Advisory Opinions

This page lists Office of Legal Affairs (OLA) Advisory Opinions (formerly “External Opinions”) from 2010 to the present. It also provides most Advisory Opinions issued after 2000 and some from before then. Please note that these opinions may be modified or superseded by later opinions or changes to the law or regulations. For questions about OLA opinions please contact Mark Freedman, Senior Associate General Counsel (mfreedman@lsc.gov).

2021 Advisory Opinions

Opinion Number	Date	Advisory Opinion Title

2020 Advisory Opinions

Opinion Number	Date	Advisory Opinion Title
AO-2020-005	Nov. 6, 2020	Non-Federal Status of LSC and LSC Grants and Contracts
AO-2020-004	June 24, 2020	Application of 45 C.F.R Part 1638 Restriction on Solicitation to Outreach Conducted by LSC Grantees
AO-2020-003	June 11, 2020	Part 1611 Income and Extra $600 Pandemic Payments
AO-2020-002	Feb. 18, 2020	Ongoing Monitoring of Part 1604 Outside Practice of Law
AO-2020-001	Feb 11, 2020	Part 1611 Asset Screening for Household Goods and Personal Effects

2019 Advisory Opinions

Opinion Number	Date	Advisory Opinion Title
AO-2019-004	Dec. 13, 2019	Use of LSC Funds as Non-Federal Matching Funds
AO-2019-003	Oct. 30, 2019	Application of 45 CFR Part 1610 to Child in Need of Care Proceedings with a Right to an Attorney
AO-2019-002	Aug. 29, 2019	Application of 45 CFR Part 1629 to LSC Funding Recipient Unable to Obtain Fidelity Bond or Similar Coverage
AO-2019-001	April 22, 2019	Recipients’ Participation in Research Studies

2018 Advisory Opinions

Opinion Number	Date	Advisory Opinion Title
AO-2018-002	Nov. 14, 2018	Restrictive Clauses in Medical-Legal Partnership Contracts Between Recipients and Health Care Partners
AO-2018-001	Sept. 26, 2018	Part 1607 Requirements for Appointing Bar Associations

2017 Advisory Opinions

Opinion Number	Date	Advisory Opinion Title
AO-2017-009	Dec. 27, 2017	Fees and Fee Sharing in Part 1609-Permissible Fee-Generating Cases
AO-2017-008	Dec. 1, 2017	Legal Information and Assistance Involving Voting Rights
AO-2017-007	Sept. 8, 2017	Part 1626 and Services by a U.S. Grantee to Micronesians living in Micronesia
AO-2017-006	Aug. 31, 2017	Qualification of a Bar Association to Appoint Attorney Members of a Recipient’s Governing Body as Required by 45 C.F.R. § 1607.3(b)(1)
AO-2017-005	June 30, 2017	Definition of “full-time attorney” in 45 C.F.R. Part 1604
AO-2017-004	June 28, 2017	Online “Free Legal Answers” Systems and LSC Screening
AO-2017-003	May 22, 2017	Application of 45 C.F.R. Part 1610 to Civil Commitment Proceedings with a Right to an Attorney
AO-2017-002	May 17, 2017	Use of LSC Funds to Offer Incentives to Recruit Client Volunteers for Intake System User Testing
AO-2017-001	May 1, 2017	Application of 45 C.F.R. Part 1607 and 45 C.F.R. Part 1619 to Board Meeting Minutes, Board Meeting Agendas, and Public Notice Requirements

2016 Advisory Opinions

Opinion Number	Date	Advisory Opinion Title
AO-2016-007	Dec. 12, 2016	LSC Restrictions on non-LSC Funded Self Help Centers
AO-2016-006	Nov. 18, 2016	Application of 45 C.F.R. Part 1613 and LSC’s 1996 Appropriations Legislation § 504(a)(15) to Reduction of Conviction and Resentencing Cases Under Utah and California Law
AO-2016-005	Sept. 9, 2016	Application of 45 C.F.R. § 1610.6 to Proceedings Involving Compelled Medication, Involuntary Commitment, or Voluntary Commitment
AO-2016-004	Aug. 19, 2016	Financial Eligibility and Income Attributable to Foster Children in Group Homes and Nursing Homes (45 C.F.R. Part 1611)
AO-2016-003	Aug. 17, 2016	Part 1626 Eligibility Screening for Group Clients
AO-2016-002	July 11, 2016	Permissibility of Providing Legal Services to Noncitizen Parents and Noncitizen Guardians of Children Seeking Special Immigrant Juvenile Status
AO-2016-001	Feb. 11, 2016	Applicability of the Restriction on Solicitation (45 C.F.R. Part 1638) to Mailings Sent by LSC Recipients

2015 Advisory Opinions

Opinion Number	Date	Advisory Opinion Title
AO-2015-003	Nov. 10, 2015	Multi-Entity Housing Initiative Coordinator Employed at an LSC Grantee
AO-2015-002	June 17, 2015	Applicability of Restrictions on Fee-Generating Cases to Advice and Counsel or Brief Services
AO-2015-001	June 15, 2015	Permissibility of Recipient Subscription to Agency Mailing Lists Under 45 CFR 1612.6(e)

2014 Advisory Opinions

Opinion Number	Date	Advisory Opinion Title
AO-2014-008	Dec. 5, 2014	Applicability of Section 504(a)(11) and Part 1626 Alienage Restrictions in American Samoa
AO-2014-007	Nov. 11, 2014	Financial Eligibility Requirements for Eligible Client Members of a Recipient Governing Body Established by LSC Act & Regulations
AO-2014-006	Sept. 9, 2014	Discretion to Grant Part 1628 Waivers for Fund Balances Exceeding 25% of LSC Support
AO-2014-005	June 9, 2014	Part 1612 Lobbying Activities
AO-2014-004	April 17, 2014	Method to Determine Compliance With Governing Body Composition Requirements Under 45 C.F.R. 1607
AO-2014-003	April 4, 2014	Part 1610 Program Integrity Involving an Attorney Incubator Project
AO-2014-002	March 7, 2014	Allocations to PAI Requirement of Costs Associated With Services Provided During Common Interest Litigation
AO-2014-001	Jan. 8, 2014	Collection of Attorneys’ Fees in Social Security Disability Cases

2013 Advisory Opinions

Opinion Number	Date	Advisory Opinion Title
AO-2013-011	Dec. 11, 2013	Attestation of Citzenship by PAI Attorneys
AO-2013-010	Dec. 10, 2013	Management Information Exchange Journal Article-LSC Restrictions on Lobbying, Legislative, and Administrative Activities
AO-2013-009	Nov. 26, 2013	Applicability of LSC's Rules of Eligibility to Court Appointments
AO-2013-008	Nov. 5, 2013	Recipient Use of Tribal Funds to Represent Clients Without Verifying Citizenship or Eligible Alien Status
AO-2013-007	Oct. 1, 2013	MLSC’s Eligibility for Governing Body Waivers
AO-2013-006	Aug. 12, 2013	Use of Paralegal Support for Outside Practice of Law
AO-2013-005	July 30, 2013	Citizenship Attestation by Minors
AO-2013-004	June 24, 2013	Representation of briefly incarcerated client under 45 C.F.R.1637
AO-2013-003	June 13, 2013	Derivative U Visas for Family Members of U Visa Applicants Represented by LSC Recipients
AO-2013-002	Feb. 21, 2013	Use of Older American Act Funds for Representation of Ineligible Aliens
AO-2013-001	Jan. 1, 2013	Prior Approval for Purchases of Personal Property and Services Under Part 1630 and the PAMM

2012 Advisory Opinions

Opinion Number	Date	Advisory Opinion Title
AO-2012-002	Aug. 22, 2012	Part 1626 Eligibility of Aliens and the DHS Deferred Action Policy for DREAM Act Eligible Aliens
AO-2012-001	Aug. 21, 2012	Part 1604 Outside Practice of Law and Court-Appointed Artibrators in Pennsylvania

2011 Advisory Opinions

Opinion Number	Date	Advisory Opinion Title
AO-2011-001	May 2, 2011	PAI Allocability of Costs Related to Intake and Referral of Applicants to Certain Pro Bono Volunteer Lawyer Programs

2010 Advisory Opinions

Opinion Number	Date	Advisory Opinion Title
AO-2010-004	Sept. 13, 2010	Inclusion of Costs in PAI Subgrant Threshold under 45 CFR Part 1627
AO-2010-003	Sept 13, 2010	Candidacy in Local Election Without Party Affiliation Not Sufficient to Render Candidacy Permissible under 45 CFR Part 1608
AO-2010-002	April 14, 2010	Legal Assistance to Ineligible Aliens with U.S. Citizen Children (Part 1626)
AO-2010-001	March 5, 2010	Permissibility of Using LSC Funds to File an Amicus Curiae Brief

Archive of Advisory Opinions Issued Before 2010

Opinion Number	Date	Advisory Opinion Title
AO-2009-1008	Dec. 4, 2009	1626 Eligibility Screening and Statutory Exceptions
AO-2009-1007	Nov. 29, 2009	"Incubator Program" Attorneys Status as Staff Attorneys
AO-2009-1006	Sept. 3, 2009	Inquiry into Income Prospects Pursuant to 45 CFR 1611.7(a)
AO-2009-1005	June 23, 2009	1612 Public Demonstrations and Working Hours
AO-2009-1004	June 19, 2009	Subgrants to Staff-Model Legal Services Provider; Qualification as PAI under 45 CFR Part 1614
AO-2009-1003	June 18, 2009	Group Eligibility Under 45 CFR Part 1611
AO-2009-1002	June 10, 2009	Application of 1626 Documentation Verification Requirements
EX-2009-1001	March 6, 2009	1610.6 Appointment of Counsel in Civil Family Law Right to Counsel Cases
EX-2008-1005	Dec. 8, 2008	Receipt of Court Ordered Guardian Fees
EX-2008-1004	Sept. 10, 2008	1610 Program Integrity Analysis of Subleasing Arrangement
EX-2008-1003	Sept. 10, 2008	Minors Represented through Court: Retainers and Eligibility Issues
EX-2008-1002	April 17, 2008	Permissibility of Attorneys' Fees in Social Security cases
EX-2008-1001	March 19, 2009	Requirement for Persons Assisted by PAI Attorneys to be Eligible Program Clients
EX-2006-1008	Nov. 2, 2006	Financial Eligibility of Client Member of Board of Directors
EX-2006-1007	Oct. 16, 2006	Application of Part 1608 to Newly Hired Attorney
EX-2006-1006	Oct. 5, 2006	Inquiry Regarding 45 CFR 1608.4(a)
EX-2006-1005	Oct. 5, 2006	Meaning of "intentionally identify" in 45 CFR 1608.4(a)
EX-2006-1004	July 11, 2006	Request for Reconsideration of EX-2003-1010
EX-2006-1003	June 7, 2006	Permissibility of Grantee Board Member Fundraising Lobbying Activities Under Part 1612
EX-2006-1002	May 8, 2006	Criminal Cases, Part 1613 and CSR Reporting
EX 2006-1001	Jan. 6, 2006	Financial Eligibility for Eligible Client Board Members
EX-2005-1004	June 10, 2005	1618 Compliance; 1604 Outside Practice of Law - Notary Service
EX-2005-1003	Dec. 16, 2005	Clarification of OLA External Opinion EX-2002-1004 Regarding PAI Cases and Attorneys' Fees
EX-2005-1002	July 15, 2005	Program Integrity Analysis of Configuration Proposal
EX-2005-1001	March 7, 2005	Whether Work with Law Students May Count Towards PAI Requirement
EX-2004-1006	Sept. 21, 2004	Duty to Ensure Continued Financial Eligibility
EX-2004-1005	Sept. 17, 2004	Review of Relationship Between MidPenn Legal Services and Dauphin County Bar Association
EX-2004-1004	June 2, 2004	Eligibility of Citizens of FSM and RMI for Legal Assistance under Compact of Free Association Amendments
EX-2004-1003	Feb. 23, 2004	Permissibility of Retroactive Payment of Wages
EX-2004-1002	Feb. 17, 2004	Representation of Persons in Actions Under Arkansas Criminal Eviction Statute
EX-2004-1001	Jan. 8, 2004	Attorney-Client Privilege and Access to Recipient Client Names, Problem Codes and Descriptions of Services
EX-2003-1015	Dec. 1, 2003	Program Integrity Analysis of Relationship Between LSC Recipient ALSC and non-LSC entity APBP
EX-2003-1014	Oct. 27, 2003	Permissibility of Attorneys' Fees Pursuant to Lease
EX-2003-1013	Sept. 16, 2003	Permissibility of PRLS Attorney Participation in Legislative Compilation of Puerto Rican Labor Laws
EX-2003-1012	July 23, 2003	1618 Compliance; 1604 Outside Practice of Law
EX-2003-1011	July 9, 2003	Interpretation of 45 CFR 1638 (Restriction on Solicitation) *Superseded by AO-2016-001
EX-2003-1010	July 9, 2003	Permissibility of Attorneys' Fees Claims Pursuant to State Contract Reciprocity Statutes
EX-2003-1009	June 24, 2003	Part 1610 Program Integrity Configuration Proposal
EX-2003-1008	May 8, 2003	Part 1610 Program Integrity Configuration Proposal
EX-2003-1007	April 2, 2003	Definition of Family Unit When Household is Split into Two Residences
EX-2003-1006	March 26, 2003	Priorities Requirements and non-LSC Funds
EX-2003-1005	March 20, 2003	Clarification of November 12, 1999 External Opinion on Attorneys' Fees
EX-2003-1004	March 7, 2003	Prohibited Political Activity under 45 C.F.R. Part 1608
EX-2003-1003	Feb. 10, 2003	Part 1604/Outside Practice of Law
EX-2003-1002	Jan. 21, 2003	Potential Conflict of Interest Where PAI Coordinator is Spouse of PAI Attorney
EX-2003-1001	Jan. 13, 2003	Transfer, Subgrant and PAI Questions Involving Technology Grants
EX-2002-1011	Dec. 13, 2002	Internal Opinion 2002-2008: Transfer, Subgrant and Subsidy Considerations for LSC Grantees Participating in Statewide Websites using LSC funds
EX-2002-1010	Dec. 8, 2002	Propriety of Judicial Custody Master Serving on NLS Board of Directors
EX-2002-1009	July 19, 2002	Subgrantee Timekeeping Requirements
EX-2002-1008	July 15, 2002	Attorneys' Fees Demand for Private Attorney Co-Counsel
EX-2002-1007	July 12, 2002	Subgrantee Timekeeping Superseded by EX-2002-1009
EX-2002-1006	June 14, 2002	Advice and Counsel or Brief Services for Prisoners
EX-2002-1005	May 7, 2002	Representation of homeless people on misdemeanor warrants and tickets
EX-2002-1004	May 7, 2002	Private attorneys claiming fees in cases under contract with recipients
EX-2002-1003	March 21, 2002	Inability of State or Local Judge to Overrule Executive Director's Determination About Outside Practice of Law or Circumvent LSC's Regulations Related Thereto
EX-2002-1002	Jan. 25, 2002	Requested Waiver of Income Eligibility Guidelines for National Reservists
EX-2002-1001	Jan. 25, 2002	Requested Waiver of Income Eligibility Guidelines for Victims of 9/11
EX-2001-1015	Oct. 22, 2001	The impact of the factors in 45 CFR sec. 1611.5(b)(1) on the determination of income eligibility
EX-2001-1014	Sept. 21, 2001	Acceptance of attorneys' fees as part of bankruptcy-related settlement
EX-2001-1013	Aug. 31, 2001	Representation of person involuntarily held in psychiatric facility pending determination of competency to stand trial for criminal charges
EX-2001-1012	July 30, 2001	Release of Client Intake Information in Response to Non-Judicial Subpoena
EX-2001-1011	July 11, 2001	Eligibility of Older Americans Act Client to Serve as ‘Eligible Client Member’ on Recipient Board of Directors
EX-2001-1010	May 7, 2001	Eligibility of Marshall Islanders for Legal Services
EX-2001-1009	April 9, 2001	Eligibility of Privately Funded, Non-Profit to Apply for LSC Grant Pursuant to Part 1634
EX-2001-1008	April 3, 2001	Health Insurance Premiums as Medical Expenses under 45 CFR Part 1611
EX-2001-1007	March 20, 2001	Assignment of Unsolicited Attorneys' Fees to Grantee by Judge
EX-2001-1006	March 19, 2001	Attorney's Fees Check Mistakenly Listing a Recipient as a Co-Payee
EX-2001-1005	Jan. 29, 2001	Representation of Legal Permanent Resident Who Has Left the U.S.
EX-2001-1004	March 14, 2001	Release of Subgrant to Reinstated Non-profit Subrecipient
EX-2001-1003	Feb. 16, 2001	Recipient Representation of Complainants in Domestic Violence Criminal Proceedings
EX-2001-1002	Feb. 2, 2001	Current Income Taxes and Client Income Eligibility under 45 CFR Part 1611
EX-2001-1001	Jan. 29, 2001	Request for an Opinion Regarding Composition of New, Merged Board of Directors
EX-2000-1023	Dec. 22, 2000	Disposal of Property with No Current Monetary Value
EX-2000-1022		Number not used
EX-2000-1021	Dec. 7, 2000	Substitution of Relay Center Service for TDD Equipment Pursuant to 45 CFR Part 1624
EX-2000-1020	Nov. 6, 2000	1618 Consultation -- 1604 Outside Practice of Law -- Previous Practice Cases after three years and the Definition of ‘Consulting.’
EX-2000-1019	Nov. 1, 2000	Eligibility of Citizen of American Samoa for Legal Services in Oklahoma; Applicability of Part 1635 Timekeeping Requirements to Public Defenders Employed by LAWO but Funded from Non-LSC Funds
EX-2000-1018	Aug. 25, 2000	LARC/NHLA Board Integration
EX-2000-1017	July 20, 2000	Permissibility of Contracts for Public Defender Services by LSC Recipients
EX-2000-1016	July 20, 2000	Use of LSC Funds as matching funds for VOCA grant
EX-2000-1015	July 20, 2000	Regarding the deductibility of current income taxes from gross income under 45 CFR Part 1611 in determining income eligibility
EX-2000-1014	Aug. 8, 2000	H-2A Worker Eligibility
EX-2000-1013	July 5, 2000	PASS Program Funds and Client Eligibility [Clarification of November 1, 1999 Opinion]
EX-2000-1012	June 21, 2000	Definition of Family Unit for 1611 Client Eligibility Purposes
EX-2000-1011	May 16, 2000	Outside Practice of Law - Consulting Services for Legal Helpline
EX-2000-1010	May 5, 2000	Outside Practice of Law - Date of Termination of Employment
EX-2000-1009	March 13, 2000	Use of LSC Funds as Matching Funds for Grants from TOP Superseded by AO-2019-004
EX-2000-1008	Feb. 23, 2000	Part 1604 Outside Practice of Law and Referrals from Charitable Organizations
EX-2000-1007	Feb. 15, 2000	Part 1626 Eligibility for Immigrants
EX-2000-1006	Feb. 15, 2000	Guardian Ad Litem Requirements
EX-2000-1005	Feb. 15, 2000	Running for non-partisan position
EX-2000-1004	Feb. 7, 2000	Waiver of Governing Body Restriction
EX-2000-1003	Feb. 1, 2000	Overlap of Board or Staff of Grantees and Subgrantees or Competing Organizations
Special Release	Jan. 29, 2000	Internal Opinion on LSC Access to Grantee Client Information [On 01.29.00, the Board of Directors of LSC voted to make this Internal Opinion available to the public.] Superseded by EX 2004-1001
EX-2000-1002	Jan. 28, 2000	Services to Alien Victim of Domestic Violence
EX-2000-1001	Jan. 11, 2000	Residency of Eligible Client Board Members of LSC Recipients
EX-1999-34	Dec. 8, 1999	Income Eligibility for FEMA Cases
EX-1999-29	Dec. 6, 1999	Transfer of IOLTA Funds and Program Integrity Guidelines
EX-1999-28	Dec. 3, 1999	Farm Expenses as Eligibility Deductions and Citizenship Eligibility for Group Clients
EX-1999-26	Nov. 12, 1999	Providing Time Records to Private Attorney for Fees Claim Clarified in EX-2003-1005
	Nov. 1, 1999	Client Eligibility under Part 1611
	Oct. 26, 1999	Part 1629 Purchase of Employee Dishonesty Insurance in Lieu of a Fidelity Bond
EX-1999-22	Oct. 15, 1999	Meaning of Income in Part 1611
EX-1999-19	Sept. 16, 1999	Program Integrity Plan [45 CFR Part 1610 & Part 1642]
EX-1999-18	Sept. 8, 2099	PSLS - Eligibility of Juveniles in State Foster Care Partially superseded by AO-2016-004
EX-1999-17	Aug. 27, 1999	Tribal Trust Funds & 45 CFR Part 1611
EX-1999-15	Aug. 16, 1999	Enforcement Procedures & Outside Practice of Law
EX-1999-12	July 1, 1999	[W]hether Recipients May Use LSC Funds for Fundraising Activities
EX-1999-08	July 16, 1999	Reporting Requirements of 45 C.F.R. § 1609
EX-1999-07	June 21, 1999	[W]hether Section 1610.6(b) Provides a Safe Harbor for Court Appointments to Civil Cases
EX-1999-06	June 21, 1999	[R]egarding the Corporation's Attorneys' Fees Regulation, 45 CFR Part 1642
EX-1999-05	March 4, 1999	Part 1637: Contract with Court to Represent Persons Likely to be Incarcerated
EX-1999-03	Aug 9, 1999	Retainer Agreement Requirement and PAI
EX-1999-02	June 18, 1999	[W]hether... Staff Member’s Potential Employment Constitutes “The Outside Practice of Law” or Falls Under the Exception of “Evaluations.”
EX-1999-01	Jan. 25, 1999	[R]Egarding the Ability of ...(A)... Full-Time Staff Attorney to Work to Supplement Her Income
EX-1998-63	Jan. 8, 1999	[R]egarding the Outside Practice of Law by a Legal Services Attorney
EX-1998-55	Nov. 6, 1998	The Application of Part 1626 to... Telephone Information, Advice and Referral System
EX-1998-53	Oct. 27, 1998	The Meaning of “Private Attorney” in 45 CFR Part 1614
EX-1998-47	Nov. 23, 1998	Whether 45 CFR Part 1608 Prohibits Voter Registration Activities by Non-Attorney Personnel in LSC-Funded Legal Services Programs
	July 27, 1998	Part 1618 Case Acceptance Procedures
EX-1998-41	July 13, 1998	Whether RLS Must Disclose Information on a Case
	July 10, 1998	Part 1637 Prisoner Representation and Clients Under House Arrest
EX-1998-38	June 25, 1998	Whether to Provide Civil Legal Representation to Prisoners
	June 23, 1998	Part 1627 Use of LSC Funds for Pension Plan Association Dues
	May 13, 1998	Part 1642 Attorneys' Fees in Administrative ERISA Case Files Prior to April 26, 1996
	April 17, 1998	Part 1609 Charging Clients Small Processing Fees
	April 14, 1998	Part 1604 Appointment of Staff Attorney as Paid Guardian Ad Litem
	April 13, 1998	Part 1610 Separately Funded Public Defender Program
	April 10, 1998	Parts 1611 and 1626 Financial and Alien Eligibility Requirements As Applied to Violence Against Women Act Funds
	April 9, 1998	Parts 1611 and 1626 Financial and Alien Eligibility Requirements As Applied to Court Grant for Pro Se Courthouse Assistance Superseded by AO-2016-007
	Jan. 27, 1998	Part 1610 Analysis of Affiliation Proposal
	Oct. 22, 1997	Part 1630 Use of LSC Funds as Matching Funds for Victims of Crime Act Grant Superseded by AO-2019-004
	Sept. 23, 1997	1607 Definition of Grantee Board Meeting Quorum
	Sept. 12, 1997	Part 1608 Program Attorney Who Ran for City Judgeship-Partially Overruled by EX-2003-1004
1997-09-10-a	Sept. 10, 1997	LSC is Not an Executive Agency, Department or Instrumentality of the Federal Government
1997-09-10-b	Sept. 10, 1997	Part 1610 Analysis of Affiliation Proposal
1997-09-10-c	Sept. 10, 1997	Provisions of Grantee Board Documents to Employee Union
	Sept. 4, 1997	Part 1607 Availability of a Waiver For Native American Program For Potential Attorney Board Members Not Licensed in the LSC Grant Service Area
1997-07-29-a	July. 29, 1997	Parts 1604 & 1642 Attorneys' Fees for Cases Handled by Full Time or Part Time Grantee Attorneys
1997-07-29-b	July 29, 1997	Part 1642 Attorneys' Fees for Social Security Cases Claimed Prior to Effective Date of Part 1642
	May 29, 1997	Part 1637 Application to Persons in Mental Institutions or Under House Arrest
	May 20, 1997	Part 1642 Application to Presentation of Attorney Time As Evidence in Re-Trial on Punitive Damages Claim
	Oct. 7, 1994	Fees Paid by Clients in a Part 1614 PAI Program