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9th Circuit

ATTORNEYS, BANKRUPTCY - Attorney Hale accepted $250 from pro se debtors in bankruptcy to provide them with "pre-filing" legal representationbut didnotappear at thecreditors meeting. The 9th Circuit found that the bankruptcy court had the authority to request an itemized bill from Hale for his services and, when Halefailed to complybut sought to recuse the judge instead, the court had the authority to sanction him by barring him from charging pro se bankrupcy clients. See ruling.

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