Without Honors
The New Jersey Disciplinary Review Board imposed a reprimand by consent in a letter of admonition
Specifically, in 1975, you graduated from Seton Hall University (SHU), earning a Bachelor of Arts degree. However, you did not graduate “cum laude.” Four years later, in 1979, you graduated from Seton Hall University School of Law (SHU Law), earning a juris doctor, without achieving cum laude status. Thereafter, between 1985 and 1988, you completed coursework at New York University School of Law (NYU), attempting to earn an LLM degree. However, you did not complete your coursework and, thus, never earned an LLM degree.
In August 1999, you joined your former law firm (Firm 1) as a partner. Sometime between 2010 and 2014, Firm 1 created a website, which falsely represented that you had obtained an LLM degree from NYU and had graduated, cum laude, from SHU. Although you did not personally prepare your biography for the website, you conceded that you “could, and should have, corrected” your inflated academic credentials.
In September 2015, Firm 1 dissolved, and you joined a new law firm (Firm 2) as a partner. In connection with that transition, Firm 2 published, on its website, your same false academic credentials which had been listed on Firm 1’s website.
On June 21, 2016, two months before Firm 2 merged with another law firm (Firm 3), you submitted an employment application with Firm 3 in which you accurately stated your academic credentials, including the fact that you had been an “LLM degree candidate” at NYU. In August 2016, in connection with the merger of Firm 2 with Firm 3, you ensured that Firm 3 did not carry over any false credentials onto its website.
Meanwhile, throughout your career at the bar, until 2019, you conducted presentations at approximately twenty Continuing Legal Education (CLE) seminars hosted by the National Business Institute (NBI). In 2014 or 2015, you directed NBI to remove the false references to your LLM degree and cum laude status from its CLE marketing materials. However, you conceded that NBI was “not consistent in removing” your false credentials from the marketing materials and that you did not “follow up” to confirm that such false information was removed. The record before the Board included CLE marketing brochures for six NBI seminars, occurring between 2014 and 2019, in which you were a presenter. Of those six seminars, only one marketing brochure – for a December 2016 estate administration seminar – falsely referenced your purported LLM degree from NYU and cum laude status from both SHU and SHU Law.
Sanction
In imposing only an admonition, the Board considered, in mitigation, that (1) your actions did not appear to have resulted from any direct attempt at personal gain; (2) the passage of almost nine years since your false academic credentials last appeared in CLE marketing brochures and on your firms’ websites; (3) the lack of clear and convincing evidence that your conduct resulted in harm to any clients; and (4), most significantly, your lack of prior discipline in your forty-five-year career at the bar.
Your conduct has adversely reflected not only on you as an attorney but also on all members of the bar. Accordingly, the Board has directed the issuance of this admonition to you. R. 1:20-15(f)(4).
(Mike Frisch)