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Opinion

Opinion By: Gregory D. Stumbo, Attorney General; James M. Ringo, Assistant Attorney

Open Records Decision

This matter having been presented to the Attorney General in an open records appeal, and the Attorney General being sufficiently advised, we find that neither Steven N. Howe, P.S.C., a private attorney, nor the private law firm of Cors & Bassett, LLC, is bound by, and therefore did not violate, the Open Records Act in their actions relative to former client Kenneth LaPradd's open records request for a copy of a video discovery tape from his case file. We believe that 01-ORD-24 and 01-ORD-40, copies of which are attached hereto and incorporated by reference, are controlling. Although private attorneys may be obligated under the Rules of Professional Conduct governing attorneys licensed to practice law in Kentucky to provide Mr. LaPradd's records from his client case file, 1 they are not obligated to do so under the Open Records Act.


A party aggrieved by this decision may appeal it by initiating action in the appropriate circuit court pursuant to KRS 61.880(5) and KRS 61.882. Pursuant to KRS 61.880(3), the Attorney General should be notified of any action in circuit court, but should not be named as a party in that action or in any subsequent proceeding.

Kenneth LaPradd, # 119159 D-8Eastern Kentucky Correctional Complex200 Road to JusticeWest Liberty, KY 41472-0636

Steven N. Howe, P.S.C.94 South Main StreetDry Ridge, KY 41035

Cors & Bassett, LLC1881 Dixie HighwaySuite 350Ft. Wright, KY 41011-2660

Footnotes

Footnotes

1 See SCR 3.130(1.16)(d), which provides: "Upon termination of representation, a lawyer shall take steps to the extent reasonably practicable to protect a client's interests, such as giving reasonable notice to the client, allowing time for employment of other counsel, surrendering papers and property to which the client is entitled and refunding any advance payment of fee that has not been earned."

LLM Summary
The decision concludes that private attorneys and law firms, such as Steven N. Howe, P.S.C., and Cors & Bassett, LLC, are not obligated under the Open Records Act to provide former clients with records from their case files. This determination is based on the precedent set by previous Open Records Decisions (01-ORD-024 and 01-ORD-040). While attorneys may have obligations under the Rules of Professional Conduct to provide such records, these obligations do not extend under the Open Records Act.
Disclaimer:
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Requested By:
Kenneth LaPradd
Agency:
Steven N. Howe; Cors & Bassett
Type:
Open Records Decision
Lexis Citation:
2005 Ky. AG LEXIS 248
Forward Citations:
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