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People v. Efe.

No. 18PDJ041 (consolidated with 19PDJ002). Suspension.

April 2020

A hearing board suspended Anselm Andrew Efe (attorney registration number 38357) from the practice of law for one year and one day, effective August 3, 2020. To be reinstated, Efe will bear the burden of proving by clear and convincing evidence that he has been rehabilitated, has complied with disciplinary orders and rules, and is fit to practice law.

Efe committed misconduct in two separate client matters. In one matter, he placed a client’s retainer directly into his operating account without earning the funds, neglected to notify the client of the basis of his fee in writing, and knowingly failed to return unearned funds to the client for six months. Through this conduct, Efe violated Colo. RPC 1.5(b) (a lawyer who has not regularly represented a client must communicate to the client in writing the basis or rate of the lawyer’s fees within a reasonable time after beginning the representation); Colo. RPC 1.15A(a) (a lawyer must hold the property of a client separate from the lawyer’s own property); and Colo. RPC 1.16(d) (on termination of the representation, a lawyer shall take steps to the extent reasonably practicable to protect the client’s interests, including refunding any advance payment of fees that have not been earned).

In the second matter, Efe filed frivolous and groundless motions and caused unnecessary delays that slowed the progress of the case. As a result, Efe personally was sanctioned $33,000 to cover the opposing party’s attorney fees. Efe failed to satisfy that award for 17 months, refusing to pay until he was held in contempt, arrested, and jailed. Through this conduct, Efe violated Colo. RPC 3.1 (a lawyer is prohibited from bringing or defending a proceeding, or asserting or controverting an issue in that proceeding, unless there is a basis in law and fact for doing so that is not frivolous); Colo. RPC 3.4(c) (a lawyer shall not knowingly disobey an obligation under the rules of a tribunal); and Colo. RPC 8.4(d) (it is professional misconduct for a lawyer to engage in conduct prejudicial to the administration of justice).

The case file is public per CRCP 251.31.

Official Office of the Presiding Disciplinary Judge proceedings can be found at the Office of the Presiding Disciplinary Judge website.

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