07/23/2021

1 Pamela D. Bucy Case Number: PR 21-0359 Chief Disciplinary Counsel 2 P.O. Box 1099 Helena, MT 59624-1099 3 (406)442-1648 4 pbucv cr montanaodc.or2 5 Office of Disciplinary Counsel

BEFORE THE COMMISSION ON PRACTICE OF THE SUPREME COURT OF THE STATE OF MONTANA *********** ** IN THE MATTER OF MARGARET Supreme Court No.: READER, ODC File No.: 21-063 A Suspended Attorney, COMPLAINT Respondent. Rules 8.1(b), MRPC 16 By leave of the Commission on Practice granted on July 14, 2021, the Office 17 ofDisciplinary Counsel for the State ofMontana("ODC"),hereby charges Margaret 18 Reader with professional misconduct as follows: 19 1. Margaret Reader, hereinafter referred to as Respondent, was admitted to 20 the practice of'law in the State of Montana in 2008, at which time she took the oath 21 required for admission, wherein she agreed to abide by the Rules of Professional 22 Conduct, the Disciplinary Rules adopted by the Supreme Court, and the highest 23 standards of honesty, justice and morality, including but not limited to, those 24 outlined in parts 3 and 4 of Chapter 61, Title 37, Montana Code Annotated.

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Complaint - Page 1 1 2. The Montana Supreme Court has approved and adopted the Montana Rules of Professional Conduct ("MRPC"), governing the ethical conduct of attorneys licensed to practice in the State of Montana, which Rules were in effect at all times mentioned in this Complaint.

5 3. In November of 2020, ODC received a grievance which alleged Respondent engaged in unethical conduct while representing numerous clients. The grievance was docketed as ODC File No.: 20-191.

8 4. Normally, ODC would forward the grievance to the Respondent for her response. However, ODC was advised that Respondent was being evicted from her io office space and she had not been seen in the office for a significant period of time.

11 Respondent's office is the address she has on file with the State Bar of Montana.

12 5. ODC attempted to contact Respondent on her cell phone, however, her voicemail was full, and no message could be left. ODC also sent text messages to the cell phone, to which Respondent did not respond. Next, ODC contacted Respondent's boyfriend confirming her personal address and that she was living at the residence with him.

17 6. By letter dated December 22, 2020, and addressed to Respondent's home address, ODC requested Respondent respond to the grievance. Respondent was given twenty-one days to provide her response, on or before January 14, 2021. The letter was not returned, and Respondent failed to respond. On February 4, 2021, ODC mailed, by certified/return receipt requested and regular mail, a letter requesting Respondent's response to the report within ten days from the date of the letter. The regular letter was not returned, and Respondent failed to respond. On March 2, 2021, the February 4 certified letter was returned to ODC as "Return to Sender, Unclaimed, Unable to Forward."

Complaint - Page 2 1 7. Having received no communication or response from Respondent, ODC requested the COP hold a Rule 24 Order to Show Cause hearing. The COP entered an Order March 12, 2021, ordering Respondent to appear on April 21, 2021. On March 19, 2021, ODC contacted the Civil Clerk with the Gallatin County Sheriff's office to personally serve Respondent with Show Cause documents. Finally, the Sheriff executed service upon Respondent on April 16, 2021, at her home.

7 8. The COP filed an Amended Petition asking the Court to accept and adopt their Rule 24 recommendation to suspend Respondent for thirty-days and take further action that the Court deems necessary. By Order dated April 27, 2021, the Montana Supreme Court denied the Petition citing that Respondent had not been 1I given proper notice as provided by Rule 24.

12 9. Rather than continue its efforts to pursue another Rule 24 hearing, ODC has elected to pursue a formal disciplinary matter. Respondent has failed to communicate with ODC in any fashion, or respond to ODC's inquiries, and effectively dodged attempts at service.

16 10. By her conduct outlined above, Respondent violated Rule 8.1(b), MRPC.

17 11. Rule 8A(6), MRLDE, provides additional grounds for discipline for Respondent's failure to promptly and fully respond to ODC's inquiries.

19 WHEREFORE,the Office of Disciplinary Counsel prays: 20 1. That a Citation be issued to the Respondent, to which shall be attached a copy of the complaint, requiring Respondent, within twenty-one (21) days after service, to file a written answer to the complaint; 23 2. That a formal hearing be had on the allegations ofthis complaint before an Adjudicatory Panel of the Commission; HI

Complaint - Page 3 1 3. That the Adjudicatory Panel of the Commission make a report of its 2 findings and recommendations after a formal hearing to the Montana Supreme 3 Court, and, in the event the Adjudicatory Panel finds the facts warrant disciplinary 4 action and recommends discipline, that the Commission also recommend the nature 5 and extent of appropriate disciplinary action, including an award of costs and 6 expenses incurred in investigating and prosecuting this matter; and, 7 4. For such other and further relief as deemed necessary and proper.

8 DATED this day of July 2021.

10 OFFICE OF DISCIPLINARY COUNSEL By.

13 Pamela D. Bucy Chief Disciplinary Counsel

Complaint - Page 4 CERTIFICATE OF SERVICE

I, Pamela D. Bucy, hereby certify that I have served true and accurate copies of the foregoing Complaint - Formal Complaint and Citation to Appear to the following on 07-23-2021:

Shelly Smith (Court Reporter) Office Administrator Supreme Court Boards and Commissions P.O. Box 203002 S. Park Ave., Ste. 328 Helena MT 59624 Service Method: eService E-mail Address: [email protected]

Electronically signed by Sandy Jacke on behalf of Pamela D. Bucy Dated: 07-23-2021