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October 2025
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The Keystone Lex
 
From the Chair
 

The annual National Celebration of Pro Bono underscores both the ongoing need for and the tremendous value of free, high-quality legal services in our communities. This year’s celebration, to be observed October 19th–25th, emphasizes supporting the unique and varied needs within our communities.
 
In the spirit that inspired this celebration, lawyers across Pennsylvania volunteer their time and expertise to provide pro bono legal services that are invaluable to the health and prosperity of their communities. No lawyer should take for granted the tremendous privilege and responsibility that accompanies a career in law. I urge you to share that privilege with those most in need of civil legal assistance, as the demand for such representation continues to grow throughout the country and here in Pennsylvania. I encourage you to visit the Pennsylvania Bar Association’s Pro Bono County Map to explore opportunities within your community.
 
Chief Justice Debra Todd has once again published an open letter to the PA Bar, honoring the National Celebration of Pro Bono. Chief Justice Todd notes this Bar’s historic leadership in pro bono service and urges the profession to continue its efforts at increasing access to justice throughout the Commonwealth.
 
The Disciplinary Board is inspired by the extraordinary pro bono work performed by legal professionals and law students throughout Pennsylvania. On behalf of the Board, I thank all who give of their time and talents in service to others. I strongly encourage all Pennsylvania lawyers to honor their professional responsibility and ethical duty to “render public interest legal service.” Our communities are greatly strengthened by it.
 
With gratitude,
 
David S. Senoff
Board Chair

Discipline Imposed
Reinstatements

September 2025
From Inactive
Courtney Mengel Dirks
Robert FitzPatrick
Grazia Elisa Mari
 
From Retired
Jeffrey Nicholas Blair
From Administrative Suspension
Lynne Ann Rocheleau
 
Note: The above-listed granted reinstatement matters reflect only those granted by Supreme Court Order. An attorney listed as reinstatement granted, but whose current license status does not reflect reinstatement, has yet to submit the fees necessary to finalize reinstatement.
Upcoming Public Proceedings
 
We encourage you to observe our public disciplinary and reinstatement hearings, oral arguments, and public reprimands on the Board’s YouTube channel. You can also view “Upcoming Public Proceedings” at the bottom of the Board’s home page.

Scheduled proceedings begin at 9:30 am unless otherwise noted.

Vacancies

The Supreme Court of Pennsylvania is aided by select boards, committees, commissions, and councils consisting of more than 180 appointed volunteers – most, but not all, are lawyers and judges. The panels have a wide range of responsibilities and functions. Some make recommendations to the Court for amendments, revisions, or simplification of court procedural rules. Others regulate the practice of law, oversee continuing legal education for lawyers, and administer funds to assist individuals unable to pay for legal services. Still others advise on keeping the courts free of bias and discrimination and on long-range planning.
 
There are currently vacancies on the following court entity:

Continuing Legal Education Board (PACLE) – Applicants must be active members of the Pennsylvania bar with their primary residency in Pennsylvania. In addition, applicants should be knowledgeable about legal practice and procedures in Pennsylvania state and federal courts.

Orphans’ Court Procedural Rules Committee – Applicants should be knowledgeable about the Pennsylvania Orphans’ Court Rules and experienced in Orphans’ Court practice in Pennsylvania.
 

Application Instructions
 
If you would like to be considered to serve on a board, committee, advisory group, or related independent entity, email the application, cover letter, resume, and other pertinent information expressing your reasons of interest to SCApplications@pacourts.us.

More information may be found on the Unified Judicial System of Pennsylvania website.
 
Applications are due by Friday, October 31, 2025.
Articles of Interest


Greene County Lawyer Suspended after Romance with Clients
 
By Order dated September 4, 2025, the Supreme Court of Pennsylvania suspended attorney Kimberly Furmanek of West Finley, Greene County from the practice of law for two years based on a finding by the Disciplinary Board that she had engaged in a romantic attachment to an imprisoned client and committed misconduct related to that representation.
 
Most of the issues arose from Furmanek’s involvement with John Lazear in a criminal case in her role as Conflicts Counsel for Greene County. She was acquainted with Lazear from high school but was not involved in a romantic relationship with him when she entered her appearance on his behalf.
 
About eighteen months into the representation, the relationship between Furmanek and Lazear became personal and romantic. This continued until Furmanek’s termination from the Conflict Counsel office on December 7, 2021. She testified that she explained to Lazear it was "frowned upon for an attorney and a client to be in a relationship" but stated "it was never an issue for [Lazear]." Furmanek admitted that she never obtained Lazear's informed consent to the conflict. She was criticized by the prison for wearing inappropriate attire, engaged in personal discussion on telephone calls intended for counsel business, and a video taken during a visit authorized only for professional contacts displayed an embrace and an intimate kiss between Furmanek and Lazear, which was strictly prohibited by prison policy. When questioned by the Court Administrator about her involvement, she falsely denied that the relationship was romantic.
 
Furmanek also allowed the client to listen in on a telephone call to his successor counsel, without counsel’s knowledge, after which the client made threatening calls to successor counsel’s office, leading to successor counsel’s decision to withdraw. Furmanek was charged with criminal conduct because of this call and entered a counseled plea of guilty to two misdemeanor counts for which she was sentenced to probation for a period of twelve months. The client was also convicted of one count of terroristic threats due to the calls.
 
The Disciplinary Board found that Furmanek’s conduct violated several Rules of Professional Conduct, including RPC 1.7(a)(2) [concurrent conflict of interest], RPC 1.16(a)(1) [failure to withdraw], RPC 4.1(a) [false statement of fact to a third person], and several sections of RPC 8.4. In addition, the Board noted that her criminal conviction was, in and of itself, grounds for discipline.
 
The Board found a significant aggravating factor in her failure to accept full responsibility or to show remorse due to her failure to comprehend that her conduct was unethical. Another aggravating factor was that Furmanek had been warned by the Office of Disciplinary Counsel that romantic relationships with clients were prohibited in a prior case and still indulged in such a relationship both with Lazear and with a subsequent client. The Board also found Furmanek's testimony lacking in credibility. Mitigating factors included a lack of prior discipline and character witness testimony. After review of case law, the Board recommended a suspension for two years. The Supreme Court accepted this recommendation and suspended Furmanek for two years.
 

Texas Lawyer Charged with Cyberstalking BigLaw Lawyers

A Texas lawyer has been charged in federal court with cyberstalking and transmitting threatening communications after she targeted a partner and an associate in a large international law firm with dozens of social media posts and emails threatening numerous consequences including violence.
 
A criminal complaint filed September 5, 2025 in the Northern District of Texas against Fangzhou Chen, who goes by the name of Amber Chen, alleges that she made numerous posts on an unidentified social media account, leveling accusations against one of the attorneys, demanding his resignation, threatening to release damaging information, and escalating to threats of violence. One post said, “If any of you ever stalk me again I’ll [pistol icon] you to death.” Another said, simply, “Sniper on site.” Another identified the locations of the two attorneys and added, “Use a silencer,” a phrase that appeared in several posts and emails. The posts stated or implied that the associate, located in Los Angeles, had contracted for the murder of the partner, located in New York.
 
The partner in New York also received nine emails over two days ordering him to leave the country under threat of death. One stated, “If I ever see you anywhere around [the law firm] anywhere on earth, you will be eliminated on the spot.”
 
Chen had never worked for the law firm, although she included it on her Texas State Bar listing, and the victim attorneys were unaware of what connection she had to the law firm or what her grievance with it was.
 
At the time the law firm reported the incidents, Chen was already under investigation by the FBI based on her history of submitting over twenty-five tips alleging a variety of threats, including international and domestic terrorism, murder-for-hire, crimes against children, bank robbery, civil rights crimes, and election crimes. None of the tips were substantiated.
 

AI Follies, October Edition: Counsel’s Responsibilities and Disciplinary Practice
 
Sometimes it seems that we need a regular monthly section on lawyers (and judges) getting themselves in trouble for misusing artificial intelligence-assisted software tools.
 
This month provides two new wrinkles in the growing literature of AI-driven misadventures.
 
Defense Counsel Responsibilities
 
A new decision from the California Court of Appeals raises a question that should bother even those attorneys who disdain or use carefully the new technology: does opposing counsel have an obligation to call the court’s attention to “hallucination” cases cited by the other side?
 
In the case of Noland v. Land of the Free, L.P., counsel for the plaintiff had well and truly mangled his briefs by citing a large number of inapplicable or nonexistent cases, or “hallucinations.” The Court found that twenty-one of twenty-three case quotations in his opening brief were fabricated, along with many more in the reply brief. The briefs contained supposed quotes from the cases that were not in them, and other cases did not support the points for which they were cited or exist at all. Counsel admitted that he was unaware that AI-generated quotes were not authentic and failed to review the cases cited directly. The Court found the appeal frivolous on this ground and upheld the lower court’s grant of summary judgment. Since the false citations forced the court staff to perform research and effort to discern the truth, the Court ordered that plaintiff’s counsel pay $10,000 in sanctions to the Court.
 
The Court declined, however, to award sanctions to the defendants, noting that “respondents did not alert the court to the fabricated citations and appear to have become aware of the issue only when the court issued its order to show cause.”
 
The California Court of Appeals ruling suggests that counsel encountering an opponent who has cited hallucinated cases has a responsibility to call them to the attention of the court and not sit back and wait for the court to do the work of discovery.
 
A Very Bad Setting to Hallucinate
 
One suspended lawyer found out the hard way what happens when opposing counsel does check the citations.
 
Iowa lawyer Royce David Turner was suspended in 2018. He filed a series of petitions for reinstatement. In the latest, he filed documents with the Supreme Court of Iowa in support of his reinstatement in anticipation of a scheduled hearing.
 
Unfortunately for Turner, counsel for the Iowa Disciplinary Board did check his citations and discovered that “several of Respondent’s filings contain what appears to be at least one AI-generated citation to a case that does not exist or does not stand for the proposition asserted in the filings.” An Indiana case by the same name exists, but neither a case in Iowa nor any case at the citation given could be found. The Disciplinary Board moved to strike the three offending documents.
 
Reports on the case do not indicate whether the Court has acted on the Board’s motion to strike, but it did cancel a reinstatement hearing scheduled for July 31st, noting that Turner had yet to establish proof of payment to his clients or provide “convincing proof” of his fitness to practice law.
 
When trying to establish one’s fitness to practice law, citing a fictitious case in support of reinstatement might not be the best strategy.
 

Lawyer for Claire’s Accepts Ear Piercing in Court
 
We’ve heard stories of lawyers getting reamed out in court, but a New York attorney volunteered to take the needle for his client’s cause, and the court took him up on it.
 
Kirkland and Ellis partner Joshua Sussberg was representing Claire’s, the accessories giant, in proceedings in bankruptcy court in the U.S. District Court for Delaware. Sussberg and his co-counsel were seeking court approval of a plan to try to find a buyer for Claire’s and avoid a liquidation. Co-counsel recounted that both she and the judge’s daughter had undergone ear piercings at Claire’s. Then the team produced a picture showing that Sussberg himself had his ears pierced at Claire’s as a high school student in 1995. Seeking to nail down the deal, Sussberg told the court, “Your honor, we are focused on preserving jobs and keeping stores open for a long time so many people can get their ears pierced. If we can get a deal done, I am willing to get my ears pierced.” Judge Bredan Shannon answered, “I’m going to hold you to that.”
 
And, indeed, he did. After the deal was worked out, Sussberg gamely showed up in Judge Shannon’s court where a Claire’s staffer did the deed on his left ear. He even wore a Claire’s crown for the occasion. There’s a video.

Attorney Well-Being

 

Lawyers Concerned for Lawyers and PA Board of Law Examiners to Discuss Character and Fitness

Attention, law students! Lawyers Concerned for Lawyers of Pennsylvania and the PA Board of Law Examiners will be hosting a live virtual event in partnership with Villanova University Charles Widger School of Law on Monday, October 20th at 10:15am. "Everything You Wanted to Know About Character and Fitness and the Challenges of Modern Practice" will be open to all PA law students and faculty. Register here for the upcoming event.

 


Explore the Disciplinary Board's Lawyer Well-Being Webpage

The Disciplinary Board's "Lawyer Well-Being" webpage connects Pennsylvania attorneys with pertinent resources, articles, events, and CLE opportunities to better understand and support their mental health and well-being. To access the Board’s “Lawyer Well-Being” page, visit padisciplinaryboard.org/for-attorneys/well-being.
 


 



Lawyers Concerned for Lawyers is a confidential assistance program for the Pennsylvania legal community and their family members. LCL may not report information about a subject attorney back to the Disciplinary Board.

Confidential 24/7 Helpline: 1-888-999-1941

Last year, the Supreme Court of Pennsylvania adopted amendments to the Pennsylvania Rules of Disciplinary Enforcement (Pa.R.D.E.) relating to confidentiality of proceedings, providing for three exceptions to the requirement of confidentiality under Pa.R.D.E. 402(d). Included in these exceptions is the allowance for Disciplinary Counsel to make a referral of an attorney to Lawyers Concerned for Lawyers of Pennsylvania (LCL) and share information as part of the referral. However, it is crucial to note that LCL may not report information about a subject attorney back to the Disciplinary Board. LCL is a confidential assistance program for the Pennsylvania legal community and their family members.

Around the Court


Chief Justice Debra Todd Pens Letter to Pennsylvania Bar Honoring 2025 National Celebration of Pro Bono
 
Chief Justice Debra Todd has published her yearly open letter to Pennsylvania attorneys honoring the 2025 National Celebration of Pro Bono and encouraging support of pro bono legal work across the Commonwealth.
 
First instituted under the sponsorship of the American Bar Association by Philadelphia lawyer Sharon Browning, the annual observance “draw[s] attention to the need for pro bono participation [and thanks] those who give their time year-round”. This year’s celebration, held throughout the week of October 19th-25th, will highlight lawyers' roles in “Supporting Communities” through pro bono work.
 
In her letter, Chief Justice Todd lauds the Commonwealth as “a national leader in so many ways, including raising the bar for providing legal services to those who cannot afford it.” She also reminds the Bar that the PA Bar Association, local bar associations, and legal aid organizations sponsor events promoting pro bono work and offering service opportunities throughout the month of October.
 
Read Chief Justice Todd’s full letter here. Access PAProBono.net’s full calendar of activities here.

 

Pennsylvania Courts Publish New Infographic in Honor of September 17th's Constitution Day

To honor September 17th's Constitution Day, Pennsylvania released a new infographic highlighting interesting facts about the state and federal Constitutions. Additional educational materials are available here on the Unified Judicial System's civics education webpage.
 
From the Pennsylvania Bar Association


 
October with the Pennsylvania Bar Association

PBA Membership

Now is a great time to get involved and join the Pennsylvania Bar Association! Throughout the month of October, new members can get fifteen months for the price of just twelve months. Join for 2026 and get the remainder of 2025 included (new members only).
 
National Pro Bono Month
 
October is National Pro Bono Month. It is time to honor the legal professionals who dedicate their time and expertise to serving those in need. This year’s National Celebration of Pro Bono's theme, “Supporting Communities Through Pro Bono,” reminds us that legal service is not just a profession—it’s a calling to uplift and empower.
 
Lawyer volunteers are needed now for Pennsylvania Free Legal Answers, an automated tool developed by the American Bar Association.
 
Using a website form, a public user may request brief advice about a specific civil legal issue. A volunteer lawyer, law student, or paralegal (working under the direction of a lawyer volunteer or staff member) provides basic legal advice without the expectation of long-term representation.
 
To participate, a legal volunteer completes three steps:
1. Signs the Attorney User Agreement.
2. Creates a password to establish a volunteer account.
3. Provides contact information and his or her Pennsylvania Attorney ID number.
 
For more information, visit pa.freelegalanswers.org.
 
PBA’s Member Appreciation Week
 
Member Appreciation Week is October 27th-31st! This year’s theme, “T.R.E.A.T.,” highlights the power of PBA membership through Talent, Relationships, Expertise, Advocacy and Training.
 
PBA members will enjoy exclusive content, prize giveaways, member spotlights, and more, all designed to recognize the incredible value members bring to our legal community. Whether a new or a longtime member, get ready to T.R.E.A.T. yourself and celebrate the benefits of belonging to the PBA!

 


Please note that the Disciplinary Board of the Supreme Court of Pennsylvania and the Pennsylvania Bar Association (PBA) are separate organizations. For more information about PBA, visit pabar.org or follow on Facebook, Instagram, and LinkedIn.
We Want To Hear From You...
 
We are always on the lookout for stories of interest relating to legal ethics, new issues in the practice of law, lawyer wellness, and funny or just plain weird stories about the legal profession. If you come across something you think might be enlightening, educational, or entertaining to our readers or social media followers, pass it along. If you are our original source, there may be a hat tip in it for you.
 
 
 

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