. "'.2
The Commiacc Is asked whether the praClic:c of U.s. lawyers fOlTllirlg puCner-
ships with forcian lawyersl violates the Model Rules of Professional ConduCt JIIO'"
saiplions against forming law panncnhips 01' simil.. assodatiGas with aoaIawyen.
against sharing legal fees with nonlawycn. and against enJ8IiI!s in or assisdq
BnOlher in the unauthorized practice of law. After considering the pmposes for
t
these proscriptions. the Commiace concludes lhaIthe Model Rules do naa prohibit
US. 1a\¥)'aS fi'om fonning panncrships willi foreign brwyas4 for Ihe purpMCI of
j pradJcing law. 'Ibe foreip lawya'l nI\'ISC,. however, be membcn of a ~
I
I
I
IcpI profession in abe foreign jurisdiction IUId the arranpmaIt musI be in COI1IpIi-
ancc with the law ofdle foreip and US. Jurisdictions wheN the fum ~
Fonnlag Plnunldps WI. Farelp LaW)'en
Dca Hoi Vialate All]' Model Rule
No proYisioll of the Model Rules" specifically addresses whether III forcip
t
E lawyer may be admincd 10 parmcnhip in a U.s. finn. There arc. however, pr0hi-
~
::
bitions in Rule S... against nonlawycrs sharinl in IqaI fees or being parbJeI's or .
.!
"
1 in cacb jurisdiction qualified to provide local law cxpcnUe. Each ...,. a mcmbenbip
fcc baed on size and qn:es to provide 811)' other mc:mba' firm ftellIdvic:a l1li a 1D8I-
,;; : ."" ; (cr. See gellllTlJl1jI Maircad Keohuc, NallkllllfielDI,),. ~ l..IIw. 8usoas
(Nomnl:JerlDccember 1999). For elhicallssues inYOlved ill law firm diliadons, sa:
ABA CDmmince on &hies and Prof. RlCSpOftSibility FOI'IIIIII Op. 94-31' (Relationships
Amoaa Law Firms). in FORMAL AND INfoau.w. ETHICS OPIMJDHS 1983-1998262
(ABA 2000). and ABA Formal Op.......3SI (LctteIbead Desipudion arNAffilillled" or
..AslI'aCiIIIed'" Law Firms).1d. II 4.
2. For a summary 01 stllisdcal infOl11l8lion" pIIms and IIJ'IIfqies of tbc wartcrs
Jaricsi law nms. sec Laura Pearlman. Olobll SO, available at
hnp:lIwww.!awjobs.comisurveyslgJobaISO.h_ Scan Famn. l..oItiIIIn IAr•• n..
Lort« WQ/I: n. u.K. SEll. WIIIIt ... NftI1 YorA J.Ittrpr. Bwt ~ WfIIIA Fb DIy
CDlUidu A Pllllr. MIlQlIWhIJe. n..1I' U.s. Stn.u.,1a Are A Mf11116. TIll .ANERICAN
LAWYEIl (November 2000), available at WESt1.AW. J JIlOOO A.MLAW 'I.
3. 1111 tenD "fore'" Iawya'" Is used here 10 dcno1Ir a pcrsaa wIIo has lICIt beca
licensed lenmally 10 pnacdce law by aay state. ten1101)'. or CGmmonwealdl of d1c
United States, but who Is authorized to pracdce tD a recosaiud IepI pmfessloD by •
jurisdic1kla elsewhere. Forclsn IepI consuI1anIs In: considered foreip Iaw1aS for
tbIs purpose, even shoup IhC)' may haw: quallflCCllD'Ida' IfM: laws of a stale 10 counsel
...u.s.
clien1S io d!at jurisdiction GIIIfM: laws ar • jurisdicIkl8. So, ..... New York
RuJa of lbe eoun of Appeals. Rules for tbe LiceDsiDl of Legal Consahants"
N.YACt. I SlI.1 et seq. (McKiImcy 2000).
4. The: analysis in Ibis opinion also applies to boIding membership ill limiIedIlia-
I billty comJIIIDict, 10 ownina shares ill professional associatioas. IIId 10 owniu& an
I interest in any 0Ihcr type of entity Iba pIKdces law.
i
-1
..
-- ••
1
o 3 Committee on Etbics and Professional Responsibility
holdine any other interest or office in an or,ani:z.atlon tut practices law.'

01-423
ThercfcR. if II member of the lepl professiGn of II fon:ip cOUDlr)' were COftIid· ..

cred a "nonlawyer" under Rule 5.4. he would be prohibited fiom bcilll II paI'IIICi
I
t
I'
t
in II U.S.1Iw fbm.
The prohibitions in Rule 5." an: direc:1cd mainly apinst cntn:prencwial reia-'
lionships with nonJawyers and primarily an: for the purpose of protcctiDllII
lawyer's indcpendcncc in exerciling profession8.l judgmeDt os the client, behalf
free from contJol by mmlawyers.6 Thil Comminee c:cmsiltcudy hu intcrpreled
I
(
5. ModellWk 5.4 JUleS:
(a) A lawyer or law rum shall nOl shan: Ic:pi fees with. nonIIIw)'cr, exc:cpC dial:
aan:eman
(I) an by a lawyer with thc lawyer's rum" pIIUIIIr, or ISSCICiaU:
may provide for the paymCIII of money, ova I JaSOnIIbIc period of lime after
the Iawycr's death, 10 the lawyer's CSIIaIC or to one or more specified pascms;
(2) a lawyer who purdIases Ihc pl"llc:dcc of a cIcc:eued, disabled" or disap-
,
i
peared lav.ycr may, pulSUIIIl110 Ihc provisions of Rule 1.7, pay 10 the estate or
other rcprcsc:madw; of lhallawyer Ihc asrced-upon pun:huc price; and
(3) a lawyer or law firm 1M)' include nonlawyer employees ill I ~
salion or redn:mcnl pllln" CYm thoup the plan is bIIscd in whole or in pan oa •
profiliDa...... III11UI&CbICI1L
I
(b) A lawyer sbaU noI form a panncrsbip with allClftiaw)'er iiIIII)' of tile acdvidcs
ofn panncrship consist oflhc ~ of law.
" ,.,. (c) A lawyer shill DOl pcrmil II pcrsoa who rccommcnds" employs. or pays tile
Iliwyer 10 reader IcplsaYiccs for IInOthcr 10 direct or n:pIaSc the Iaw1a's profasfaD..
aljudgmcnt in ~ IUdi Ic:pi scrrices.
t
j
(eI) A lawyer shill noI prac:tic:c with or in the form of II ptofcssicnal carponatioa or
association lIuthorized 10 pnctic:c law _ • pront,. if:
(I) • ftonIawyer O'WBS 1111)' interest Ihcrcia, cxccpc that II fiducitlry rq:n-
sentlilive ollhc CSI.IIC ora lawyer 1M)' hold"1IM: Itodt or imc:rc:st of the 1aW)'a'
for II n:::asonable time durin& administnlion;
(2) • 11OnJaw:ycr ill c:orpanIC cHRiaor or ofIk:er Ihceol; or
(3) • nonlawyer has Ihc riabt to din:c:l or comroIthe professional juda-
mad or llawyI:r.
The Districa of Columbia is the only U.S.jurisdicdoa that IIIowIIawyers 10 baw: "
nonllwyer parlnCl'S subject, howcver, to striogaat c:oaditiou. S. D.C. RtIIc of
Professional Conduct So4 (a) (4) - (b) (2001).
6. Su Rule S.4 colli. In. 1bc Me was developed in Ihc ABA Hause of Dc.Icpta
durina dcbala OD the Kulak Commissiorfs Proposed Rule '.4. which the House
rejected. Sa 2 G.c. HAZAIID AM) W. W. HoDEs, THE LAw or LAW'YEII.ING (lit eeL
2001) f 4~. TbreaIs 10 lawyer professional indepenc:leacc n:suItiD& IiOlIl c:ocpontc
ownership or public inYCstlllCld ill lew rums !Cd Ihc House of DcIcpta 10 suIIsdftnc
nearly vabI1im the provisioDs of Ihc discipliDary rules in Ihc fGl1llCl' Model Code of
Professional Conduct for the Kulik Commission's proposal. sa ABA Model Rules of
Professional Conduct (2001 cd.). ConeWion Tabla, Table A .. 123. where it is DOCed ".
thai aada paraaraph of Rule 5.4 is subslantiall)' idc:naa.. 10 a disciplinu,y ........
paragrIIpI:a (I). Co DR 3-I02(A); panaraph (b), 10 DR 3·103(A); p1II"IIIWpb (c), flO DR
S·I07(b); and pIU'III8IIh (d), to DR j.107(C). Su HAZAIID A Ib:e /It .. ch. 4' for.
. -----
-- ' -.;
r 01-423 Formal Opinion
Rule 5.4 willi this purpose in mind, and on occasion bas rejected a literal appJic:a.
4
don of its povisions ..... did IlOl accord widB the purpose far the Rule.7
Rule S.4 accomplishelthis purpose by requirinc that lawyers, to the cxc:iusiOa
of nonlawyer'S, own and control law prac:dc:es. which thus helps asSure 'Chat clillllS
are BCCOAIcd the protec:lions of Ihe professional standards lawycn must mabataiP-
The Comminee believes Ibat foreip lawyen who are members of a recopimd
legal profession are qua6rlCd to accord these same protecdoas 10 clierds of U.s.
Jaw firms in which they become paI"IMU. Therefore, those foreip lawyers should
be considered lawyers mhcr than IKII'Ilawyers for purposes ofR. S.4.
This cqncepl fmds support ill Rule 7.5(b) because that rule recognizes that
there may be assoc:iadcms in law practice with !awyus not admiUed in the juris--
dictio... and requires only ..... Ihe fum indicate '"the jurisdicdobal limiiauOlll 011
those not licensed 10 practice ill the jurisdiction where the Oft"'1CC is.loca&ed....
When the Modd Rules wen: adopted, some U.S. law firms bid foreign lawyers as
pu1neIS: hence. BOy infalt 10 Rndcr the praclice a rules vioJalion needed 10 be
clearly staled. Yct P01hin& in this or lID)' other Model Rule,. or in the legislative
history of the Model Rules. suggests ihIt Ihe lenD "jurisdiction- IS used in Rule
7.s(b) cxcludesjurisdicdons outside the United States.
i
;
critique ofeacb paraamph of Rule 5.4 as ICIoph:d.ln Fehrualy 8nd AuJUll2DOO. con- .)
cem th.!d admission of nonlawyer professiollllls as putnea in law firms wouJd infaIo
........ fen: with IaW)'Crl' profasiorW ~_ ~ ~ofdlec.ore ...... of
.>11
the profession led Ihe HOUle of Ddcpta 10 n:jed pn:IpCIAIs 10 allow par1Df:rIIdps
wid! nonlawyer profcssioalds and 10 dIrec1 dud no . . . . be . . 10 Rule 5.4. S-
ABA Hause ofDelcpII:J l\eYised Report KIF, adcIpced Ju" 10.11,2000.
7. SU...... ABA FOrmal Op. Formal Op. 93-374, FCIUtW. AND INFolu.w. Enitcs
OPIMOHS 1983·1991 .. 182-84 (analyzina 1hc fOW' panpapbs of Rule 5.4 in 11_ of
its purpose to prolecl professional independence and c:oncIudin& thai Ihe rule is DOl
violaled by • Jawya's sharin& court.awanlcd fees wid! • pro boDo crpniza1ioD b
sponsors the litiption; the eonelusicn \VIS based penly on the abalenc:e in such f~
sbarina of an11hra11O the lawYer's independcDt professional judgmcnl); ABA Formal
Op. 880-3'6. id. .. 35 (payi1J8 service fcc 10 B s.emponsy IIIwya IIpIIIC1 baed OIl • per-
centage ollawya's WIIpI did 001 consdtute DkpI fcc-sp1i1Wla VIIdc:r Rule 5.4(11) or a
vioIaIicIa ar... 5.4(c»). •
f
8. Rule 7.s(b). In dJc former Modd Code ofProfessiooal ResponsIbility.1he simi-
IIII' provision, DR 2-102(D). was phrased ~ raIber than pennisstvdy and
pnwided thai. law pII'IIliasbip
shall DOl be formed or continued bctwcaa or IIDOI'II lawyas licensed in difl'CRIII
jurisdicdons unless all enumcralians of the manbcD and IIlISOCi8tes of the firm on
its Icaabcad IIId in ada pamimDie Jislinp make clear the jurisdictionalilmha-
lions on those members and associates of !be fimllIOIliccnscd 10 pracdcc In all list.
c:djurisdidions; bowcw:r,lhe same filTl'llllmC maybe used in eacbjurisdiction.
meters tbr propaty 1-.

We believe the DR is the same in subsIancc as Model Rule 1..5(b). wIIich SCIS. the para-
DOUdmitlc:d Iawyas In sudi a way. to comply with die
Rule 1.1 pnIICriptioIIag'" maIcitIB ... false or misIc:acfiq communication aboua die ~
)
lawyer or Ibe law:rcn serviccL-
.' ........,
'
..... !
"
fII'.
-
S Committee on Ethics and Professional Responsibility 01-423
o . The American au Assocililion has. moROVCl'. rccopaized the desirability of

assuring the eYBilebiBity of foreign J8'W)'erI 10 wise clicatl ira die United Stafa
with issues involving foreign _ and has funhcR:d Ihe reciproc:aI opportuIIiJfa fer
u.s, lawyers 10 pracIicc abroad by edopt.ias • "Model Rule iJr the Lk:ensinl of
Legal ConsuIIllnIS.'" This rule specifICS thId lic:cnIcd foreign IepI consultants may .
, be partners ialaw firms, thus accordins some RtOIP1ition to the amng~ 10
i Rule 5.5 11 provides I basis for disciplinil1l IIwyers when they violate or assist
l in • violation of e jurisdiction's law praaicc admissions standards and unautho-

rized practice of lew rcgulations.l:Z These standards and repletions en: for the
9. Su ABA House of Delqala Ilepan lOSE, SruruIIuIty of-Adlolt T.a.I&n by •

H __ oj Dekglllu". AIItfU'it:I;n IkIr bloclmUm., ABA 1m AMluAl. MEETING,
NEW YfJRX,. NEW YCIIUt, Auausr 10-11, 1m, 29-34.
·t• 10. Once licensed. end willi specified limiLlticu 011 Ihe sc:opI of.the IepI consW-
UIOl's prac:dcc.1he consuIIaal is subjecllO Ihe licensiqjurisd~'s rules ofproCCs-
sional conducl and 10 discipline then:: and is subjecllO !he lIlGnIC)'-CIienI. work'1'fOd-
I•
I
ua. and simil. profcssiorual pivileJCS. fI 5, 6, It/. e.31·33. Not surprisinslY. fCSUic..
ljOIll 011 the scope of pniICIiol:. I 4, ill. It 31. resemble these ... lawfully could be
imposed on I kpI profcsskma.llieeDscd in one Eurvpcan comJI1UIIity member COUfJtIy
I wimina 10 prec:liCl in IIIIOlhcr. $c. Dctfcy F. Vqas. Prqfu61l11f111 Rapomlbility III
TraM"'_ P,.«lit:tl: ConjIlt:l ami RuG/filion; 13 Gm. J, LEo. ETHICS 6", 616
'.')
: "j. . ... loloo
I
f
!
(2000) (describin& Ibc eO'ecI·of.Rcynen v. Bel&l-.. 1974 E.CJl. 611. whIcb Rands
for the proposition Ihat citizens of'OIba Eunlpan ~ c:III1IlIGI be excluded by
one SI.IIU from the pI'lIC&iCI of law). The ABA Model Fordp Consultant Rule is nearly
Identical 10 the New York Rull: en lic:ensiPa forcEp • • ~ . . . ROle 3.
II. RIlle ,.3 stata:
A Iewyc:t sballaac
(e) prac:lice lew in Ijurisdiction where doing so violela the RluWon of
Ihc ICpI professioa ia Ibeljllrisdicdon; or
(b) assist. penon wOO is nail member oflbc bar in the pcrfonuna: of
or
activity daat constitlltes Ihe uneulbori:red pncaicc IIw.
12. 2 H.W.ID A HOoe, mpNI note 6, III I 46-3. "Prac:dciDlIaw" is • repleaory
l
,
f,
concept depcndeat upoD Ibc II. of eacb jurisdiClio.n. Approprielc lulhoriudon 10
practice In. Jurisdiclioa usually is gaiDed 1hrough bar cxamiDadaa end pncraI admil-
sion; admission as ltewycr either oa motion or tIIrouP a . . . bar examillelion; pro
hac 'lrICl admissioa for OCCISionaJ appceranc:a in COUl'1S" lllbiblllious. or adm~
hearings; euthorizatioa lOr ID-hou.se COtIII.SCI to .epiUUIII ber anpIoya; spa:ial11cen-
sure as I fORip lepl consuI1am; or (as allowed by $18_ rule ar c:ustcIm) tcmponIIy
appearenccs ill • jurisdic:tion in fUltherancc of metiers baYiDa • RIadonship 10 anodIt8
jurisdlClioa in wbicb die IIwyer is luthorized 10 handle the lepl ma1ter. S .. I
R£;sTA'fENEN'r (TaM, or 1HE LAw GovaNING LAWYEIIS. Topic: 2. Tide B § 3(3).
J",.lsdieIIOM' Se., oj ,It« PrcclJR of La", by II La.,. 24 (2000) (hereinafter
"IlEnA't1!NEN1"'1. dcf", !he jurisdicdaoal scope: or Ihe practice of Ia. by • lawyer
o as includins provision of IepI services 10 • clialt " ... place widIiD • jurisdiction in
wbidllbc IawyCl' is DCI admitlcd 10 the c:xt.cnIlhld die IIIW)'II's ecdvities IIrisc out of or
en: otbcnrisc rasouably n:Jat.cd 10 the lawyers precliec ia another jurisdJcdon where
allthoriza1.· See IIboi:ma. c.1tL &126-30.
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01-423 Formal 02inion
purpose of protecting clieta and Ihc jUrisdiction's IepI system tiom the adverse
effects of incompetence or unethical conduct. lJ The rule is DOt violaced by • r.
6
0
I
eiBn lawyer who. ahbough • plUU'lef or lISSOCialC in a law finn that has 111ft offICe to
pradice law in Ihc jurisdiction, ncverlhe1ess does nOl himsdf-pI1ICtice laW- in the :
jurisdiction as the lam is defined Ihcn:.
For these reasons, Ihe Commitlee is of Ihc opinion 1hat U.s. lawyers may in :
general form pannerships willi foreign lawyers provided die fomgnlawyen satis-
fY Ihc requirements dexribed in die I'ICXt pan. I
The ForelgD Lawyer Mud Be a Member of a Recoplzed Legal Profess_ I
In order to qualify as a foreign lawyer for p~ of'Rule 5.4• • penon mud
be' • member of. rccopiz.c:d legal profession in • foreip jurisdicdaa. The tam
"profession" itself Ecncndly c:onnc.u:s the atrrib..des ofc.'ducaci0li and formal train-
ing. licensure to prac;tice, standards. and • systan of sanc:tians for violll1ioas of'
the standards. I" There ncwrlhcJess is no.arbihry definiticn of"lawya"" or 0I1cpI
profession" that must be applied to determine wbeda • person in • fGRip juris-
diction is a lawyer. The determination essentially is facmaI. rcquirinl considera-
tion of the jurisdiction's IepJ S1rUc:twe as. well as the naiure of the lICI'YiI::eI QISoo
tomarily performed II)' the persOns in qucstio:n- . .
Generally speaking. • person who is ,pccially Inlincd lQ provide advic:e on the
laws of the foreign jurisdiction and to represei1I clienlS in 1m . . . system. and is
licensed by the jurisdiction to do so. will qualify as • foreip lawyer. Before
ac:ccpting a foreign lawyer as a parmer. the responsible Iawyas of' a U.s. law film
(-)
~ ' ... -4
ens.
must take reasonable steps 10 ensure that the fomp lawyer Is • member of'. n:c-
ogniz.c:d lepl profession 8~ to in Ihc pncticc of'law in 1hc foreip
jurisdiction and 1hat the arrIIIfIgcment complies willi tile law of the Jllrisdicdons
where the firm prK'dces.1S For example. fore. . lawyers admiaed to praclice ill
13.S,e. fI.g•• RESTATEMENT. Topic 2. Titk A• .4d",I",_ '0 Prtu:"c. lAw.

IntrodIli:IDI'JINOie. ,llpNJ nofI: 12,. .. 16:"'[iJo gcnual. ajurisdiction's requirements for
admission and for n:ncwaI of II license 10 prac:aict law II"C best dcsipcd wbert direr::Ied
pri~'y toward protecting Ihc tcpI system against incompclad pI'IICIitiaacn ot Ihase
wbose professional ac:ts would prcdiaabl)' c:ausc.harm to diads" Ihe IepI sysICm or
Ihc public."
14. A precise ddinition of"'profeaian'" has been suh~ 10 dcbaIc. s.. ......... . 111
~
Iii. SpirU Df Pu611c Se",/ce:" A BI.eprlll' /0' ,.. RdllNllI"6 0/ lA""..,
Pro/WionDlimI., 1986 ABA 0:M.ass1aN ON PIlOFESSIONAUSU 10.11 and soun:es cited
tberein. Dean Pound cites IS d!ree anributcs ofa profession: orpnizatian.lcamias. . .
a splrle of public service. &I. ROSCOE PouND. THE LAWYB FlOW AImQuny To
MoI:aN n..a 4010(19.53).
I'. Slate and local bar ethics committees hIVe Imposed limilar obUpIions on
lawyers in fIlmS 1hal admit fGRip lawyers to pannership. s.r..
&g.. A.ssociadon of'the
Bar of1be Cd)' of'Ncw VOlt eonmunee 011 Pn:I(. and Judicial Ettaics formal 0,. II·
72 (commcntinlon lenerilead clesiplions offorelp lawyers and notin& IbIt wbeIber
New Yark lawyers may fonn a parmcrsbip relationship widl • foreip law fil1ll
., requires a factual Inquily "whether the nining of and ethic:aI srandards applicable to r)
\.
the fGRip lawyer are comparaillc to those fot 111ft Amcric:aD lawyer" SUICb 1hal the for-
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7 Committee on Ethics and Professional Responsibility 01-423
!
Sweden, Japan. Great Britain and odaer European Union countries would satisfy
thc:se requiremenu and have bcca fOUlld by bar association ethics &ommitter:s to
! qualify for pu1nCtSbip in u.s. law fum.s. 11
i, It: however, professionals in. forei&n jurisdiclion are not members of a recos- .
!
niu:d legal profession ill that jurisdiaion., Ihc professionals should, in our opinion.
i be considered non lawyers rather 1han lawyers for purposes of Model Rule 5.4.
Hence, they would not be eligible for panncrsbip in a U.s. law firm. For example,
qualification as forci&n lawyer for purposes of Rule '.4 ordinarii), should be
accorded memben of the profession of nocII' (CqunrOODl lawyer) or ctNUell
jllritJiqrM (transactional Of business lawyer). buI miPt not be acconIcd members
of the profession of lttJIario or notary, • substantially different fUnc:lioaary in most
c:ivillaw jurisdic:tions.''1 In some eounuies. morcovcr,1htn II1II}' be no rccopUud
c:ign lawyer is • "lawyer" within the meaniD,c of DR 3-103(A) or Ibc New Yoric Code
r of Professional RClp~sibili1y); UlIIh s.. Bar Elides Advisaly 0,. 96-14 (J8IWII\Iy
24, 15197) (UUIh lawyer may fonn a pIJ1nerSbip or associall: willi lepl pnclitianas
I from a forcip country who are authorize4 by Ihc laws of the fORil" country to
I cOl. in !he funCiionaJ equiYa!cnl of U.S.lcpl pracdcc).
16. See New yurt SL1dc Bar Ass. CGmmiua: 011 Prof. EIbicI Op. 6SI (1994) (under
I
DR's 2-102(C). 2-1OZ(D).l-103(A). is is permissible far SVIedish Jaw fum to farm pII't-
nc:rship wid! New yurt flnn. subject to ccmpliulce willi law): New Yodc SIIIIC Bar Ass.
Commillcc on Prof. Ethics Op. 646 (1m) (approvina par1ftCr.Ihip with Japmese lawyer
.,.
. ... ....
I .'_} pncticiJt& in New Yurt); New YOIt SIItc S. Ass. ConuniI:Iec on,fa'DL Edlics Op. 542
(1982) (approylnl partnersbip witb British solicilar to practice in New YOJII:) •
I
' ~
Philadelphia Bar Ass. Prof: Guidance Comm.iIIee GuidIna: Op. No. 92-19, 1992 WI.
40.5939 (December 1992) (Pcnn.s,ylvlnill law.ycrs may farm pIIrtDenIrips with lawyers
admiacd to prac:lic:e ClUlSidc U.s.); Iowa Supreme Court Bd.. ofPlVf. EIhic:s and Conduct
I
: Op. 97-25 (MardI 3, 1991) (Iowa lawyer may practice law ill. pII1DerShip dud includes
!
Enllish solicitors praClicina in EngiaDd and Wales). umptll'e wll. Viqinie up
~ 0,. 1743 (April 13, 2000) (imp'oper far a Vqinia lawyer to farm parD'Iership
with a foreip legal c:onsuhanl DOl admillcd to pIIdic:e in Ihe u.s.; lawyer liccmed ill
another countl)' considcrc:d anon-lawyer" far PIl1'pOSa of VU'pnia'lII UnauthoriD:cl
Practice of Law Rules. VI, S. Ct. R., pi. 6, f I). So Ql60 Laurel S. Terr,y, All
I IntTOdvalDn IlJ 1M E.wopetm CCJ"""~ uJGl ElJJicr C_ Pm I: All AIIIJ/y:rU oj-

CCBE CiHIII ofC~ 7 Gm. J. Of I.a:IAI.. EnDc:s I (filii'") (Cl.'llDpeheDslw . .
cussi. or the CCBE (Europc:an Bar Council) Code of Profc:ssioaal Conduc::t and Ihc
rcladcmhip of ks provisions to Ihe various rdI.iDd. bid dift'tnIIr. pn:wisiODs of I'I'I8IIy
European UuiOD COUIIIries).
1
I
17. In BelaiwD. 't]nD.sfcr ofral c:sL1dc and audacnlica1ion of signatures. wills, CIc.
is the monopofy of notaries. who remain orpnizcd scpan&cly from tbe lawyen.
I Whaas lawyers haft die possibility sa IIdvise in matten fIIIiD& wiIhia Ihe compo.
,i lcnce or notaries. they have DO aulhorily sa perfonn dJc official fuactioas of. 1IOCaI)'.
Quill: ol\cn" the notar)' and lawyer wiD Ihen:fCII'C work 1OJCIhcr, although it is not )'CI
permilted that lawyers and notuics combine their offices ia the firm." Roel
Nieuwdorp. &1,_ ira LAw WmIOUf FII.OimERS. A OIwPAltA11V! SUIt'VEY 01' TIll
RULES 01' PItOf'ESSIQIW. E'1'HICS AIPUC:A.ILE 10 CJtoss..lklmI!a PRAcnc::E or LAw 30
Q (Edwin GodfRy cd. 1995), a pJblicadm CODtairJiD& essays on Ihc elhk:al and repJaro-
I)' rules appIablc in most EaIopIaA u.uc. COIIIIIria.
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01-423 forma! Opinion 8

l ~
lea'; profasiOil. In chili case, admiItins the fon:ip professiotllllS a pIIII'Ina' or

sharin; IcpI fees wiIh aM foreign professional also would nat be ethical., per-
missible under Rule 5.4. 11 '
The law and ethicai standards applicable to aM lepl profession in foreip •
countries will differ fiom some of the law mel ethical S1andards dill app.,
to U.s.
lawyers. For example. the scope of dicnt c:onfldcnllalily may difl'cr.Just IS Rule
1.6 and the auonacy-dicat privilege differ amon& United SIIda jurisdic:tions.19
This difference would not disqualify. forcip lawyer ftom puUlCIsbip ill a U.S.
law firm. However, when necessary to enable a c:lient 10 make inf«med decisions
about rcprcscnt8don in • fomp jurisdiction where the attomr:)'-c:licftt privilege is
materially more limited than in the United States, alaw)'er 'II'IOItin& em the md.er
in a U.S'. oflicc has an obligatian ullder Rules 1.4 and 1.6 10 uplaio the riIb of
diminished protcctioa to the c:1icDt. Moreover, responsible Iawycrs ill U.s. law
firms must, in accordanc:e with Rule 5.1,lI! make reasonable effons 10 ensure that
II. The Model Rules would noc. however, bar • amtnldual rdaIicIasbip willa a scpo
UIIIC orpniutlem ia whidl thc fon:ip profcssioaala wae putnas .... could, wiIh
appropriate disdosun:s, abo be partly owned by U.s. IIW)'a'IIIS a 1aw-n::1a&cd entity.
Sft Rule 5.7. Law;yers also may use nonJawycrs III "'paraprofessionllls" to assisa them
in the pcdOl'JllllllCe of lepl sc:rviccs lIS 10111 as the 11OIIIa"')'Cn an: supc:rrisrIrd appro-
pilllel)'. Sc~ Rule 50S emL IIJ (nol lWislinl U1UNthorizecI pracdct far a lawyer to
employ "1hI': sc:rvic:cs of paraprofessionals and Ide....lJICS) functions to diem. as kina as
thc lawyer ~ Ihc deleplCd wort and n:I.IIins rcspoasibilily f. their work"" lIS
provided in Rule 53). "
19. Wholly . . . from admission of famp 1aW)WS to ~ ~ c&nI
confidenl:cs is a II'II\Ior concem in any ~ IepI . . . . . . . . ID _ dvil
law c:ourdries, Ihe atIOI11e)'-diall privilese applies difJ'crend.r. and l1li)" _ apply III aU in
$OlDC ciraJmsIances when: it would be applicable in Ihe United s.e.. ,.,.• 10 CIOI1IInUIJi...
cadons willi iD-house. corponte counsd.. Sft pllll'tJll.1 DaistcYashidII,. 11M Appllt:ablllly
0/ l/rt AIl~limf Pml. 10 COlJrlr..mi.cDIlC/IV willi Ftllflpl.qol Pro./U6kNtD1s,
66 FORDHAM L. RI:v. 209. 227 (1997); Joseph PndI, TIttt PIInIIII,"'" 0/ II. AllOrntIy-
Cli,,., P,lvll,p fIN' I".Hou.r~ Coua,' 01 Ih, 1"'~'lfIlllo'" IANI: "OI~CI;". 1M
Compmry" OJrIid«IIIW IIffonnatJtm. 2ON.W-l. bon\. LAw a: Bus, 145, 159(1999>-
20. Rule 5.1 sIIIIa:
(a) Ii. pail'IDCr ill a law finn shall make Je8.SODIbIc cft'_ to CIISUiI'8 dill the
fum bIs ill effect _ _ pins reasonable IISSUI'8DCe . . . III IIwyas in Ihc finD
confom to Ibc Rules afProl'cssioftal ConducL
(b) Ii. lawyer haYilll direct supervisal)' autborit.Y cm:r uodler lawyer &bill
make rcasonahIe cff'ans to cnsun: ahaIthe oIher lawyer confOnDS 10 Ihc Rules of
Plofessicul Conduct
(c:) A JaW)'fIt shell be responsible for another lawyer's viole!.ioa oflbc Rules of
Professioaal Coaduct if:
(I) the lawyer ocdcD or. with bowledse of the spccifie c:oraduc:t, ratifies
the CCIIDdIac:t imfolved; or
(2) the 1aw;F is a p8I1DCl' in Ihc law firm in wbich IhI: odtcr lawyer pnIt>
tic:cs, or bas dln:cC supervisory lUlhorfty tIW:I Ihe: ocher 1aw7er. and Jcnowa of
the c:onduct at a lime when ill COII!CqUcnCa can be avoided « mitipled but
faill to 1akc rasonaIIIe rcmediaillClion.
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Ii
9 Committee on Ethics and Professional ResponsibiHty 01-423
I ciiem infonnation respeaioa matIcrJ in their U.s. offICeS is protected in accor-

dance with Rule 1.6, thai conflicas with Ihe intcnI:SlS of diads with U.s. maa.en
are manaaed as Rule 1.7 and . .ted rules requiIe, IUId dI&I all the Ipyers in the
firm comply with other applicable rules of professional conduct.21
finally, when foreign lawyers IlR panhCIS in 01 otherwise are 1lSSQCia1ed with
U.s. law firms, the U.s. lawyers in Ibe ftnD arc prohibited by Rule ,~) mxn
I
I:
assistilll their fOleign partners IIIId associates ill what would be ,dccmc:d the uaau-
lhoriuld practice of law in Illy U.s. jurisdic:tiOIL Callina upon • fon:ip lawyer to
provide advice on the law of. foreign jurisdic:tioo to a diem whO is 10CIl1Cd in a
U:5. jurisdiction, however, onlinalily should DOl violate'Rule 5.5 eYeD thoup the
foreign lawyer neither is admitted 10 pm:dce senerally DOIIicensecI as II fomp
legal c:onsuiu.nt as 'ons
as the foreign lawyer is DOl regulerly iD the jurisdidion
and the nudler has a relationship 10 the juriJdicUcln in which the romgn lawyer is
admitted or otherwise permitted to pracdce.D
I Sum...."
I In the CommittA:e's opinion, i1 is ethiA11y permissible UDdIir the Model Rules
II for U.S. lawyers 10 form partnerships or OIlIer entities ill wbicIJ fomp lawyers
I an:: partner1 or owners. as Iona as Ihc foreign lawyers In meinbeq or a recog-
r nized legal profcssiOll In the foreisa jurisdiclion, and the arnnscment complies
with laws of the U.S. and foreign jurisdic:tions in whkb the fum prac1ic:cs.
f PersGIIS who In not members of • recognized lepI professioa, including dIOSe
i from jurisdic:tions with no rec:opiz.ed Jepl-pofcssion, de not qualify as lawyers
-..,; .. , ,- -4 for purposes of Rule 5.4. R.esponsible lawyers in • u.s. law firm must ........
! sonaIIle effOlU to ensure dud foreign lawyers admitted to parblersbip or 0wner-
ship in die firm Atisty these requirernenlS; that the arranpment Is mcompIiImce
t with the law of jl.l1isdictions where the fum prac:lices; 1baI I1I1I&fcn in their u.s.
ofl"1CCS that involve reprcscnUlion in • foreign jurisdiction In manapd in' 1iCCOI'-
dance with applicable Model Rules; IIJId lbat all lawyers in the firms comply with
other applicable ethical rules.
21. We apply the tenD "rules ofprofcssiaaal conduct'" 10 maD Ihe Model Rules,. if
in effect lit • jurisdiction, 1M if IICIC, odIcr cIenomiftaled cdDcaI II1II disc:ipliDary . .
dards in c«ect in U.s. ud foreip jurisdktioas, the rules in which apply to the c0n-
duct in questioa. We do nDC, boweYer, IIkIres:s bere die difticuIa choiec of law _ _
that arise when delcrminins whicb jurisdiaions' clbic:aIlUId discipliDary stIIIIdards
apply to lawyers cnpaed in • multinational lepl DIIl'IcI. S. Model Rule l.S(b).
22. See. e.e.. Virginia Unaulborized Pracdcc: on..
w Commiaec Op. No. 195 (April
Il, 1000); RaTAm.tDn', npt'tIllCIfC 12, .24, Topic 2. Title B f 1, .lllrUdktltIIfIJI
Scope oft. Prot:tb ofLtrw by D LtrwyIt' 24 (mddadaI wodt in I jurisdicdoa where a
lawyer is IlOl admiUcd to practic:e dial is related to I Icpl mau.er on wbicb Ihe lawyer
worlcs from an offace in • jurisdic:tian when: Ibc lawyer is admiIIed does DDt iIm:IIvc
0· unauthorized pm:dce of law). fRIfJI an C'lhical SI.BIIdpoUIf, 8 fORip lawyer shGuld be

aft'arded tile same trc:atmclll .1thoc!Ih the law ill cadl Jurisdiclion derermiaa what
c:onduct const.iIUte:s WI8UIbori:&cd pracdce of law.
..,.', ~.... ~ .. - - " , - ; , . _ . . . . . "I.. •
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Statement of Costs
T. Andrew Ragusin
10PDJOOl1l01 PDJ035/01 UPL035

01 UPL11103UPL065/09UPL142
09UPL127/09UPL140110SA067
4/412002 Courier Service 4.00

6/6/2002 Camera & Developing 23.30
6/20/2003 Translation 30.00
712412003 Translation 30.00
9/2612003 Translation 280.00
9/30/2003 Camera & Developing 52.22
12/15/2004 Deposition/Ragusin 120.00
118/2010 Translation 1,596.09
1120/2010 Process Service 45.00
2/2/2010 Courier Service 20.90
2112/2010 Deposition/Johnson 422.00
2116/2010 Deposition/Reynolds 278.75
3/5/2010 Process Service 37.00
11117/2010 Administrative Fee 91.00
Amount Due $ 3,030.26

··T-- .--:r----... . _.- ----
.--' I
4/04/02 831276 OS SUPREME COURT ATTORNEY REGULATION
bOO-17TH sr
KDOS AND BERBER
303 E. 17TH AVE
4.00 I
I DENVER CD DENYER CO
Caller: ELVIA Kgnt: 1 Lbs
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RITE AID iii
~ /' --It's nor iust a store. It's a solution~
WOLf CAMERA 013&3 (303)-592-7991
1&th St. Mall INTERNET ~ REFILLS'!'
www.RlteAld.com
1363 11 7168 4124/2002 621e3 . . _.d ~¥ O:i!"q;SIct"....t':r.1:.
5~ 1390a:?9 f'UiISAVER 35 W/FlASH 5. 9'.J

SUBTOTAL 5.99 Store #OGlES
"A:(ABlE 5.99 750 16TH ST. I~ALL
TAJ{ .43 - - OENVER, CO 80202
ro"AL 6.42 (303) 534-7824
TENDERED vm~ 6.42 Register #9 Transaction #197002
4323853366378~l02 9/03 712720 Cashier #61861784 6/06/02 9:40AM
HICKERSONl ERIC
ASSOCIATE: HEa 1 ONE HOUR PHOTO 15.75 T
1 Items Subtotal 15.75
Tax 1.13
This receipt .ust be with all returns & Total 16.&8
wammty repai i' requests. ndse must be "'PAID BV VIS"'" 15.138
\1et1, in original packaging IrIith unopened VISA card ~ #XXXXXXXXXXXX8902
software. All digItal video &cellular _ _ _ Ex!> 9/30/03 App 1# ~.JTO
IInits IlUst be returne~ within 1a dal's. Ref # 216893
All others must be returned within 3D Card Present
days. Cash reflllds over i5S paid by T·.J " I ·S.88
check. .00
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TOPS FOAM 4109

( ,
6/20/2003
Translation
Michael Amon
$30.00
Case Numbers:
01UPL035
OlUPLll
6559 Jungfrau Way
Evergreen, CO 80439
July 24,2003
Susan L. Berry
Administrative Assistant
(303) 893-8121 X 307
Colordo Supreme Court
Attorney Regulation Counsel
The charge for this translation (letter from to Christine Weirauch to John Gleason reo
Andrew Ragusin) is $30.00.
Please send a check payable to Michele Amon to the above address. Thank you.
Sincerely,
Michele Amon
(303) 670-3149
i ' •
9/26/2003
Maria Halloran
Translation
01UPL035
$ 280.00
February 28 1h, 2002
Dorothy -
Here are the receipts we discussed on the phone - pi case reimburse me, directly. The
expense~, were necessary to purchase disposable cameras and then developing the film.
I've higr lighted my actual cost for each item -
The case information is:
\l
People v T. Andrew Ragusin, case #'s 01-PDJ-OOII & OI-PDJ-03S.
Y~1f ~
wit!, any questions, ext: 304 - thanks
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It's not just CI store. It's a solution::.
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It's a solution:
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INTERNET ~ REFILLS\!!
www.RiteAId.com INTERNET~
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Qafllgmre.rom. n ~
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Store #06186 .
750 16TH ST. !4ALl FEB 2 g 2002 FEB (] 13 :2232
Store #06186
~~ 750 16TH ST. MALL
Cl(#Q~~.
DENVER, CO 80202 Q
(303) 534-7824 Cr( #:::.:::"-t1l(. DENVER, CO B0202
Register #4 Transaction #572662
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(303) 534-7824
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Cashier #61869151 2/20/02 lO:lBAM ~ ~ Reg1 star fl.? Tr'ansact 1on #139826 <l t;;)
Cash1er #61862307 2/21/02 2:17PM h t,
~d,~~~~~~,~ .AR OUTDOOla~:~~~1~'J~,~~t ~ ~ ~ alI~.:nI!l1lP.J 22.63 T~ ~
i'oON:rSAtE)~~Ri9 . g,) , ~. ....
1!!EVfAtfllA1'ER- rIfER 1.09 T '1 ~ 1 Items Subtotal 22.63 '- ~
Tax 1.62 '0 (',)
11r'~~11'lC;t"l"'"'
3 IteMs SubtolaJ 9.37. ~~.l':U~;>~!
fax .67 *PAIO BV VISA'" .~~.~
: Total 10.04 VISA card • #XXXXXXXXXXXX8902
*PAID BV VIS~* 10.04 Exp 9/30/03 App # ~IAN to /
VISA card * #XKXXXXXXXXXXB902 Ref /I 053110 /
Exp 9/30/03 App # AUTO Card Present
Ref /I 490800 TendE'red 24.25
Card Present Cash Change .00
Tendered 10.04
Cash Change .00
Internet Refills at RiteAld.com
powered by drugstore. com .
1-800-RITEAIO for customer servIce
Internet Refills at RiteAid.com
powered by ,jrugstore.com
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INVOICE
30
3131 South Vaughn Way, Suite 224 DATE INVOICE #-
Aurora, Colorado 80014 ATTOPINEY
REGULATION 12/29/2004 11384
(720) 449-0329 FEIN 84-1566167
BILL TO: RE:

, CHARLES MORTIMER, ESQ. People v. T. Andrew Ragusin
, Assistant Regulation Counsel Supreme Court, State of Colorado
600 Seventeenth Street Original Proceeding in Unauthorized
, Suite 200 South Practice 0 ' efore the Attorney Regul
Denver, Colorado 80202 i
ICase T • 03UPL065
DUE DATE SHIP VIA

1-------+------+---+-""""---""-------
j 1/29/2005
QUANTITY ITEM DESCRIPTION RATE AMOUNT

----""",,l-AF"''''-_-'''N'-r'''o''''-- --+-""-----0-£-'T"-.-Ar'-ND-",-R"E"-W'-RA----a"U--S-IN-" "7't'-----1O-o.~" -------1"-0"0-.-0-0'
Appearance Fee
Transcript Not Ordered
0.5 NO-Hours Transcript Not Ordered 40.00 20,00
Hours
December 15, 2004
; I
I
Interest will be charged at the rate of 1.5% per month on any

, amount not within 30 Total $120.00
I_ eJ,- "~'O
rei
(~UI
TRANSPERFEC1
Bill To: Requested By:
Colorado Supreme Court ML Kevin Hanks

Attn: ML Kevin Hanks Colorado Supreme Court
1560 Broadway 1560 Broadway
Suite 1800 Suite 1800
Denver. CO 80202 Denver. CO 80202
USA USA
Invoice #: 249837 Sales Contact: Kristen Wiley

(KWiley@transperfecLcom)
Invoice Date: 01/08/2010 )
Invoice Due: 02/07/2010 Payment Terms: Net 30
Contract #: tpt211022 Purchase Order #:
Project Notes:
Italian into English documents
Description Quantity Unit Unit Cost (US$) E~nded Cost (US$)

! t~.J
Italian to English
Certification 1.00 Each 25 000
() 25.00
Formatting 100 Each 200 000 200.00
Translation and Proofreading 6.529.00 Words 0.210 1,371.09
Total to Bill this Contract:
Tax Amount: US$ 0.00

f
Total Amount Due: US$ 1,596.09
PAYMENT INSTRUCTIONS
~--~----~----~-------------
Please remit payment to: Wire Transfer Detaiis:
TransPerfect Translations International Inc. Citibank. N.A.
Attn.: Accounts Receivable AlC #: 06541211
Three Park Avenue, 39th Floor ABA Routing #: 021000089
New York. NY 10016 SWIFT CODE: CITIUS33
Tax ID #: 13-3686771
Please reference the Contract # tpt211022 and Invoice # 249837 with your remittance.
Interest will be charged at the rate of 1.5% per month (or the maximum allowed by law) for accounts more than 30 days past due
TRANSPERFECT TRANSLATIONS INTERNATIONAL. INC
TRANSPERFECT GLOBAL HQ· 3 PARK AVENUE. 39TH FLOOR. NEW YORK, NY 10015
T +1212589.5555 F +12125891059' E-MAIL [email protected]
WV'IW TRANSPERFECT COM 1
1/1
ClCberkmate. ]fur.
EIN #84-0763803 DATE INVOICE #
438 Bannock Street
Denver, CO 80204
/20/ 0H),,/
(303) 778-7630 Fax (303) 778-1310
[email protected]
143816 ,/
BILL TO:
SUBPOENA
ATTORNEY REGULATION 19/10 7: 0pr·1
15 BROADWAY, #1800 AFFIANT: 3HARP
DENVER CO 30 02
Nt::t i5 - Due 2 41 10
COLORADO V T. A. RAGUSIN
SUPREME COLORADO - 09UPL127, 09UPL140, 9UPL142
T. ANDREW RAGUSIN
9 5 6 4 KALAlJ!ERE CT
DOUGLAS COUN1'¥ f CO
S.srv ce Fee 45.00
I
, .
r. RhDREi R~GUSl~
9~64 K~LARER£ CT
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.l C K
& STENSTROM, LLC
cCJtlijied ·jliOJdlialtd !tepOJlteJtj
INVOICE
1- 2010 DA TE INVOICE #
3131 South Vaughn Way, Suite 224
Aurora, Colorado 80014
ATICnNEY 3/9/20101 15453,.,
(720) 449-0329 FEIN 84-1566167
BILL TO: RE:

KIM IKELER, ESQ. People v. T. Andrew Ragllsin
Office of Attorney Regulation Counsel Supreme Court, State of Colorado
1560 Broadway Investigative Proceeding in Unauthorized
Suite 1800 Practice of Law ----.~~
Denver, Colorado 80202 Case No. 09UPL127
DUE DATE REPORTER SHIP DATE SHIP VIA
4/912010 ES 2/25/2010 UPS

72 Depo ARC Deposition of LELAND MATTHEW 3.75 270.00
JOHNSON, ESQ.
Original Transcript Preparation
February 12,2010
189 Exhibits Exhibit Copying 0.30 56.70

2 Index Tabs Index Tabs 0.15 0.30
1 AF - Half Day Appearance Fee - Half Day 75.00 75.00
1 0+ 1 DelivelY Delivery (Original and copy) 20.00 20.00
,\ ~

amount not paid within 30 days. Total $422.00
_ 1. C K
& STENSTROM, LLC
ccyti{ied ,\fl~~tfzand 'tepOJdClt;l
INVOICE
MAR Ii 20
3131 South Vaughn Way, Suite 224
DA TE IINVOICE #
3/9120lP I
Aurora, Colorado 80014
l545A
(720) 449-0329 FEIN 84-1566167
BILL TO: RE:

KIM E. IKELER, ESQ. People v. T. Andrew Ragusin
Office of Attomey Regulation Counsel Supreme COUli, State of Colorado
1560 Broadway Investigative Proceeding in Unauthorized
Suite 1800 Practice of Law
Denver, Colorado 80202 Case No. 09UPLI40
DUE DATE REPORTER SHIP DATE SHIP VIA
4/9/2010 2/26/2010 UPS

49 DepoARC Deposition of LEE ANN REYNOLDS 3.75 183.75
Original Transcript Preparation
February 16,2010
1 AF - Half Day Appearance Fee - Half Day 75.00 75.00

1 0+ 1 Delivery Delivery (Original and copy) 20.00 20.00
,
I
/
II \
,
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1/11{5 ~ :;.r
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amount not paid within 30 days. Total $278.75
Regulation Counsel
ATTORNEY REGULATION COUNS
11 r Stephen R. Fatzinger
• ..cltion Counsel Lisa E. Frankel
..Ion S. Gleason Margaret B. Funk
Kim E. Ikelar
Chief Deputy Regulation Counsel Elizabeth Espinosa Krupa
Nancy L. Cohen Cynthia D. Mares
April M. McMurrey
Charles E. Mortimer, Jr.
Deputy Regulation Counsel
Matthew A. Samuelson
James C. Coyle Louise Culberson-Smith
Attorneys' Fund for Client Protection James S. Sudler
Unauthorized Practice of Law
March 5,2010
Denver Sheriffs Dept.

10500 East Smith Road
Denver, CO 80239
Re: People v. T. Andrew Ragusin, 2010SA0067 Service of Process
To Whom It May Concern:
Mr. T. Andrew Raglisin is currently a resident at the Denver County Jail

located at 10500 East Smith Road, Denver, CO 80239. His inmate number is
2010018228. Enclosed with this letter are two copies of the Petition for
Contempt Citation and Injunction, the Order of Injunction, Citation to Show
Cause, and a check for $37,.00. Please have Mr. Ragusin service at the Denver
County Jail. ."
Once served would you please send the Affidavit of Service to:
Kim E. Ikeler, Esq.

Office of Attorney Regulation Counsel
Denver, CO 80202
Please let me know if you have any questions.
Very truly yours,
~
KIM E. IKELER
303-866-6440
KEI/kh
Enclosures
1560 Broadway, Suite! 800 - Denver, Colorado 80202 .. (303) 866-6400 .. Toll free (877) 888-1370 -Website .. www.coJoradosupremecQurt.com

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COloradO Supreme Court

101 West Colfax Avenue, Suite 800

The People of the State of Colorado, Supreme Court Case No:

T. Andrew Ragusin and Ragusin International Association,

Upon consideration of Petitioner's Motion to Proceed, Petitioner's

Withdrawal of Motion to Proceed, and the Stipulation, Agreement and Affidavit

Consenting to a Finding of, and Entry of an Order Regarding Contempt as to Tullio

Andrew Ragusin, and Entry of an Order of Injunction as to Ragusin International

IT IS ORDERED that said Request to Withdraw Motion to Proceed shall be,

and the same hereby is, GRANTED.

IT IS FURTHER ORDERED that said Stipulation, Agreement and Affidavit

is APPROVED. Respondent, T. ANDREW RAGUSIN is found in Contempt of

the March 7, 2005 Order of Injunction.

IT IS FURTHER ORDERED that T. ANDREW RAGUSIN is ordered to

on August 27,2010 by Judge Bronfin in the consolidated criminal cases, plus

the date of this order.

IT IS FURTHER ORDERED that RAGUSIN INTERNATIONAL is

ENJOINED from engaging in the unauthorized practice of law in the State of

IT IS FURTHER ORDERED that RAGUSIN INTERNATIONAL is

BY THE COURT, MARCH 28, 2011.

I ORIGINAL PROCEEDING IN THE

I Tullio Andrew Ragusin

Regulation Counsel; and respondent Tullio Andrew Ragusin

("Ragusin"), enter into the following stipulation, agreement, and

affidavit consenting to a finding of, and order regarding, contempt

("stipulation") and submit the same to the Colorado Supreme Court

for a finding and order of contempt pursuant to C.R.C.P. 238-239.

Assistant Regulation Counsel Ikeler and Ragusin, as principal of

respondent Ragusin International Association, LLC ("Ragusin

International"), enter into a stipulation, agreement and affidavit

consenting to an order of injunction ("stipulation") and submit the

same to the Colorado Supreme Court for a finding and order of

injunction pursuant to C.R.C.P. 229-237.

1. Ragusin's address is CMC - Skyline Correctional Center -

to practice law in the State of Colorado or any other State of the

United States. Ragusin is not licensed to practice law in any other

country in the world. In particular, Ragusin is not licensed to

(Milan district, Veneto region, Toscana region, Puglia region,

Marsala district or Trapani district) or the Seychelles Islands.

2. Ragusin International is a delinquent Colorado limited

liability company. Ragusin International's last known address is

9564 Kalamere Court, Highlands Ranch, CO 80126. Ragusin

operated Ragusin International until his incarceration.

3. Respondents enter into this stipulation freely and

voluntarily. No promises have been made concerning future

consideration, punishment, or lenience in the above-referenced

matter. It is respondents' personal decision, and respondents

affirm there has been no coercion or other intimidating acts by any

person or agency concerning this matter.

4. Respondents are familiar with the rules of the Colorado

Supreme Court regarding the unauthorized practice of law.

Respondents acknowledge the right to a full and complete

evidentiary hearing on the above-referenced petition for contempt

and for entry of an order of injunction. At any such hearing,

respondents would have the right to be represented by counsel,

present evidence, call witnesses, and cross-examine the witnesses

petitioner would have the burden of proof and would be required to

prove the charges contained in the petition for contempt beyond a