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        • Public Comment Archives
          • 2026 Public Comment
            • Proposed New Rule 2.3 of the State Bar Rules Regarding the Civility Oath (Reissued)
            • Proposed Amendments to the Rules of Court and the State Bar Rules Regarding the Procedure Upon Suspension for Nonpayment (Reissued)
            • Proposed Formal Opinion Interim No. 21-0003 (Ethics of In-House Counsel)
            • Proposed New and Revised Rules Related to Grants Administration
            • Proposed Amendments Rules Related to Lawyer Referral Services
            • Proposed Amendments to the Rules of Court and the State Bar Rules Regarding the Procedure Upon Suspension for Nonpayment
          • 2025 Public Comment
            • Proposed Amendments to Client Trust Account Protection Program Rules
            • Proposed Amendments to Rule 2.45 Regarding Voluntary Resignation
            • Proposed Amendments to Rules of Professional Conduct 8.2 and 8.4
            • Proposed Formal Opinion Interim No. 19-0004 (Client File Release and Retention Duties)
            • Proposed New and Revised Rules Related to Grants Administration
            • California Supreme Court Proposes Amendments to Rules Governing the Bar Exam and Other Admissions Matters
            • Proposed Amendments to Rules of Procedure Related to Probation
            • Proposed Amended Rule of Professional Conduct 7.3
            • Proposed Program to Allow Waivers of Filing Fees and Waivers of Transcript Costs in State Bar Court
            • Proposed Amendments to State Bar Rules on Governance, Fees, and Procedures
            • Proposed Changes to the Rules of Procedure Regarding the Alternative Discipline Program
            • Proposed Scope of Client Trust Account Protection Program Compliance Review Procedures
            • Proposed Rule Revisions Regarding the Practical Training of Law Students
            • Proposed Standards for Certification and Recertification in Privacy Law
            • Proposed Amended Rules of Professional Conduct 8.2 and 8.4 (Reissued)
            • Proposed New Rule 2.3 of the State Bar Rules Regarding the Civility Oath
            • Proposed Formal Opinion Interim No. 20-0001 (Lawyer as Expert Witness)
            • Proposed Revisions to Rules Pertaining to the Law Office Study Program
            • Proposed Amended Rules of Professional Conduct 8.2 and 8.4
            • Proposed Amendment to Rules of Court Governing Stipulations and New Rule of Court Related to Professional Responsibility Examination
            • Proposed New State Bar Policy Regarding the Removal of Criminal Conviction Transmittal Notation from the Attorney Profile Page
            • Proposed Revised Formal Opinion Interim No. 20-0003 (Flat Fees and Termination)
          • 2012 Public Comment
            • Proposed Formal Opinion Interim No. 11-0002 (Deceitful Conduct)
            • Proposed Formal Opinion Interim No. 09-0001B (Duty of Confidentiality and Seeking Legal Advice)
          • 2013 Public Comment
          • 2010 Public Comment
            • Proposed Formal Opinion Interim No. 08-0002 (Confidentiality and Technology) Reissued
          • 2011 Public Comment
          • 2014 Public Comment
            • Proposed Formal Opinion Interim No. 12-0007 (Puffing in Negotiations)
            • Proposed Formal Opinion Interim No. 11-0003 (Dissolving Firm and Moving to New Firm)
            • Proposed Revisions to the Rules of Procedure of the State Bar of California Title 5, Discipline
          • 2015 Public Comment
            • Proposed Formal Opinion Interim No. 12-0006 (Attorney Blogging)
          • 2016 Public Comment
          • 2019 Public Comment
            • Proposed Changes to the Responsibilities of the California Board of Legal Specialization (CBLS)
            • Proposed Formal Opinion Interim No. 12-0003 (Attorney Directory and Rating Websites)
            • Options for Regulatory Reforms to Promote Access to Justice
            • Proposed New and Amended Rules of Procedure of the State Bar Regarding Vexatious Complainants
            • Proposed Revised Formal Opinion Interim No. 14-0004 (Witness Perjury)
            • Amendment to Rule of Procedure 2201 (Appointment and Authority)
            • Proposal to Eliminate the Committee on Mandatory Fee Arbitration
            • Proposed Rule Changes Addressing Public Licensee Information and Required Reporting
            • Proposed Amended California Rules of Professional Conduct Regarding File Release and Retention Duties
            • Proposed Changes to State Bar Rules to Revise the Role of the Committee of Bar Examiners for the Purpose of improving Governance and Service Delivery
            • Proposed State Bar Rule of Procedure Setting Forth Guidelines for the Imposition and Collection of Monetary Sanctions
            • Proposed Formal Opinion Interim No. 13-0003 (Ethical Obligations When Departing Firm)
            • Proposed Changes to State Bar of California Model Rules of Procedure Rule 38.1 and State Bar Rule 3.536(E), Regarding Arbitrator Compensation
            • Proposed Formal Opinion Interim No. 12-0003 (Attorney Directory and Rating Websites)
          • 2024 Public Comment
            • State Bar Policy on Law School Name Changes
            • Proposed Amendments to State Bar Rules Governing Commission on Judicial Nominees Evaluation (JNE)
            • Proposed Amended Conflict of Interest Code for Designated State Bar Employees
            • Proposed State Bar Rules and Rule Amendments Related to Grants Administration
            • Proposed Amendments to State Bar Rules Regarding Pro Bono Practice Program
            • Proposed Amendments to the Rules of Procedure Relating to Early Neutral Evaluation Conferences
            • Proposed Amendment to State Bar Rule Regarding Schedule of Fees and Deadlines (Rule 1.22)
            • Clarifying and Corrective Amendments to Multiple State Bar Rules
            • Proposed Amendments to Rule of Procedure Governing Probation
            • Proposed Arbitration Advisory Interim No. 2022-0XA (Standard of Review in Fee Disputes Where There Is a Written Fee Agreement)
            • Proposed Amendments to Attorney Sanction Standards: Effect of Prior Discipline
            • Proposed Amendments to State Bar Rules Relating to Pro Bono Practice Program
            • Proposed Formal Opinion Interim No. 20-0003 (Flat Fees and Termination)
            • Proposed Revised Formal Opinion No. 2021-206 (Colleague Impairment)
            • Proposed Arbitration Advisory Interim No. 2022-0XB (Determination of a “Reasonable” Fee)
            • Proposed Formal Opinion Interim No. 20-0005 (Conversion Clauses in Contingent Fee Agreements)
            • Proposed Amendments to Rules of Procedure of the State Bar Regarding Remote Appearances in State Bar Court Proceedings
            • Proposed New Rule of Procedure Regarding Vexatious Litigants in State Bar Court
            • Proposed Amendments to Rules Relating to Attorney Reporting and the Timing of the Annual Renewal Cycle
            • Proposed New Rule 9.33 of the Rules of Court Regarding the Expungement of Nondisbarment Discipline
            • Proposed Amendments to Rules of the State Bar Regarding the Lawyer Assistance Program
            • Proposed Amendments to California Rules of Court, Rule 9.23
            • Proposed Formal Opinion Interim No. 20-0002 (Succession Planning)
            • Proposed Formal Opinion Interim No. 21-0003 (Ethics of In-House Counsel)
            • Proposed Amendments to Rules of Procedure 5.28 (Computing Time) and 5.127 (Public and Private Reprovals)
            • Proposed State Bar Rule to Implement Offer and Compromise Program
            • Proposed New State Bar Policy Regarding the Removal of Nondisbarment Discipline, Administrative Suspensions, and Inactive Enrollments
            • Proposed Amendments to Rule 2.31 Relating to the Deadline for Submission of the Transfer to Inactive Status Form and the Effective Date of the Transfer
          • 2022 Public Comment
            • Proposed Formal Opinion Interim No. 20-0005 (Conversion Clauses in Contingency Fee Agreements)
            • Proposed Formal Opinion Interim No. 19-0004 (Client File Release and Retention Duties)
            • Elimination of Time Limit on the Validity of a Passing Bar Examination Score
            • Proposed New Case Processing Standards
            • Proposed Amendments to Rule 3.513 (Electronic Submissions in Mandatory Fee Arbitration)
            • Proposed Amendment to Rule 2.11 (Due date and form of payment, licensee fees)
            • Proposed Amendments to State Bar Rule 7.40 (Assignment of Judicial Nominees Evaluation Commissioners)
            • Proposed New Rule of Court and Amended Rules of Professional Conduct for the Client Trust Account Protection Program (CTAPP)
            • California Paraprofessional Program Recommendations
            • Proposed Formal Opinion Interim No. 20-0004 (Ethical Obligations When Working Remotely)
            • Ad Hoc Commission on the Discipline System Recommendations
              • Ad Hoc Commission on the Discipline System Roster
            • Proposed Amendments to the Rules of Procedure of the State Bar, Provisional Licensure Program
            • Proposed Amendments to the Rules of Procedure of the State Bar, Remote Court Proceedings
            • Proposed Amendment to Rule of Procedure 5.80 (Motion for Entry of Default)
            • Proposed Amendments to the Rules of Procedure of the State Bar, Rule 5.127 (Public and Private Reprovals) and Rule 5.155 (Actions by Review Department)
            • Proposed Amendments to Rules of Procedure 5.65 (Discovery Procedures), 5.337 (Expedited Proceeding; Limited Discovery), and 5.345 (Hearing Department Procedures)
            • Proposed Amendments to Rule of Procedure 5.21 (Limitations Period)
            • Proposed New State Bar Rule, Amended Rule of Professional Conduct, and Amended New Rule of Court for the Client Trust Account Protection Program (CTAPP)
          • 2017 Public Comment
            • Proposed Formal Opinion Interim No. 12-0003 (Attorney Directory and Rating Websites) (September 2017)
            • 2017 Standard Setting Study and Related Options
          • 2021 Public Comment
            • Proposed Formal Opinion Interim No. 17-0003 (Considers Duty to Prospective Client)
            • Proposed Revised Rules for Accredited Law Schools
            • Proposed Arbitration Advisory Interim No. 2020-0XB (Handling Disputes Regarding Costs and Expenses)
            • Proposed Rule 3.453 Governing Client Security Fund Payment Plans for Nondisbarred and Nonresigned Licensees
            • Proposed Revisions to State Bar Rule 3.662 Regarding Legal Services Trust Fund Commission Term of Appointments
            • Proposed Formal Opinion Interim No. 19-0003 (Improper Contract Provisions)
            • Proposed Formal Opinion Interim No. 13-0002 (Client with Diminished Capacity)
            • Amendment to Rule of Procedure 2201 (Appointment and Authority)
            • Proposed Amendments to State Bar Rules 3.440, 3.445 (Client Security Fund- Electronic Service and Electronic Signatures)
            • Proposed Formal Opinion Interim No. 19-0003
            • Proposed Amendment to Rule of Procedure 2201 (Appointment and Authority)
            • Proposed Amendments to State Bar Rule 7.61 Regarding Voting Procedures of the Commission on Judicial Nominees Evaluation
            • Proposed Formal Opinion Interim No. 20-0004 (Ethical Obligations When Working Remotely)
            • Proposed Formal Opinion Interim No. 19-0004 (Client File Release and Retention Duties)
            • Proposed Amendments to 4.160(D)(6), Minimum, Cumulative Five-Year Bar Passage Rate (MPR)
            • Proposed Amendments to Rule 9.23 of the California Rules of Court
            • Proposed Technical Amendment to Rule 2.53 Governing Minimum Continuing Legal Education (MCLE) Requirements for New Licensees
            • Proposed Formal Opinion Interim No. 17-0003 [Duty to Prospective Client]
            • Proposed Formal Opinion Interim No. 14-0001 (Colleague Impairment)
            • Proposed Revised State Bar Rule 4.90 Regarding Testing Accommodations
          • 2023 Public Comment
            • Proposed Amendments to the Rules of the State Bar Pertaining to Testing Accommodations
            • Proposed Amendments to Title 4 of the Rules of the State Bar Pertaining to Moral Character
            • Proposed Rule Revisions Regarding the Practical Training of Law Students (PTLS) Program
            • Proposed New Rule of Professional Conduct 8.3 (Reporting Professional Misconduct)
            • Proposed Amendments to State Bar Rules Related to Grants Administration
            • Proposed Amendment Requiring Attorneys to Complete Annual Civility Pledge
            • Proposed Amendments to the Rules of Professional Conduct Addressing Incivility
            • Proposed Amendments to Rules Governing Minimum Continuing Legal Education (MCLE)
            • Report from the Blue Ribbon Commission on the Future of the California Bar Exam
            • Proposed New Rule of Professional Conduct 8.3
            • Admissions Fee Increase Proposal
            • Proposed Amendments to Rules Governing Minimum Continuing Legal Education (MCLE)
            • Revised Proposed Amendments to the Rules of Professional Conduct Addressing Incivility
            • Revised Proposed Amendment Requiring Attorneys to Complete Annual Civility Pledge and New State Bar Rule for Implementation
            • Revised Proposed Amendments to the Rules of the State Bar Pertaining to Testing Accommodations
            • Proposed Changes to the Administration of the California Bar Exam
            • Revised Proposed Amendments to State Bar Rules Related to Grants Administration
            • Proposal for a Portfolio Bar Examination
            • Proposed New Rule of Court 9.8.1
            • Fees Charged to California Accredited Law Schools: Modified Proposal
            • Update to Rules of Court Re: Fees for Pro Hac Vice and Out-of-State Attorney Arbitration Counsel
            • Proposed Formal Opinion Interim No. 20-0001 (Lawyer as Expert Witness)
            • Proposed Amendments to California Rules of Court 9.11 and 9.90
            • Proposed Amended Conflict of Interest Code for the Board of Trustees
            • Revised Amendments to Testing Accommodations Rules
            • Proposed Amendments to Rules Governing Mandatory Fee Arbitration (MFA)
            • Proposed Amendments to the California Rules of Court and Title 2 of the State Bar Rules Regarding the Rights and Responsibilities of Licensees
            • Proposed Amendments to the Rules of the State Bar Regarding Moral Character for Out-of-State Attorney Applicants and Examinations (Rules 4.41 and 4.62)
            • Proposed Amendments to State Bar Rules 7.52 (Commission on Judicial Nominees Evaluation In-Person Candidate Interviews) and 7.60 (Meeting Requirements)
            • Proposed Revisions to Rules Pertaining to the Law Office Study Program
          • 2020 Public Comment
            • Proposed Formal Opinion Interim No. 14-0002 (Alternative Litigation Funding)
            • Proposed Formal Opinion Interim No. 16-0002 (Data Breaches)
            • Proposed Formal Opinion Interim No. 17-0001 (Advising a Cannabis Business)
            • Provisional Licensure with a Pathway to Full Licensure
            • Amendment to Rules of Procedure Governing Fee Arbitration Award Enforcement Proceedings
            • Proposed Formal Opinion Interim No. 14-0001 (Colleague Impairment)
            • Amendment to Lawyer Referral Service Proposed Rules of Procedure
            • Proposed Arbitration Advisory Interim No. 2020-0XA (Awards of Interest under the Mandatory Fee Arbitration Program)
            • New Provisional Licensure Rule, Rule of Court XX
            • Proposed New and Amended State Bar Rules of Procedure, Rule 5.137
            • Proposed Amendments to Rules and Proposed New Rules Regarding Electronic Service and Electronic Signatures
            • Proposed Amended California Rule of Professional Conduct 5.4 [Financial and Similar Arrangements with Nonlawyers]
            • Proposed Amendments to Rule of Procedure Regarding Electronic Trial Exhibits
            • Proposed Amendment to Client Security Fund Rules
            • Proposed Changes to Elimination of Bias MCLE Rules
            • Proposed Formal Opinion Interim No. 14-0002 (Alternative Litigation Funding)
            • Proposed Rules of Procedure Governing the Review Process for Certification, Revocation, and Suspension Decisions Regarding Lawyer Referral Services
            • Proposed Amended California Rule of Professional Conduct 1.1 (Competence)
            • Proposed Formal Opinion Interim No. 16-0002 (Data Breaches)
            • Proposed Changes to State Bar Rules Regarding Electronic Service of Process and Videoconference Appearances
          • 2018 Public Comment
            • Proposed Formal Opinion Interim No. 14-0003 (Settling Before Withdrawal)
        • Proposed Formal Opinion Interim No. 20-0003 (Flat Fees and Termination)
        • Proposed Amendments to California Rule of Court, Rules 9.6 and 9.31 and State Bar Rules 2.32 and 2.50
        • Proposed amendments to Rule 1.7 (Conflicts of Interests: Current Clients) of the Rules of Professional Conduct of the State Bar of California
        • Proposed amendments to the State Bar rules regarding law corporations
        • Proposed Amendments to Guideline 6.9 of the Guidelines for Accredited Law School Rules
        • Proposed Adjustments to Law School Fees
        • Proposed Amendments to the Rules of Professional Conduct
        • Proposed Amendments to the Rules of Professional Conduct (August 2017)
        • Proposed Amendments to Law School Regulation Rules
        • 2017 Content Validation Study on the California Bar Examination
        • Proposed Amendments to Admissions Rules re Qualification of Out-of-State Attorney Applicants to File Moral Character Determination Applications
        • Proposed Amendments to the Law School Regulation Statutes and Rules re Mandatory Accreditation of Law Schools
        • Proposed Amendments to Standards 2.2, 2.5, 2.6, 2.13, 2.15, and 2.21 of the Standards for Attorney Sanctions for Professional Misconduct
        • Proposed changes to MCLE Rule 2.54
        • Proposed Formal Opinion Interim No. 10-0001 (Social Networking)
        • Proposed modification to the Rule 31 of the State Bar Rules of Procedure for Fee Arbitrations re: subpoenas
        • Proposed Modification to Rule 30.0 (“Subpoenas”), State Bar of California Model Rules of Procedure for Fee Arbitrations
        • Proposed Formal Opinion Interim No. 09-0001B (Duty of Confidentiality and Seeking Legal Advice)
        • Conflict of Interest Code for Designated Employees
        • Proposed Formal Opinion Interim No. 09-0001A (State Bar Complaint Threats)
        • Proposed Further Amendments to Rule 5.30, subdivisions (A) and (C), Rules of Procedure of the State Bar-Release for Additional Public Comment
        • Proposals For Sequence Of Elections Under Revised State Bar Districts Effective January 1, 2012
        • Proposed Formal Opinion Interim No. 09­0001A (State Bar Complaint Threats)
        • Proposed changes to MCLE Rule 2.54
        • Proposed amendments to Rules 5.30 and 2409, Rules of Procedure of the State Bar
        • Proposed Formal Opinion Interim No. 08 0003 (Serving Subpoenas on Existing Clients of a Law Firm) – 90-day Public Comment Circulation
        • Proposed Revisions to State Bar Rules Title 6, Division 2, Chapters 1 and 2 regarding State Bar Open Meeting Rules
        • Proposed Online Posting of Consumer Alert re Attorneys Charged with Significant Loan Modification Misconduct and Petition filed under Business & Professions Code section 6007(c) involving Loan Modific
        • Provision of Core Curriculum of 25 hours of Free Online MCLE in Legal Ethics
        • Proposed Formal Opinion Interim No. 10 0002 (Communications with Opposing Counsel’s Implied Consent Under the “No Contact” Rule) – 90-day Public Comment Circulation
        • Proposed Online Posting of Major Misappropriation Consumer Alert and Petition
        • Proposed Formal Opinion Interim No. 06-004 (Confidential Information and Unsolicited E-Mail Correspondence) -- Additional 60-day public comment circulation
        • Proposed administrative amendments to the Admissions Rules
        • Proposed Expungement of MCLE Inactive Enrollment - Rule of Court 9.6
        • Amendments to Rule 2.16 of the State Bar Rules, regarding Fee Waivers
        • Proposed Amendments to Rule 9.21 of the California Rules of Court, Resignation of State Bar Members with Disciplinary Charges Pending
        • Proposed Formal Opinion Interim No. 08 0001 (Gifts from Clients) – Additional 45-day Public Comment Circulation
        • Proposed New Rule 6.62 re Location of State Bar Board-Appointed Committee Meetings, Release for Public Comment
        • Proposed Formal Opinion Interim No. 08-0002
        • Conflict of Interest Code for Designated Employees (2010) - 30-Day Public Comment
        • State Bar Rule 6.9 - California Young Lawyer Governor, Proposed Amendment
        • Proposed amendments to Division 8, Library Requirements contained in the Guidelines for Accredited Law School Rules
        • Proposed amendments to Division 8, Library Requirements
        • Proposed Amendments to Standards for Certification in Immigration and Nationality Law.
        • Proposed revision of Rule 9.30, Rules of Court re Unaccredited Law Schools
        • Proposed revisions to the Lawyer Referral Service Rules
        • Proposed amendments to the State Bar Rules by the JNE Process Review Committee
        • Proposed revisions to State Bar Sample Fee Agreement forms
        • Seven proposed new or amended Rules of Professional Conduct of the State Bar of California developed by the State Bar’s Special Commission for the Revision of the Rules of Professional Conduct.
        • Proposed Law Corporation Rules
        • Proposed Formal Opinion Interim No. 06‑0004 (Confidential Information and Unsolicited E-Mail Correspondence)
        • Proposed Formal Opinion Interim No. 08-0001 (Gifts from Clients)
        • Proposed Amendments to the Standards for Attorney Sanctions for Professional Misconduct
        • Proposed Amendments to Conflict of Interests for the Board of Governors of the State Bar of California
        • Proposed Amendments to Standards for Certification in Admiralty and Maritime Law re Alternative to the Examination
        • Proposed modifications to Rules of Procedure of The State Bar of California
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MICHAEL SULLIVAN & ASSOCIATES

Speciality CertificationWorkers' Compensation Law
Contact Address7120 Whitney Avenue, Suite 105
Fresno, CA 93720
ContactLisa Bettendorf
Phone(559)785-6000
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E-maillbettendorf@sullivanattorneys.com
Web site www.sullivanattorneys.com
Provider Number15527

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