Office of Lawyer Regulation v. Daniel J. Rostollan , 381 Wis. 2d 5 ( 2018 )

2018 WI 38SUPREME COURT OF WISCONSIN
CASE NO.: 2016AP1890-D
COMPLETE TITLE: In the Matter of Disciplinary Proceedings
Against Daniel J. Rostollan, Attorney at Law:
Office of Lawyer Regulation,
Complainant,
v.
Daniel J. Rostollan,
Respondent.
DISCIPLINARY PROCEEDINGS AGAINST ROSTOLLAN
OPINION FILED: April 18, 2018
SUBMITTED ON BRIEFS:
ORAL ARGUMENT:
SOURCE OF APPEAL:
COURT:
COUNTY:
JUDGE:
JUSTICES:
CONCURRED:
DISSENTED:
NOT PARTICIPATING:
ATTORNEYS:
2018 WI 38NOTICE
This opinion is subject to further
editing and modification. The final
version will appear in the bound
volume of the official reports.
No. 2016AP1890-D
STATE OF WISCONSIN : IN SUPREME COURT
In the Matter of Disciplinary Proceedings
Against Daniel J. Rostollan, Attorney at Law:
Office of Lawyer Regulation, FILED
Complainant,
APR 18, 2018
v.
Sheila T. Reiff
Daniel J. Rostollan, Clerk of Supreme Court
Respondent.
ATTORNEY disciplinary proceeding. Attorney's license
suspended.
¶1 PER CURIAM. We review Referee Jonathan V. Goodman's
amended report recommending that this court suspend Attorney
Daniel J. Rostollan's license to practice law in Wisconsin for a
period of two years and direct him to pay restitution as well as
the costs of this proceeding.
¶2 No appeal has been filed so we review the referee's
report pursuant to Supreme Court Rule (SCR) 22.17(2). After
conducting an independent review of the matter, we agree that
No. 2016AP1890-D
Attorney Rostollan should be deemed to have defaulted, we accept
and adopt the referee's findings of fact and conclusions of law,
which are based on the allegations of the complaint filed by the
Office of Lawyer Regulation (OLR). We agree that Attorney
Rostollan's law license should be suspended for two years and
that he should be directed to pay restitution. We impose the
full costs of this proceeding on Attorney Rostollan, which are
$2,663.71 as of January 30, 2018.
¶3 Attorney Rostollan was admitted to practice law in
Wisconsin in 1983. He has not previously been disciplined.
However, while this matter was pending, this court granted the
OLR's request and temporarily suspended Attorney Rostollan's
license to practice law for failure to cooperate in a new and
separate disciplinary investigation. As of the date of this
order, his license is suspended. See Office of Lawyer
Regulation v. Daniel J. Rostollan, No. 2018XX173-D, unpublished
order (S. Ct. April 9, 2018).
¶4 On September 30, 2016, the OLR filed a complaint
against Attorney Rostollan alleging 21 counts of professional
misconduct.
¶5 Attorney Rostollan filed an answer and asserted, inter
alia, that his practice was adversely affected by depression and
family issues. He also stated that he had reimbursed former
client, R.W. Thereafter, however, he failed to respond to
discovery requests and on June 5, 2017, the OLR moved for a
default judgment. On July 11, 2017, the referee advised
2
No. 2016AP1890-D
Attorney Rostollan that he had seven days to respond to the
default motion. Attorney Rostollan did not respond.
¶6 On July 31, 2017, the referee issued an initial report
and recommendation, recommending the court deem Attorney
Rostollan to have defaulted, finding the facts as alleged in the
OLR's complaint as true, and concluding that Attorney Rostollan
had committed the alleged misconduct. The referee recommended
we suspend Attorney Rostollan's license to practice law for two
years and recommended that Attorney Rostollan be ordered to pay
restitution to R.W.
¶7 The court identified some factual and procedural
issues with the report and, on November 13, 2017, remanded the
matter to the referee for additional information, with
directions to file a supplemental report.
¶8 On remand, Attorney Rostollan indicated he wanted to
participate in this proceeding. The referee conducted a hearing
on December 5, 2017, at which Attorney Rostollan appeared. The
referee afforded him an opportunity to respond to discovery, but
Attorney Rostollan then failed to respond.
¶9 Accordingly, the referee filed a supplemental report
on January 10, 2018, including additional information requested
by this court and confirming the previous recommendation.
Neither party has appealed so we consider the amended report
pursuant to SCR 22.17(2).
¶10 We review a referee's findings of fact subject to the
clearly erroneous standard. See In re Disciplinary Proceedings
Against Eisenberg, 2004 WI 14, ¶5, 269 Wis. 2d 43,
3
No. 2016AP1890-D
675 N.W.2d 747. We review the referee's conclusions of law
de novo. Id. We determine the appropriate level of discipline
independent of the referee's recommendation. See In re
Disciplinary Proceedings Against Widule, 2003 WI 34, ¶44, 261
Wis. 2d 45, 660 N.W.2d 686.
¶11 First, in light of Attorney Rostollan's failure to
consistently appear or participate in this case, we accept the
referee's finding that Attorney Rostollan's conduct was
egregious such that his answer should be stricken and he should
be deemed to have defaulted.
¶12 The referee's findings of fact are based on the
allegations in the complaint. They have not been shown to be
clearly erroneous, and we adopt them. We also accept the
conclusions of law that flow from those findings.
¶13 The first nine counts of the complaint pertain to
Attorney Rostollan's representation of R.W. In 2012, R.W.
retained Attorney Rostollan to file a Chapter 13 bankruptcy
petition on his behalf and to represent him in certain adversary
claims.
¶14 There were a number of problems with Attorney
Rostollan's representation of R.W. These included no written
fee agreement or disclosures, mishandling of the bankruptcy
proceeding, mishandling of trust funds, and various
misrepresentations that Attorney Rostollan made to his client,
the court, and the OLR.
¶15 On July 23, 2013, Attorney Rostollan filed the
requested Chapter 13 bankruptcy petition in the Eastern District
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No. 2016AP1890-D
of Wisconsin. The bankruptcy court dismissed this petition, so
Attorney Rostollan filed a second petition, with documents
required for two related adversary proceedings. He then filed
inaccurate bankruptcy schedules, and electronically affixed
R.W.'s signature to these filings, potentially exposing R.W. to
charges of perjury and endangering the bankruptcy matter.
¶16 Attorney Rostollan also informed the bankruptcy court
that he had charged R.W. $4,000 for the bankruptcy action but
later acknowledged that he had charged R.W. an additional $4,690
for related adversary actions without disclosing these
additional fees to the bankruptcy court.
¶17 The bankruptcy court has established a presumptively
reasonable fee of $4,000 for Chapter 13 cases. If attorney fees
will exceed the presumptively reasonable amount, the attorney
must disclose the additional fees to the bankruptcy court.
11 U.S. Code § 329, Rule 2016(b). Additionally, it is the
bankruptcy court's policy that fees in addition to a
presumptively reasonable fee must be approved by the court under
local Rule 20.16.
¶18 Meanwhile, R.W. gave Attorney Rostollan a $36,000
check, representing life insurance proceeds that Attorney
Rostollan was to hold in trust for R.W. On April 9, 2013,
Attorney Rostollan deposited these funds into his trust account,
yielding a balance of $36,020.
¶19 Over several months, Attorney Rostollan transferred
money in and out of various accounts. On April 10, 2013,
Attorney Rostollan disbursed $4,281 from his trust account to
5
No. 2016AP1890-D
his business account, leaving $31,719 in trust. On June 12,
2013, Attorney Rostollan disbursed $5,000 to R.W. Between April
and mid-August 2013, Attorney Rostollan transferred almost all
of the remaining funds from his trust account into his business
account. By May 30, 2014, Attorney Rostollan's trust account
balance was $10.
¶20 In July 2014, Attorney Rostollan sent R.W. an
accounting stating that only $1,500 remained from the insurance
proceeds and that some $36,000 had been expended on debts,
adversary claims, and legal fees. R.W. questioned this
accounting.
¶21 In August 2014, Attorney Rostollan sent R.W. a second
accounting, this time stating that $14,784 remained in trust.
Meanwhile, on August 15, 2014, Attorney Rostollan deposited
$29,407.53 belonging to another client, M.Z., into his trust
account. The next day, Attorney Rostollan wrote a check to R.W.
in the amount of $14,784.24 with a memo line stating "balance
from trust account." At most, $10 of those funds actually
belonged to R.W. Attorney Rostollan failed to disclose his
conversion of R.W.'s funds.
¶22 The OLR received notice of an overdraft in Attorney
Rostollan's trust account and commenced an investigation.
Attorney Rostollan sent the OLR fabricated and misleading trust
account ledgers that omitted deposit information, internet
transfers, and included non-existent disbursements, and
transactions. Attorney Rostollan also made misrepresentations
to the OLR orally and in writing regarding the source and use of
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No. 2016AP1890-D
funds in his trust account. On March 3, 2015, the OLR requested
additional information from Attorney Rostollan. Attorney
Rostollan failed to fully and timely respond. Eventually, this
court issued an order directing Attorney Rostollan to show cause
why his license should not be suspended for non-cooperation.
This prompted Attorney Rostollan to respond, so the OLR withdrew
its motion.
¶23 Based on the allegations in the complaint, the referee
concluded that:
 By failing to communicate in writing to R.W. the
rate and basis for all of the fees he intended to
charge related to the representation, and also by
failing to state in writing the purpose and
effect of any advanced fee payment, Attorney
Rostollan violated SCR 20:1.5(b)(1)1 and (2)2
(Count 1);
1
SCR 20.1.5(b)(1) provides:
The scope of the representation and the basis or
rate of the fee and expenses for which the client will
be responsible shall be communicated to the client in
writing, before or within a reasonable time after
commencing the representation, except when the lawyer
will charge a regularly represented client on the same
basis or rate as in the past. If it is reasonably
foreseeable that the total cost of representation to
the client, including attorney's fees, will be $1000
or less, the communication may be oral or in writing.
Any changes in the basis or rate of the fee or
expenses shall also be communicated in writing to the
client.
2
SCR 20:1.5(b)(2) provides: "If the total cost of
representation to the client, including attorney's fees, is more
than $1000, the purpose and effect of any retainer or advance
fee that is paid to the lawyer shall be communicated in
writing."
7
No. 2016AP1890-D
 By failing to safeguard and hold in trust client
funds, Attorney Rostollan violated
SCR 20:1.l5(b)(1)3 (Count 2);
 By converting client funds to his own use or for
the use of other clients, Attorney Rostollan
violated SCR 20:8.4(c)4 (Count 3);
 By making misrepresentations to R.W. regarding
his handling of R.W.'s funds, Attorney Rostollan
violated SCR 20:8.4(c) (Count 4);
 By failing to disclose to the United States
Bankruptcy Court for the Eastern District of
Wisconsin that he intended to charge and/or that
he charged R.W. fees related to the adversary
proceedings in addition to the $4,000 fee,
Attorney Rostollan failed to comply with 11 U.S.
Code § 329, Rule 2016(b) of the Federal Rules of
Bankruptcy Procedure, and the Eastern District's
local policy, in violation of SCR 20:3.4(c)5
(Count 5);
 By filing with the United States Bankruptcy Court
for the Eastern District of Wisconsin documents
related to R.W.'s bankruptcy that included false
3
SCR 20:1.15(b)(1) provides:
A lawyer shall hold in trust, separate from the
lawyer's own property, that property of clients and
3rd parties that is in the lawyer's possession in
connection with a representation. All funds of
clients and 3rd parties paid to a lawyer or law firm
in connection with a representation shall be deposited
in one or more identifiable trust accounts.
4
SCR 20:8.4(c) provides: "It is professional misconduct
for a lawyer to engage in conduct involving dishonesty, fraud,
deceit or misrepresentation."
5
SCR 20:3.4(c) provides: "A lawyer shall not knowingly
disobey an obligation under the rules of a tribunal, except for
an open refusal based on an assertion that no valid obligation
exists."
8
No. 2016AP1890-D
and/or inaccurate information, Attorney Rostollan
violated SCR 20:8.4(c) (Count 6);
 By acting under a concurrent conflict of interest
by representing R.W. in the bankruptcy
proceedings after R.W. had claims against
Attorney Rostollan for misuse of R.W.'s funds,
Attorney Rostollan violated SCR 20:1.7(a)(2)6
(Count 7);
 By making deposits in and disbursements from his
trust account via internet banking transactions,
6
SCR 20:1.7(a)(2) provides:
Except as provided in par. (b), a lawyer shall
not represent a client if the representation involves
a concurrent conflict of interest. A concurrent
conflict of interest exists if;
. . .
(2) there is a significant risk that the
representation of one or more clients will be
materially limited by a personal interest of the
lawyer.
(b) Notwithstanding the existence of a concurrent
conflict of interest under par. (a), a lawyer may
represent a client if:
(1) the lawyer reasonably believes that the
lawyer will be able to provide competent and diligent
representation to each affected client;
(2) the representation is not prohibited by law;
(3) the representation does not involve the
assertion of a claim by one client against another
client represented by the lawyer in the same
litigation or other proceeding before a tribunal; and
(4) each affected client gives informed consent,
confirmed in a writing signed by the client.
9
No. 2016AP1890-D
Attorney Rostollan violated former
SCR 20:1.l5(e)(4)c7 (Count 8);
 By failing to timely file responses to the OLR's
investigative letters, and by making
misrepresentations to the OLR during its
investigation, Attorney Rostollan violated SCR
22.03(2)8 and (6),9 enforceable via SCR 20:8.4(h)10
(Count 9).
7
Effective July 1, 2016, substantial changes were made to
Supreme Court Rule 20:1.15, the "trust account rule." See
S. Ct. Order 14-07, (issued Apr. 4, 2016, eff. July 1, 2016).
Because the conduct underlying this case arose prior to July 1,
2016, unless otherwise indicated, all references to the supreme
court rules will be to those in effect prior to July 1, 2016.
Former SCR 20:1.15(e)(4)c provided: "A lawyer shall not
make deposits to or disbursements from a trust account by way of
an Internet transaction."
8
SCR 22.03(2) provides:
Upon commencing an investigation, the director
shall notify the respondent of the matter being
investigated unless in the opinion of the director the
investigation of the matter requires otherwise. The
respondent shall fully and fairly disclose all facts
and circumstances pertaining to the alleged misconduct
within 20 days after being served by ordinary mail
request for a written response. The director may
allow additional time to respond. Following receipt
of the response, the director may conduct further
investigation and may compel the respondent to answer
questions, furnish documents, and present any
information deemed relevant to the investigation.
9
SCR 22.03(6) provides:
In the course of the investigation, the
respondent's wilful failure to provide relevant
information, to answer questions fully, or to furnish
documents and the respondent's misrepresentation in a
disclosure are misconduct, regardless of the merits of
the matters asserted in the grievance.
10
No. 2016AP1890-D
¶24 The next nine counts alleged involved Attorney
Rostollan's representation of clients in a Chapter 13 bankruptcy
petition. The clients, who will jointly be called "E.A.",
informed Attorney Rostollan that they wished to file their
petition promptly. There was no written fee or representation
agreement. Attorney Rostollan delayed until the clients
indicated they intended to hire another attorney. At that
point, Attorney Rostollan filed the Chapter 13 petition, but
failed to file a fee disclosure statement or a Chapter 13 plan.
Attorney Rostollan emailed the clients an affidavit for E.A. to
sign and return. The client signed the emailed affidavit
outside of Attorney Rostollan's presence, yet Attorney Rostollan
notarized it.
¶25 The bankruptcy court dismissed the matter because no
Chapter 13 plan had been filed. Attorney Rostollan moved the
court to reconsider dismissal of the bankruptcy, but did so
without informing E.A. of the dismissal or his plans to file a
reconsideration motion. Attorney Rostollan filed his fee
disclosure with the bankruptcy court, indicating that he was to
be paid $2,750 to represent the clients, none of which had been
paid.
10
SCR 20:8.4(h) provides: "It is professional misconduct
for a lawyer to fail to cooperate in the investigation of a
grievance filed with the office of lawyer regulation as required
by SCR 21.15(4), SCR 22.001(9)(b), SCR 22.03(2), SCR 22.03(6),
or SCR 22.04(1)."
11
No. 2016AP1890-D
¶26 On November 12, 2015, Attorney Rostollan sent E.A. a
proposed Chapter 13 plan, disclosed that the court had dismissed
their case, but said he had filed a reconsideration motion. On
November 14, 2015, E.A. terminated Attorney Rostollan's
representation.
¶27 On November 17, 2015, Attorney Rostollan appeared on
E.A.'s behalf at a bankruptcy hearing on his motion for
reconsideration, without telling the court that the clients had
terminated him. Attorney Rostollan told the court that E.A. had
agreed to a Chapter 13 plan, while her spouse had not. In fact,
Attorney Rostollan had not presented a plan to the clients until
after the dismissal. The court denied the reconsideration
motion, citing the clients' alleged inability to agree on a
Chapter 13 plan as not excusable neglect.
¶28 The OLR alleged and the referee concluded:
 By failing to communicate the rate and basis of
his fees, and any changes in the rate and basis
of his fees, in writing to the clients, Attorney
Rostollan violated SCR 20:1.5(b)(1) (Count 10);
 By depositing the $300 the clients paid to him in
his business account, Attorney Rostollan violated
former SCR 20:1.l5(b)(4) (Count 11);11
11
Former SCR 20:1.15(b)(4) provided:
Except as provided in par. (4m) unearned fees and
advanced payments of fees shall be held in trust until
earned by the lawyer, and withdrawn pursuant to sub.
(g). Funds advanced by a client or 3rd party for
payment of costs shall be held in trust until the
costs are incurred.
12
No. 2016AP1890-D
 By failing to take the steps necessary to file
the Chapter 13 plan, or to file a motion for an
extension of time to file the plan, Attorney
Rostollan violated SCR 20:1.312 (Count 12);
 By failing to clearly and accurately communicate
with the clients when their Chapter 13 petition
would be filed, and failing to inform them of the
dismissal of their Chapter 13 bankruptcy or of
his intent to file a motion to reconsider the
dismissal until after the motion was filed,
Attorney Rostollan in each instance violated
SCR 20:1.4(a)(3)13 (Count 13);
 By appearing on behalf of the clients at the
November 17, 2015 hearing without advising the
court that they had terminated or attempted to
terminate his representation, and without
clarifying with the clients whether they wished
for him to appear on their behalf or the steps
they would need to take to protect their own
interests if they did not wish for him to appear,
Attorney Rostollan violated SCR 20:1.16(a)(3) and
(d)14 (Count 14);
12
SCR 20:1.3 provides: "A lawyer shall act with reasonable
diligence and promptness in representing a client."
13
SCR 20:1.4(a)(3) provides: "A lawyer shall keep the
client reasonably informed about the status of the matter."
14
SCR 20:l.16(a)(3) and (d) provides:
Except as stated in par. (c), a lawyer shall not
represent a client or, where representation has
commenced, shall withdraw from the representation of a
client if:
. . .
(3) the lawyer is discharged.
. . .
(d) Upon termination of representation, a lawyer
shall take steps to the extent reasonably practicable
to protect a client's interests, such as giving
(continued)
13
No. 2016AP1890-D
 By making false statements to the bankruptcy
court, and/or by failing to correct false
statements previously made to the bankruptcy
court, Attorney Rostollan violated
SCR 20:3.3(a)(1)15 (Count 15);
 By causing, or failing to correct, the bankruptcy
court's mistaken belief that the clients had been
presented with a Chapter 13 plan for signature
prior to the dismissal of their case and had
failed to agree to that plan, causing or
contributing to the failure of a plan to be
timely filed, Attorney Rostollan violated
SC 20:8.4(c) (Count 16);
 By notarizing the affidavit signed by E.A.,
thereby asserting that it had been "Subscribed
and sworn to before me," even though E.A. did not
sign the affidavit in front of him, Attorney
Rostollan violated SCR 20:8.4(c) (Count 17);
 By making misrepresentations to the OLR during
the course of its investigation of the clients'
matter, Attorney Rostollan violated SCR 22.03(6),
enforceable via SCR 20:8.4(h) (Count 18).
¶29 In May 2015, J.V.E. filed a grievance against Attorney
Rostollan. The OLR requested certain information but Attorney
Rostollan did not timely respond, despite repeated requests.
This court ordered Attorney Rostollan to show cause why his
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 or expense that has not
been earned or incurred. The lawyer may retain papers
relating to the client to the extent permitted by
other law.
15
SCR 20:3.3(a)(l) provides: "A lawyer shall not knowingly
make a false statement of fact or law to a tribunal or fail to
correct a false statement of material fact or law previously
made to the tribunal by the lawyer. "
14
No. 2016AP1890-D
license to practice law should not be suspended. Attorney
Rostollan did not respond and, on December 2, 2015, Attorney
Rostollan's license to practice law was temporarily suspended.
¶30 On December 8, 2015, Attorney Rostollan appeared at
two bankruptcy hearings on behalf of clients, despite the fact
that his license was temporarily suspended.
¶31 On January 19, 2016, Attorney Rostollan provided a
response sufficient to allow the OLR to continue its
investigation, and Attorney Rostollan's license to practice law
was reinstated. On January 25, 2016, Attorney Rostollan
disclosed that he had practiced law during his license
suspension.
¶32 On February 4, 2016, the OLR requested Attorney
Rostollan provide it with additional information but Attorney
Rostollan failed to timely respond. Again, this court ordered
Attorney Rostollan to show cause why his license to practice law
should not be suspended. Attorney Rostollan responded and the
OLR withdrew its motion.
¶33 The OLR alleged and the referee concluded:
 By failing to timely file a response to the OLR's
July 31, 2015 letter in the J.V.E. matter,
Attorney Rostollan violated SCR 22.03(2) and (6),
enforceable via SCR 20:8.4(h) (Count 19);
 By practicing law in Wisconsin at a time when his
license to practice law was suspended, Attorney
Rostollan violated SCR 22.26(2) (Count 20);16
16
SCR 22.26(2) provides:
(continued)
15
No. 2016AP1890-D
 By failing to timely file a response to the OLR's
February 4, 2016 letter, Attorney Rostollan
violated SCR 22.03(2) and (6), via SCR 20:8.4(h)
(Count 21).
¶34 Having accepted the referee's conclusions of law, we
turn to the appropriate discipline for Attorney Rostollan's
misconduct. While no two disciplinary cases are identical, we
agree that In re Disciplinary Proceedings Against Ramthun, 2015
WI 94, 365 Wis. 2d 7, 869 N.W.2d 775, supports the referee's
recommendation for a two-year license suspension. Like Attorney
Rostollan, Attorney Ramthun had no prior formal disciplinary
history, initially participated in the matter but later
defaulted, and cited extenuating medical issues as a reason for
his failure to abide by the rules of professional misconduct.
He was suspended for two and one-half years for 46 counts of
misconduct that included failure to respond to pleadings,
failure to appear at court proceedings, failure to communicate,
trust account anomalies, including conversion of a portion of
the client funds, and failure to cooperate with the OLR,
including making misrepresentations. We agree that a two-year
An attorney whose license to practice law is
suspended or revoked or who is suspended from the
practice of law may not engage in this state in the
practice of law or in any law work activity
customarily done by law students, law clerks, or other
paralegal personnel, except that the attorney may
engage in law related work in this state for a
commercial employer itself not engaged in the practice
of law.
16
No. 2016AP1890-D
license suspension is required to impress on Attorney Rostollan
the seriousness of his extensive misconduct.
¶35 The OLR requested we order Attorney Rostollan to pay
$4,690 in restitution to R.W. In his initial report the referee
agreed and recommended restitution in the amount on $4,690. In
his supplemental report, however, the referee recommended
$1,690. In response to an inquiry from the court, the referee
confirmed this was a typographical error; the referee recommends
restitution in the amount of $4,690. We accept this
recommendation. Further, consistent with our standard practice,
we impose the costs of this proceeding on Attorney Rostollan
which are $2,663.71 as of January 30, 2018.
¶36 IT IS ORDERED that the license of Daniel J. Rostollan
to practice law in Wisconsin is suspended for a period of two
years, effective the date of this order.
¶37 IT IS FURTHER ORDERED that Daniel J. Rostollan shall
comply with the provisions of SCR 22.26 concerning the duties of
a person whose license to practice law in Wisconsin has been
suspended.
¶38 IT IS FURTHER ORDERED that within 60 days of the date
of this order, Daniel J. Rostollan shall pay restitution to his
former client, R.W., in the amount of $4,690.
¶39 IT IS FURTHER ORDERED that within 60 days of the date
of this order, Daniel J. Rostollan shall pay to the Office of
Lawyer Regulation the costs of this proceeding.
17
No. 2016AP1890-D
¶40 IT IS FURTHER ORDERED that the restitution is to be
completed prior to paying costs to the Office of Lawyer
Regulation.
18
No. 2016AP1890-D
1