Rule 1.8. Conflict of Interest: Current Clients: Specific Prohibited Transactions

(a) A lawyer shall not enter into a business transaction with a client or

knowingly acquire an ownership, possessory, security or other pecuniary

interest adverse to a client unless:

(1) the transaction and terms on which the lawyer acquires the interest

are fair and reasonable to the client and are fully disclosed and transmitted

in writing in a manner that can be reasonably understood by the client;

(2) the client is advised in writing of the desirability of seeking and is

given a reasonable opportunity to seek the advice of independent legal

counsel on the transaction; and

(3) the client gives informed consent, in a writing signed by the client, to

the essential terms of the transaction and the lawyer’s role in the transaction, including whether the lawyer is representing the client in the transaction.

(b) A lawyer shall not use confidential information relating to representation of a client to the disadvantage of the client unless the client gives informed

consent, except as permitted or required by these Rules.

(c) A lawyer shall not solicit any substantial gift from a client, including a

testamentary gift, or prepare an instrument giving the lawyer or a person

related to the lawyer any substantial gift unless the lawyer or other recipient

of the gift is related to the client. For purposes of this paragraph, related

persons include a spouse, child, grandchild, parent, grandparent or other

relative or individual with whom the lawyer or the client maintains a close,

familial relationship.

(d) Prior to the conclusion of representation of a client, a lawyer shall not

make or negotiate an agreement giving the lawyer literary or media rights to

a portrayal or account based in substantial part on information relating to the

representation.

, child, grandchild, parent, grandparent or other

relative or individual with whom the lawyer or the client maintains a close,

familial relationship.

(d) Prior to the conclusion of representation of a client, a lawyer shall not

make or negotiate an agreement giving the lawyer literary or media rights to

a portrayal or account based in substantial part on information relating to the

representation.

(e) A lawyer shall not provide financial assistance to a client in connection

with pending or contemplated litigation, except that:

(1) a lawyer may advance court costs and expenses of litigation, the

repayment of which may be contingent on the outcome of the matter; and

(2) a lawyer representing an indigent client may pay court costs and

expenses of litigation on behalf of the client.

(3) a lawyer representing an indigent client pro bono, a lawyer representing an indigent client pro bono through a nonprofit legal services or public

interest organization and a lawyer representing an indigent client pro bono

through a law school clinical or pro bono program may provide modest gifts

to the client for food, rent, transportation, medicine and other basic living

expenses. The lawyer:

(i) may not promise, assure or imply the availability of such gifts prior

to retention or as an inducement to continue the client-lawyer relationship

after retention;

(ii) may not seek or accept reimbursement from the client, a relative of

the client or anyone affiliated with the client; and

(iii) may not publicize or advertise a willingness to provide such gifts to

prospective clients.

Financial assistance under this Rule may be provided even if the representation is eligible for fees under a fee-shifting statute.

he client-lawyer relationship

after retention;

(ii) may not seek or accept reimbursement from the client, a relative of

the client or anyone affiliated with the client; and

(iii) may not publicize or advertise a willingness to provide such gifts to

prospective clients.

Financial assistance under this Rule may be provided even if the representation is eligible for fees under a fee-shifting statute.

(f) A lawyer shall not accept compensation for representing a client from one

other than the client unless:

(1) the client gives informed consent;

(2) there is no interference with the lawyer’s independence of professional

judgment or with the client-lawyer relationship; and

(3) information relating to representation of a client is protected as

required by Rule 1.6.

(g) A lawyer who represents two or more clients shall not participate in

making an aggregate settlement of the claims of or against the clients, or in a

criminal case an aggregated agreement as to guilty or nolo contendere pleas,

unless each client gives informed consent. The lawyer’s disclosure shall

include the existence and nature of all the claims or pleas involved and of the

participation of each person in the settlement.

(h) A lawyer shall not:

(1) make an agreement prospectively limiting the lawyer’s liability to a

client for malpractice unless the client is independently represented in

making the agreement; or

(2) settle a claim or potential claim for such liability with an unrepresented client or former client unless that person is advised in writing of the

desirability of seeking and is given a reasonable opportunity to seek the

advice of independent legal counsel in connection therewith.

(i) A lawyer shall not acquire a proprietary interest in the cause of action or

subject matter of litigation the lawyer is conducting for a client, except that the

lawyer may:

(1) acquire a lien authorized by law to secure the lawyer’s fee or expenses;

and

(2) contract with a client for a reasonable contingent fee in a civil case.

ek the

advice of independent legal counsel in connection therewith.

(i) A lawyer shall not acquire a proprietary interest in the cause of action or

subject matter of litigation the lawyer is conducting for a client, except that the

lawyer may:

(1) acquire a lien authorized by law to secure the lawyer’s fee or expenses;

and

(2) contract with a client for a reasonable contingent fee in a civil case.

(j) A lawyer shall not have sexual relations with a client unless a consensual

sexual relationship existed between them when the client-lawyer relationship

commenced.

(k) While lawyers are associated in a firm, a prohibition in the foregoing

paragraphs (a) through (i) that applies to any one of them shall apply to all of

them.

Comment. — Business Transactions Between Client and Lawyer. [1] A

lawyer’s legal skill and training, together with the relationship of trust and

confidence between lawyer and client, create the possibility of overreaching

when the lawyer participates in a business, property or financial transaction

with a client, for example, a loan or sales transaction or a lawyer investment on

behalf of a client. The requirements of paragraph (a) must be met even when the

transaction is not closely related to the subject matter of the representation, as

when a lawyer drafting a will for a client learns that the client needs money for

unrelated expenses and offers to make a loan to the client. The Rule applies to

lawyers engaged in the sale of goods or services related to the practice of law, for

example, the sale of title insurance or investment services to existing clients of

the lawyer’s legal practice. See Rule 5.7. It also applies to lawyers purchasing

property from estates they represent. It does not apply to ordinary fee arrangements between client and lawyer, which are governed by Rule 1.5, although its

requirements must be met when the lawyer accepts an interest in the client’s

business or other nonmonetary property as payment of all or part of a fee

clients of

the lawyer’s legal practice. See Rule 5.7. It also applies to lawyers purchasing

property from estates they represent. It does not apply to ordinary fee arrangements between client and lawyer, which are governed by Rule 1.5, although its

requirements must be met when the lawyer accepts an interest in the client’s

business or other nonmonetary property as payment of all or part of a fee. In

addition, the Rule does not apply to standard commercial transactions between

the lawyer and the client for products or services that the client generally

markets to others, for example, banking or brokerage services, medical services,

products manufactured or distributed by the client, and utilities’ services. In

such transactions, the lawyer has no advantage in dealing with the client, and

the restrictions in paragraph (a) are unnecessary and impracticable.

[2] Paragraph (a)(1) requires that the transaction itself be fair to the client

and that its essential terms be communicated to the client, in writing, in a

manner that can be reasonably understood. Paragraph (a)(2) requires that the

client also be advised, in writing, of the desirability of seeking the advice of

independent legal counsel. It also requires that the client be given a reasonable

opportunity to obtain such advice. Paragraph (a)(3) requires that the lawyer

obtain the client’s informed consent, in a writing signed by the client, both to the

essential terms of the transaction and to the lawyer’s role. When necessary, the

lawyer should discuss both the material risks of the proposed transaction,

including any risk presented by the lawyer’s involvement, and the existence of

reasonably available alternatives and should explain why the advice of independent legal counsel is desirable. See Rule 1.0(f) (definition of informed

consent)

to the

essential terms of the transaction and to the lawyer’s role. When necessary, the

lawyer should discuss both the material risks of the proposed transaction,

including any risk presented by the lawyer’s involvement, and the existence of

reasonably available alternatives and should explain why the advice of independent legal counsel is desirable. See Rule 1.0(f) (definition of informed

consent).

[3] The risk to a client is greatest when the client expects the lawyer to

represent the client in the transaction itself or when the lawyer’s financial

interest otherwise poses a significant risk that the lawyer’s representation of the

client will be materially limited by the lawyer’s financial interest in the

transaction. Here the lawyer’s role requires that the lawyer must comply, not

only with the requirements of paragraph (a), but also with the requirements of

Rule 1.7. Under that Rule, the lawyer must disclose the risks associated with

the lawyer’s dual role as both legal adviser and participant in the transaction,

such as the risk that the lawyer will structure the transaction or give legal

advice in a way that favors the lawyer’s interests at the expense of the client.

Moreover, the client must give informed consent. In some cases, the lawyer’s

interest may be such that Rule 1.7 will preclude the lawyer from seeking the

client’s informed consent approving the transaction.

[4] If the client is independently represented in the transaction, paragraph

cture the transaction or give legal

advice in a way that favors the lawyer’s interests at the expense of the client.

Moreover, the client must give informed consent. In some cases, the lawyer’s

interest may be such that Rule 1.7 will preclude the lawyer from seeking the

client’s informed consent approving the transaction.

[4] If the client is independently represented in the transaction, paragraph

(a)(2) of this Rule is inapplicable, and the paragraph (a)(1) requirement for full

disclosure is satisfied either by a written disclosure by the lawyer involved in the

transaction or by the client’s independent counsel. The fact that the client was

independently represented in the transaction is relevant in determining

whether the agreement was fair and reasonable to the client as paragraph (a)(1)

further requires.

Use of Confidential Information Related to Representation. [5] Use of confi-

dential information relating to the representation to the disadvantage of the

client violates the lawyer’s duty of loyalty. Paragraph (b) applies when the

confidential information is used to benefit either the lawyer or a third person,

such as another client or business associate of the lawyer. For example, if a

lawyer learns that a client intends to purchase and develop several parcels of

land, the lawyer may not use that confidential information to purchase one of

the parcels in competition with the client or to recommend that another client

make such a purchase. The Rule does not prohibit uses that do not disadvantage the client. For example, a lawyer who learns a government agency’s

interpretation of trade legislation during the representation of one client may

properly use that confidential information to benefit other clients. Paragraph (b)

prohibits disadvantageous use of confidential client information unless the

client gives informed consent, except as permitted or required by these Rules.

See Rules 1.2(d), 1.6, 1.9(c), 3.3, 4.1(b), 8.1 and 8.3.

Gifts to Lawyers

nt agency’s

interpretation of trade legislation during the representation of one client may

properly use that confidential information to benefit other clients. Paragraph (b)

prohibits disadvantageous use of confidential client information unless the

client gives informed consent, except as permitted or required by these Rules.

See Rules 1.2(d), 1.6, 1.9(c), 3.3, 4.1(b), 8.1 and 8.3.

Gifts to Lawyers. [6] A lawyer may accept a gift from a client, if the

transaction meets general standards of fairness. For example, a simple gift such

as a present given at a holiday or as a token of appreciation is permitted. If a

client offers the lawyer a more substantial gift, paragraph (c) does not prohibit

the lawyer from accepting it, although such a gift may be voidable by the client

under the doctrine of undue influence, which treats client gifts as presumptively

fraudulent. In any event, due to concerns about overreaching and imposition on

clients, a lawyer may not solicit, promote, or suggest that a substantial gift be

made to the lawyer or for the lawyer’s benefit, except where the lawyer is related

to the client as set forth in paragraph (c).

[7] If effectuation of a substantial gift requires preparing a legal instrument

such as a will or conveyance, the client should have the detached advice that

another lawyer can provide. The sole exception to this Rule is where the client

is a relative of the donee.

[8] This Rule does not prohibit a lawyer from seeking to have the lawyer or

a partner or associate of the lawyer named as executor of the client’s estate or to

another potentially lucrative fiduciary position. Nevertheless, such appointments will be subject to the general conflict of interest provision in Rule 1.7

when there is a significant risk that the lawyer’s interest in obtaining the

appointment will materially limit the lawyer’s independent professional judgment in advising the client concerning the choice of an executor or other

fiduciary

state or to

another potentially lucrative fiduciary position. Nevertheless, such appointments will be subject to the general conflict of interest provision in Rule 1.7

when there is a significant risk that the lawyer’s interest in obtaining the

appointment will materially limit the lawyer’s independent professional judgment in advising the client concerning the choice of an executor or other

fiduciary. In obtaining the client’s informed consent to the conflict, the lawyer

should advise the client concerning the nature and extent of the lawyer’s

financial interest in the appointment, as well as the availability of alternative

candidates for the position.

Literary Rights. [9] An agreement by which a lawyer acquires literary or

media rights concerning the conduct of the representation creates a conflict

between the interests of the client and the personal interests of the lawyer.

Measures suitable in the representation of the client may detract from the

publication value of an account of the representation. Paragraph (d) does not

prohibit a lawyer representing a client in a transaction concerning literary

property from agreeing that the lawyer’s fee shall consist of a share in

ownership in the property, if the arrangement conforms to Rule 1.5 and

paragraphs (a) and (i).

Financial Assistance. [10] Lawyers may not subsidize lawsuits or administrative proceedings brought on behalf of their clients, including making or

guaranteeing loans to their clients for living expenses, because to do so would

encourage clients to pursue lawsuits that might not otherwise be brought and

because such assistance gives lawyers too great a financial stake in the

litigation. These dangers do not warrant a prohibition on a lawyer lending a

client court costs and litigation expenses, including the expenses of medical

examination and the costs of obtaining and presenting evidence, because these

advances are virtually indistinguishable from contingent fees and help ensure

access to the courts

ause such assistance gives lawyers too great a financial stake in the

litigation. These dangers do not warrant a prohibition on a lawyer lending a

client court costs and litigation expenses, including the expenses of medical

examination and the costs of obtaining and presenting evidence, because these

advances are virtually indistinguishable from contingent fees and help ensure

access to the courts. Similarly, an exception allowing lawyers representing

indigent clients to pay court costs and litigation expenses regardless of whether

these funds will be repaid is warranted.

[11] Paragraph (e)(3) provides another exception. A lawyer representing an

indigent client without fee, a lawyer representing an indigent client pro bono

through a nonprofit legal services or public interest organization and a lawyer

representing an indigent client pro bono through a law school clinical or pro

bono program may give the client modest gifts. Gifts permitted under paragraph (e)(3) include modest contributions for food, rent, transportation, medicine and similar basic necessities of life. If the gift may have consequences for

the client, including, e.g., for receipt of government benefits, social services, or

tax liability, the lawyer should consult with the client about these. See Rule 1.4.

[12] The paragraph (e)(3) exception is narrow. Modest gifts are allowed in

specific circumstances where it is unlikely to create conflicts of interest or invite

abuse. Paragraph (e)(3) prohibits the lawyer from (i) promising, assuring or

implying the availability of financial assistance prior to retention or as an

inducement to continue the client-lawyer relationship after retention; (ii)

seeking or accepting reimbursement from the client, a relative of the client or

anyone affiliated with the client; and (iii) publicizing or advertising a willingness to provide gifts to prospective to clients beyond court costs and expenses of

litigation in connection with contemplated or pending litigation or administrative proceedings

continue the client-lawyer relationship after retention; (ii)

seeking or accepting reimbursement from the client, a relative of the client or

anyone affiliated with the client; and (iii) publicizing or advertising a willingness to provide gifts to prospective to clients beyond court costs and expenses of

litigation in connection with contemplated or pending litigation or administrative proceedings.

[13] Financial assistance, including modest gifts pursuant to paragraph

(e)(3), may be provided even if the representation is eligible for fees under a

fee-shifting statute. However, paragraph (e)(3) does not permit lawyers to

provide assistance in other contemplated or pending litigation in which the

lawyer may eventually recover a fee, such as contingent-fee personal injury

cases or cases in which fees may be available under a contractual fee-shifting

provision, even if the lawyer does not eventually receive a fee.

Person Paying for a Lawyer’s Services. [14] Lawyers are frequently asked to

represent a client under circumstances in which a third person will compensate

the lawyer, in whole or in part. The third person might be a relative or friend,

an indemnitor (such as a liability insurance company) or a co-client (such as a

corporation sued along with one or more of its employees). Because third-party

payers frequently have interests that differ from those of the client, including

interests in minimizing the amount spent on the representation and in learning

how the representation is progressing, lawyers are prohibited from accepting or

continuing such representations unless the lawyer determines that there will be

no interference with the lawyer’s independent professional judgment and the

client gives informed consent to permit the arrangement. See also, Rule 5.4(c)

(prohibiting interference with a lawyer’s professional judgment by one who

recommends, employs or pays the lawyer to render legal services for another)

accepting or

continuing such representations unless the lawyer determines that there will be

no interference with the lawyer’s independent professional judgment and the

client gives informed consent to permit the arrangement. See also, Rule 5.4(c)

(prohibiting interference with a lawyer’s professional judgment by one who

recommends, employs or pays the lawyer to render legal services for another).

[15] Sometimes, it will be sufficient for the client to give informed consent

regarding the fact of the payment and the identity of the third-party payer. If,

however, the fee arrangement creates a conflict of interest for the lawyer, then the

lawyer must comply with Rule 1.7. The lawyer must also conform to the

requirements of Rule 1.6 concerning confidentiality. Under Rule 1.7(a), a

conflict of interest exists if there is significant risk that the lawyer’s representation of the client will be materially limited by the lawyer’s own interest in the

fee arrangement or by the lawyer’s responsibilities to the third-party payer (for

example, when the third-party payer is a co-client). Under Rule 1.7(b), the

lawyer may accept or continue the representation if each affected client gives

informed consent, unless the conflict is nonconsentable. Under Rule 1.7(b), the

client’s consent must be confirmed in writing.

Aggregate Settlements. [16] Differences in willingness to make or accept an

offer of settlement are among the risks of common representation of multiple

clients by a single lawyer. Under Rule 1.7, this is one of the risks that should be

discussed before undertaking the representation, as part of the process of

obtaining the clients’ informed consent. In addition, Rule 1.2(a) protects each

client’s right to have the final say in deciding whether to accept or reject an offer

of settlement and in deciding whether to enter a guilty or nolo contendere plea

in a criminal case

wyer. Under Rule 1.7, this is one of the risks that should be

discussed before undertaking the representation, as part of the process of

obtaining the clients’ informed consent. In addition, Rule 1.2(a) protects each

client’s right to have the final say in deciding whether to accept or reject an offer

of settlement and in deciding whether to enter a guilty or nolo contendere plea

in a criminal case. The rule stated in this paragraph is a corollary of both these

Rules and provides that, before any settlement offer or plea bargain is made or

accepted on behalf of multiple clients, the lawyer must inform each of them

about all the material terms of the settlement, including what the other clients

will receive or pay if the settlement or plea offer is accepted. See also, Rule 1.0(f)

(definition of informed consent). While lawyers representing plaintiffs or

defendants in a class action, or those proceeding derivatively, might not have a

full client-lawyer relationship with each member of the class, such lawyers must

comply with applicable rules regulating notification of class members and other

procedural requirements designed to ensure adequate protection of the entire

class.

Limiting Liability and Settling Malpractice Claims. [17] Agreements prospectively limiting a lawyer’s liability for malpractice are prohibited unless the

client is independently represented in making the agreement because they are

likely to undermine competent and diligent representation. Also, many clients

are unable to evaluate the desirability of making such an agreement before a

dispute has arisen, particularly if they are then represented by the lawyer

seeking the agreement. This paragraph does not, however, prohibit a lawyer

from entering into an agreement with the client to arbitrate legal malpractice

claims, provided such agreements are enforceable and the client is fully

informed of the scope and effect of the agreement

sirability of making such an agreement before a

dispute has arisen, particularly if they are then represented by the lawyer

seeking the agreement. This paragraph does not, however, prohibit a lawyer

from entering into an agreement with the client to arbitrate legal malpractice

claims, provided such agreements are enforceable and the client is fully

informed of the scope and effect of the agreement. Nor does this paragraph limit

the ability of lawyers to practice in the form of a limited liability entity, where

permitted by law, provided that each lawyer remains personally liable to the

client for his or her own conduct and the firm complies with any conditions

required by law, such as provisions requiring client notification or maintenance

of adequate liability insurance. Nor does it prohibit an agreement in accordance

with Rule 1.2 that defines the scope of the representation, although a definition

of scope that makes the obligations of representation illusory will amount to an

attempt to limit liability.

[18] Agreements settling a claim or a potential claim for malpractice are not

prohibited by this Rule. Nevertheless, in view of the danger that a lawyer will

take unfair advantage of an unrepresented client or former client, the lawyer

must first advise such a person in writing of the appropriateness of independent

representation in connection with such a settlement. In addition, the lawyer

must give the client or former client a reasonable opportunity to find and

consult independent counsel.

Acquiring Proprietary Interest in Litigation. [19] Paragraph (i) states the

traditional general rule that lawyers are prohibited from acquiring a proprietary interest in litigation. Like paragraph (e), the general rule has its basis in

common law champerty and maintenance and is designed to avoid giving the

lawyer too great an interest in the representation

to find and

consult independent counsel.

Acquiring Proprietary Interest in Litigation. [19] Paragraph (i) states the

traditional general rule that lawyers are prohibited from acquiring a proprietary interest in litigation. Like paragraph (e), the general rule has its basis in

common law champerty and maintenance and is designed to avoid giving the

lawyer too great an interest in the representation. In addition, when the lawyer

acquires an ownership interest in the subject of the representation, it will be

more difficult for a client to discharge the lawyer if the client so desires. The

Rule is subject to specific exceptions developed in decisional law and continued

in these Rules. The exception for certain advances of the costs of litigation is set

forth in paragraph (e). In addition, paragraph (i) sets forth exceptions for liens

authorized by law to secure the lawyer’s fees or expenses and contracts for

reasonable contingent fees. The law of each jurisdiction determines which liens

are authorized by law. These may include liens granted by statute, liens

originating in common law and liens acquired by contract with the client. When

a lawyer acquires by contract a security interest in property other than that

recovered through the lawyer’s efforts in the litigation, such an acquisition is a

business or financial transaction with a client and is governed by the requirements of paragraph (a). Contracts for contingent fees in civil cases are governed

by Rule 1.5. See also, Rules Governing Contingent Fees for Members of the

Wyoming State Bar.

Client-Lawyer Sexual Relationships. [20] The relationship between lawyer

and client is a fiduciary one in which the lawyer occupies the highest position

of trust and confidence. The relationship is almost always unequal; thus, a

sexual relationship between lawyer and client can involve unfair exploitation of

the lawyer’s fiduciary role, in violation of the lawyer’s basic ethical obligation

not to use the trust of the client to the client’s disadvantage

ship between lawyer

and client is a fiduciary one in which the lawyer occupies the highest position

of trust and confidence. The relationship is almost always unequal; thus, a

sexual relationship between lawyer and client can involve unfair exploitation of

the lawyer’s fiduciary role, in violation of the lawyer’s basic ethical obligation

not to use the trust of the client to the client’s disadvantage. In addition, such

a relationship presents a significant danger that, because of the lawyer’s

emotional involvement, the lawyer will be unable to represent the client without

impairment of the exercise of independent professional judgment. Moreover, a

blurred line between the professional and personal relationships may make it

difficult to predict to what extent client confidences will be protected by the

attorney-client evidentiary privilege, since client confidences are protected by

privilege only when they are imparted in the context of the client-lawyer

relationship. Because of the significant danger of harm to client interests and

because the client’s own emotional involvement renders it unlikely that the

client could give adequate informed consent, this Rule prohibits the lawyer from

having sexual relations with a current client regardless of whether the relationship is consensual and regardless of the absence of prejudice to the client.

[21] Sexual relationships that predate the client-lawyer relationship are not

prohibited. Issues relating to the exploitation of the fiduciary relationship and

client dependency are diminished when the sexual relationship existed prior to

the commencement of the client-lawyer relationship. However, before proceeding

with the representation in these circumstances, the lawyer should consider

whether the lawyer’s ability to represent the client will be materially limited by

the relationship. See Rule 1.7, Comment [12]

tation of the fiduciary relationship and

client dependency are diminished when the sexual relationship existed prior to

the commencement of the client-lawyer relationship. However, before proceeding

with the representation in these circumstances, the lawyer should consider

whether the lawyer’s ability to represent the client will be materially limited by

the relationship. See Rule 1.7, Comment [12].

[22] When the client is an organization, paragraph (j) of this Rule prohibits

a lawyer for the organization (whether inside counsel or outside counsel) from

having a sexual relationship with a constituent of the organization who

supervises, directs or regularly consults with that lawyer concerning the

organization’s legal matters.

Imputation of Prohibitions. [23] Under paragraph (k), a prohibition on

conduct by an individual lawyer in paragraphs (a) through (i) also applies to

all lawyers associated in a firm with the personally prohibited lawyer. For

example, one lawyer in a firm may not enter into a business transaction with a

client of another member of the firm without complying with paragraph (a),

even if the first lawyer is not personally involved in the representation of the

client. The prohibition set forth in paragraph (j) is personal and is not applied

to associated lawyers.

Definitional Cross-References

“Firm” See Rule 1.0(d)

“Informed consent” See Rule 1.0(f)

“Knowingly” See Rule 1.0(g)

“Substantial” See Rule 1.0(m)

“Writing” and “Signed” See Rule 1.0(o)