Ethics Watch 4th Quarter 2022

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4th Quarter 2022 Ethics Decisions

Brady/Giglio/Rosario & Other Discovery Issues

1st Dept

People v Knowles (Tyrone), 2022 NY Slip Op 07169 (12/15/22) – People’s belated disclosure (after jury deliberations had begun) of a statement written by the arresting officer in support of his request for departmental recognition did not warrant reversal.

“The written statement noted that the incident began when police officers saw defendant standing outside an illegally parked car, but omitted certain observations, to which the arresting officer testified at trial…. The trial court conducted a reopened suppression hearing after trial, at which the officer explained that he omitted that information because he did not consider it relevant to the request for recognition based on his seizure of a pistol from defendant. Although defendant’s suppression claims are not at issue on appeal, the testimony at the posttrial hearing tends to illuminate the harmlessness of the nondisclosure. Moreover, had counsel been able to make timely use of the recognition request in an effort to show that the drug-related observations were fabrications, counsel could have risked opening the door to suppressed evidence of drugs recovered from defendant.” In short, “defendant was not ‘substantially prejudiced’ by the nondisclosure, and ‘there is no reasonable possibility that the People’s failure to disclose the witness statement at issue undermined the fairness of defendant’s trial or impacted the verdict’ [citations omitted].”

3rd Dept

People v Christiano, Jr. (Richard), 2022 NY Slip Op 05893 (10/20/22) – On defendant’s appeal from grand larceny convictions, 3rd Department rejected his claim of a Brady violation, as had the trial court. One week prior to trial, the prosecutor submitted a letter to the trial court with a copy to defense counsel in which the ADA advised that the Attorney General was in the process of investigating the Galway Police Department (where the officer in question was employed) and other police departments; the officer in question had been interviewed as part of that investigation. During the trial, but before the officer in question testified, the ADA advised the court and the defendant that the officer had become an accredited field training officer; the certificate for that accreditation indicated he had completed a stated number of hours of training, but due to the small number of enrollees in the training class, the officer actually completed fewer hours of training than what was reflected in the certificate. The officer had assured the prosecutor that he had not modified or forged the certificate.  Sometime after the trial was completed, the officer was charged with offering a false instrument for filing based on the discrepancy in the training hours actually completed and the hours listed on the accreditation certificate.

“[B]ecause the Attorney General’s investigation did not have anything to do with the officer’s credibility,” the trial court “correctly concluded that this evidence was not Brady material requiring disclosure.” In the alternative, “such evidence was neither within the control of the People…, nor did a reasonable probability exist that its timely disclosure would have led to a more favorable outcome [citations omitted].”

People v Stokes (James), 2022 NY Slip Op 07101 (12/15/22) – Court upheld trial court’s summary denial of defendant’s CPL 440.10 motion, in which he claimed both newly discovered evidence of prosecutorial misconduct and a Brady violation. Defendant alleged that the prosecution failed to disclose a “plea deal” with a specific trial witness, and that instead of turning over the witness’s actual NYSID report, the People gave the defense a typewritten list that did not include the witness’ conviction for Endangering the Welfare of a Child.  In addition, defendant alleged that both the witness and her boyfriend (who had allegedly sold the weapon which was the subject of this prosecution to the defendant) received a favorable plea bargain in exchange for their cooperation in this prosecution.

First, defendant acknowledged that the People did not call the witness’ boyfriend to testify at trial, and defendant’s claim that the witness in question received favorable treatment in exchange for her testimony was refuted by the record, which revealed that the witness was sentenced on the misdemeanor Endangering charge six months before she testified for the prosecution at defendant’s trial.  In addition, defendant’s attorney cross-examined the witness concerning whether she had received a benefit in exchange for her testimony and she had answered “that she ‘wasn’t getting [anything] out of it.’” Given that testimony and the lack of any evidence to support defendant’s claim of a plea agreement, defendant was not entitled to vacatur of his weapons convictions on this ground.
Second, the Appellate Division rejected defendant’s claim of a Brady violation.  While the witness’ Endangering conviction was impeaching in nature, defendant’s trial counsel had cross-examined the witness about her lengthy criminal history and the fact that she was serving a second felony offender prison sentence at the time of the trial. The 3rd Department concluded that timely disclosure of the witness’ misdemeanor endangering conviction would not have affected the outcome of the trial.

Grand Jury

2nd Dept

People v Nicholson (Calvin), 2022 NY Slip Op 06719 (11/23/22) – Evidence of uncharged crimes adduced by the prosecutor in the grand jury “completed the narrative and was probative of the witness’s ability to identify the defendant from video surveillance. In light of the other testimony before the grand jury and the prosecutor’s limiting instruction, the probative value outweighed the danger of any potential prejudice [see generally People v Morris, 21 NY3d 588, 594 (2013)].” Consequently, the integrity of the grand jury was not so impaired as to require dismissal of the indictment pursuant to trial denying CPL 210.35 (5).

People v Jones (Justice), 2022 NY Slip Op 06942 (12/7/22) – “The prosecution was under no obligation to elicit certain additional testimony [from the complainant] or present the other evidence [defendant claimed was helpful to the defense], as such evidence was not entirely exculpatory and would not have materially influenced the grand jury’s investigation [citations omitted].”

3rd Dept

People v Calafell (Tarell), 2022 NY Slip Op 06838 (12/1/22) – Prosecutor was not obligated to instruct the grand jury on either temporary and lawful possession of a weapon or the justification defense. “Given that the grand jury viewed the video footage and heard the eyewitness accounts of defendant getting up off the ground, moving toward and shooting at the retreating subject, there was no rational view of the evidence at the hearing before the grand jury that would support the viability of such defenses” [internal punctuation and case citation omitted].

People v. Galusha (Charles), 2022 NY Slip Op 07481 (12/29/22) – The Appellate Division rejected defendant’s contention that the integrity of the grand jury proceeding was impaired when a state police investigator testified that defendant’s DNA was matched to a cigarette product found at the burglary scene by using a data base containing DNA information from convicted offenders.   The investigator explained that he relied on the DNA match to run the defendant’s criminal history. He learned that the defendant was on probation, contacted defendant’s probation officer and then interviewed defendant at the probation office.  The grand jury never learned any information about the details of defendant’s prior bad acts from the state police investigator or the exhibits.  The information provided by the investigator merely explained how the investigator located defendant and was necessary background for the investigator’s narrative.  Also the prosecutor gave proper instructions to mitigate prejudice.  As a result, defendant failed to establish that the brief reference to his prior convictions established wrongdoing or errors by the prosecutor which would require dismissal of the indictment.

Voir Dire & Juror Issues 

4th Dept

People v Fulton (Frank), 2022 NY Slip Op 06376 (11/10/22) – During deliberations, a juror sent a note to the court that defendant on appeal argued should have prompted the trial court to replace her. That claim, however was not preserved because defendant did not request that the trial court discharge the juror (See People v Fernandez, 269 AD2d 167, 167 [1st Dept 2000], lv denied 95 NY2d 796 [2000]).

The Fourth Department further held that while the juror initially expressed concern over her well being, she “ultimately assured the court in unequivocal terms that she would be fair and impartial and would follow the court’s instructions [citations omitted].” Thus the trial court was not required to discharge her as “grossly unqualified” to serve pursuant to CPL 270.35(1).

Opening

1st Dept

People v Santana (Frankie), 2022 NY Slip Op 05928 (10/20/22) – Court declined to reverse conspiracy and drug sale convictions on ground that it was improper for prosecutor to incorporate a PowerPoint presentation into the opening statement:

“The content of the PowerPoint was within the bounds of what is proper for an opening statement, giving an overview of the evidence to be presented without including any commentary or otherwise prejudicial material (see People v Kurtz, 51 NY2d 380, 384 [1980], cert denied 451 US 911 [1981]). A PowerPoint presentation may be used as a visual aid in connection with closing arguments, provided that what is displayed would likewise be proper to present in the form of an oral statement [citations omitted]. The fact that the PowerPoint was used in connection with the People’s opening statement, when facts were not yet in evidence, rather than their summation, when all the evidence would have already been admitted, does not warrant a different result, especially where the court advised the jurors that anything the prosecutor said during opening statements was ‘not evidence.’ The principle that permits visual aids during closing arguments is applicable to opening statements, where the People state what they intend to prove.”

Direct

1st Dept

People v Jones (Frederick), 2022 NY Slip Op 05960 (10/25/22) – On direct examination, prosecutor elicited testimony from detective that defendant’s arrest was “the end result” of information provided by defendant’s girlfriend. Relying on People v Stone, 29 NY3d 166 (2017), the 1st Department held that by striking that testimony, and giving a curative instruction to the jury that defense counsel helped fashion, the trial court eliminated any possible prejudice in this case, where the evidence of the defendant’s guilt was overwhelming.

People v Dean (Clarence) 2022 NY Slip Op 06643 (11/22/22) – Not improper for People’s case to include expert testimony that one of the victim’s wounds was a human bite. “While there are serious questions about the validity of bite mark matching, no such evidence was offered or admitted at defendant’s trial. Defendant has not shown that expert testimony simply identifying a wound as a bite mark is so unreliable that it must be excluded. * * * In any event, any error in admitting the limited bite mark evidence at trial was harmless….”

People v Fuller (Shaquille), 2022 NY Slip Op 06765 (11/29/22) – Admission of photograph of defendant holding a pistol was not reversible error. The probative value of the photo exceeded the potential for prejudice, for defendant “was wearing a very distinctive jacket [in the photo], similar to a jacket worn by a man shown in a surveillance videotape relating to the homicide. Furthermore, the photo also depicted defendant’s companion, who had completed an application to purchase a pistol on a trip with defendant to Pennsylvania, and thus provided evidence tending to connect defendant to the purchase application.” Additionally, the trial court gave an appropriate, limiting instruction.

People v Outlaw (Lewis), 2022 NY Slip Op 07035 (1st Dept 12/14/22) – Detective should not have testifed “that he was told by the employer of a home health care aide, who was in the apartment where the drug transaction and ensuing arrest took place, that the aide had made complaints about drug activity in the apartment. This was not relevant as background to explain why the officers did not arrest the aide, who was undisputedly in the apartment to care for an infirm resident, and defendant did not open the door to this otherwise inadmissible hearsay testimoy [citation omitted].” But 1st Dept declined to reverse drug sale and possession convictions. “The offending testimony did not inculpate defendant or contradict his defense, but merely tended to show that drug activity was being conducted in the apartment by someone,” and there was “overwhelming evidence of defendant’s guilt, including his possession of prerecorded buy money.”

2nd Dept

People v Porter (Adrian), 2022 NY Slip Op 06720 (11/23/22) – People properly permitted to introduce recording of phone call defendant made from Rikers Island. Former CPL 240.20(1)(g), in effect at the time of this 2018 trial, required the People, upon demand, to disclose to the defendant “[a]ny tapes or other electronic recordings which the prosecutor intends to introduce at trial, irrespective of whether such recording was made during the course of the criminal transaction.” But the record here demonstrated that the prosecution did not intend to use the recording — “until after defense counsel made his opening statement, during which he argued, among other things, that the police ‘just assume[d] and speculate[d] that [the defendant] is Sonny’.” Thus, the People did not fail to fulfill their statutory disclosure obligations. “Moreover, the recording was properly provided to the defendant after defense counsel made his opening statement, and there was no showing of bad faith on the part of the People which would warrant the extreme sanction of preclusion [see People v Jenkins, 284 AD2d 550, 551 (2d Dept 2001), affd 98 NY2d 280 (2002)]. Further, the probative value of the recording outweighed any prejudice to the defendant [citation omitted].”

People v White (Neil), 2022 NY Slip Op 06726 (11/23/22)

  • Not improper for People to recall expert witness “to address an issue raised during cross-examination of a police officer, particularly since the People had not rested at the time the expert was recalled [citations omitted].”
  • Nor was a 20-second “love you” video from the mother to the (murdered) child victim an impermissible appeal to the jury’s sympathy. The video “tended to establish the time line of events on the day that the victim was killed and was material to establishing the defendant’s consciousness of guilt [see People v Pobliner, 32 NY2d 356 (1973); People v Sims, 110 AD2d 214 (2d Dept 1985).”

People v O’Sullivan (Elizabeth), 2022 NY Slip Op 06944 (12/7/22) – Trial prosecutor should not have elicited testimony from expert on human trafficking that the complainant exhibited signs of being a human trafficking victim. See People v Graham, 251 AD2d 426 (2d Dept 1998). But App. Div. court deemed the non-constitutional error harmless in light of the overwhelming evidence of guilt and because there was no significant probability that the defendant would have been acquitted but for this piece of improper testimony.

People v Bryant (Isaac), 2022 NY Slip Op 07075 (12/14/22) – Third requirement of CPL 60.25(1)(a) was not met in this case: the witness declared that he did not see the previously identified person in the courtroom — not that he could not identify the defendant on the basis of present recollection. Consequently, the trial court should not have permitted a police officer to testify for the People as to the witness’s lineup identification of defendant. But reversal not required because error was harmless.

3rd Dept

People v Lorenz (Travis), 2022 NY Slip Op 06837 (12/1/22) – Surveillance video footage properly received into evidence on People’s direct case at arson trial. Testimony from a property manager, an investigator from the DA’s Office, and a fire investigator, property manager, an investigator from the Schenectady County District Attorney’s Office, and a fire investigator provided the requisite foundation. Each of these witnesses testified as to their familiarity with the respective video surveillance system and video files. Additionally, they “further testified that the footage could not be altered, established the chain of custody for each video file, and affirmed that … the video files accurately represent[ed] the events depicted thereon.”

People v Reed (Kenneth), 2022 NY Slip Op 06657 (11/23/22) –  Court reversed defendant’s convictions for child sex offenses in the interest of justice. The victim was 2½ at the time the crime was committed and 3 at the time of the trial.  The trial court allowed the child to give unsworn testimony without conducting an inquiry of the child to determine whether the child possessed the intelligence and capacity to give unsworn testimony, and there was nothing in the record to indicate that the trial court made a specific determination that the child was competent. The prosecutor’s initial questioning of the child witness to elicit pedigree information was insufficient to satisfy that the witness knew the difference between the truth and a lie and was competent to testify.

4th Dept

People v Parilla (Miguel), 2022 NY Slip Op 07379 (12/23/22) – On appeal, defendant contended that the People’s introduction of testimony concerning his post-arrest bribe offers without an advance ruling was improper, and that the admission of this evidence deprived him of a fair trial. Court rejected defendant’s Molineux claim as the testimony was admissible as consciousness of guilt evidence, and its probative value outweighed any potential for prejudice. Even assuming that the People should have obtained a ruling in advance, the error was harmless because of the overwhelming evidence of guilt.

People v Ismael (Syaf), 2022 NY Slip Op 06614 (11/18/22) – At trial on aggravated harassment and criminal contempt charges, a witness was permitted to testify that the victim-wife — who did not take the stand — stated shortly after receiving text messages that “they’re from” the defendant. The trial court admitted the statement over defense objection, under the excited utterance rule. The 4th Dept held this was not an excited utterance as it was not a statement “‘made contemporaneously or immediately after a startling event and which asserts the circumstances of that occasion as observed by the declarant’ (People v Cummings, 31 NY3d 204, 209 [2018]) [emphasis added by 4th Dept).” Here, the text messages did not come from a number belonging to defendant, and defendant did not identify himself by name as the sender. “Thus, the wife’s identification of defendant as the sender was ‘not a report of [her] contemporaneous observation, but rather [her] surmise’ (Brown v Keane, 355 F3d 82, 89 [2d Cir 2004] [emphasis in original]).” However, the 4th Department found the error harmless and affirmed the conviction.

People v Clinkscales (Jullian), 2022 NY Slip Op 06375 (11/10/22) – Defendant was convicted after a jury trial of the attempted murder of his mother. The 4th Department found that the trial court properly allowed the victim to testify about defendant’s prior violent conduct towards her as this was proper Molineux testimony that provided necessary background information, completed the narrative of the events charged, and also established defendant’s motive to attack his mother.

Cross-examination

1st Dept

People v Henderson (Paul), 2022 NY Slip Op 07009 (12/8/22) – Third degree robbery conviction — which rested on Starbucks employee’s testimony that defendant threatened him after stealing a mug — reversed in the interest of justice. The pre-trial Sandoval ruling limited the People’s cross-examamination to merely eliciting that defendant had been convicted of three unspecified felonies. But after defendant said “I guess so”, when the prosecutor asked if he had been convicted of three felonies, and then said he wasn’t sure how many felony convictions he had, the prosecutor was permitted to inquire about the underlying facts of all three convictions, which included drug and theft-related crimes.

“Defendant’s trial testimony,” the First Department ruled, “did not open the door to a prejudicial modification of the court’s Sandoval ruling. * * * Unlike cases in which Sandoval modifications were found to be appropriate, [this] defendant did not attempt to assert his innocence in past cases, deny the existence of any of his convictions, or mischaracterize the crimes he had committed.” The error could not be deemed harmless because “[a]side from the testimony provided by the employee and defendant, there was no other evidence proving or disproving that a threat was made during the incident. Thus, defendant’s credibility was a central issue at trial.”

2nd Dept

People v Salcedo (Santiago), 2022 NY Slip Op 05548 (10/05/2022) – Prosecutor should not have asked defendant on cross-examination if the testimony of a prosecution witness was “a lie.” But this line of improper cross-examination was deemed harmless in light of overwhelming evidence of defendant’s guilt.

Summation

➢ Criticisms of a defense attorney’s ethics in closing argument are rarely seen in appellate decisions. But in rejecting a defendant’s argument that the prosecutor’s objections to counsel’s summation were themselves objectionable, the Second Department held that the trial court properly sustained the objections “on the ground that defense counsel was misstating the law by suggesting that motive was an element of the crime of murder in the second degree [see People v Mitchell, 117 AD3d 971 (2d Dept 2014)], and on the additional ground that defense counsel was encouraging the jury to make unreasonable inferences unsupported by the record [see generally People v Ashwal, 39 NY2d 105, 110 (1976)].” People v Fernandez (Andres), 2022 NY Slip Op 06137 (2d Dept 11/2/22).

2d Dept

People v Adorno (Angelo), 2022 NY Slip Op 05856 (10/19/2022) – Defendant on trial for charges that included allegation he had punctured skin of store security guard with a hypodermic needle. A prospective juror reported during voir dire that an “ex” was a police officer who had contracted HIV/AIDS after being stabbed by a “crackhead.” In response to one aspect of defense counsel’s closing argument, the prosecutor in summation argued that a hypodermic instrument can be a dangerous instrument and remarked, “We were all here in jury selection when the individual talked about what happened to his partner which is the needle stick. It is capable of causing serious physical injury, death, serious bodily harm, depending on how it’s used.” A 3-2 majority of the Second Department was not persuaded that defendant’s claim of prosecutorial misconduct in summation was preserved or meritorious. That comment, in their view, “merely reflected a matter of well-understood common knowledge and human experience,” and “to the extent it was improper, was not egregious or unduly prejudicial so as to deprive the defendant of a fair trial.”

3rd Dept

People v Lorenz (Travis), 2022 NY Slip Op 06837 (12/1/22) – Not improper for prosecutor during summation to show a collage of still frame photographs: “each still frame was extracted from a properly admitted video, and the prior witness testimony ‘was adequate to establish the authenticity and integrity of the video excerpt and still frame’ (People v Williams, 184 AD3d 1010, 1012 [3d Dept 2020], lv denied 35 NY3d 1097 [2020]).”

Miscellaneous

Motion to strike People’s brief

People v Blackburn (Jessica), 2022 NY Slip Op 06517 (3rd Dept 11/17/22) – At the conclusion of its decision affirming the defendant’s conviction, the App. Div. court noted it was denying the defendant’s motion to strike the People’s brief, or portions thereof, on the ground that it referred to matter outside the record.  “To the extent that the People’s brief contains references to [dehors the record facts], this Court has ignored such references and has based its conclusions solely upon the materials appearing in the record on appeal.”

People’s statement of readiness & witness preparation

People v Hill (Patrick), 2022 NY Slip Op 05626 (4th Dept 10/7/22) – Successful People’s appeal from trial court’s dismissal of the indictment charging child sex offenses. After People declared their readiness, the case was repeatedly adjourned, along with others that were resolved by guilty pleas in the week preceding the August 4, 2021 pretrial calendar call. On that day, the prosecutor stated the People had not contacted the witnesses for this case “because they expected the three preceding matters to be tried, and they did not wish to put the child victims through the emotional trauma of preparing for trial. The trial prosecutor further indicated that they had not subpoenaed or interviewed those witnesses on any of the earlier dates when the matter was scheduled for trial. Finally, the trial prosecutor stated that ‘we feel it is unfair for [the teenage victims] to be thrown into a jury trial with four days notice.'” The trial court granted defendant’s CPL 30.30 motion on the ground that the People’s statements of readiness were illusory.

The 4th Department first rejected the People’s argument that the “exceptional circumstances” exception [see CPL 30.30 (4) (g)] applied here, for “the determination not to prepare the victims to testify at trial was solely within the control of the District Attorney’s Office.” But it reversed the trial court and reinstated the indictment. None of the adjournments before August 4 was due to the People’s failure to have witnesses ready for trial. The People are not required to contact their witnesses on every adjourned date, “‘nor do they have to be able to produce their witnesses instantaneously in order for a statement of readiness to be valid’ (People v Camillo, 279 AD2d 326, 326 [1st Dept 2001]; see People v Robinson, 171 AD2d 475, 476-478 [1st Dept 1991], lv denied 78 NY2d 973 [1991]).” Although time after August 4, 2021, would be properly chargeable to the People, the prior statements of readiness were not illusory.

In conclusion, the 4th Department admonished the prosecutor “that she must obey an order of the court to have a case ready for trial. Regardless of the prosecutor’s feelings concerning the order scheduling the trial for August 9, 2021, or its possible impact on the witnesses, it was a valid order of the court, and with certain exceptions that are not relevant here, ‘a court order must be obeyed’ (People v Williamson, 136 AD2d 497, 497 [1st Dept 1988]; see generally Matter of Balter v Regan, 63 NY2d 630, 631 [1984], cert denied 469 US 934 [1984]).”

Disciplinary & Other Proceedings/Sanctions

  • Town Court Justice formally admonished by NYS Commission on Judicial Conduct for identifying himself as “JUDGE” in the character references he provided for his neighbors’ submission in support of their pistol license applications. After one of the neighbors, whom he’d identified as his court clerk, was turned down for a full carry license, the judge submitted a letter for reconsideration on his judicial letterhead, and signed it as Hon. John M. Aronian. Matter of Aronian (State Comm’n on Jud Conduct) (11/7/22).
  • On November 18, the Fourth Department suspended nearly 40 attorneys who had not complied with Judiciary Law § 468-a’s attorney registration requirements & who had not responded to multiple notifications and an Order to Show Cause. Matter of Attorneys In Violation of Judiciary Law § 468-a, 2022 NY Slip Op 06621 (4th Dept 11/18/22).
  • The First Department has now suspended more than 2500 attorneys from the practice of law, effective November 17, who continued to not comply with the attorney registration requirements of Judiciary Law § 468-a even after various notifications given over the years since their initial failure to re-register. Matter of Attorneys Who Are In Violation of Judiciary Law Section 468-a For Failing to Register, NY Slip Op 06558 (1st Dept 11/17/22).
  • List of the suspended attorneys [1].
  • On November 15, the First Department formally disbarred the 2 attorneys who were arrested in 2020 for throwing a Molotov cocktail into an empty NYPD van during protests following the killing of George Floyd. The attorneys had pleaded guilty in U.S. District Court, EDNY, to conspiracy to commit arson and the making-possession of an unregistered destructive device — convictions that are “essentially similar” to convictions for felony offenses defined by New York’s Penal Law so as to trigger, they acknowledged in their federal plea colloquies, the automatic disbarment provision of Judiciary Law § 90 ( 4). Matter of Mattis (Colinford), 2022 NY Slip Op 06438 (1st Dept 11/15/22), and Matter of Rahman (Urooj), 2022 NY Slip Op 06439 (1st Dept 11/15/22).

News From Around the US

  • Georgia’s Supreme Court deemed e-mail correspondence between Ass’t AG and public defender attorneys to constitute a contract whereby State agreed to waive sovreign immunity. Consequently, Court refused to vacate interlocutory injunction prohibiting the resumption of the execution of death sentences in Georgia. State of Georgia v Federal Defender Program, Inc., citation not yet available (Ga 12/20/22).
  • A former Assistant District Attorney — who pleaded guilty in federal court earlier this year to document tampering — has been suspended from the practice of law in Maine. While an ADA, she deleted text messages she had exchanged with a neighbor who wanted to know whether he was under investigation; at one point, it was alleged, she did tip him off. She was not charged, however, with any of the substantive crimes arising out of the neighbor’s marihuana enterprise, which he had told her was a lawful CBD venture. Board of Overseers of the Bar v Alves, no citation available (Me. 11/21/22).

New CLE requirement for all attorneys starting 2023

To read the new CLE cybersecurity requirements and an article on this, see: