Attorney Grievance Commission of Maryland v. George L. Farmer, AG No. 41, September 

Term, 2021. Opinion by Gould, J.

ATTORNEY DISCIPLINE – SANCTIONS – INDEFINITE SUSPENSION

The Court indefinitely suspended an attorney who engaged in the unauthorized practice of 

law, represented clients with a conflict of interest, collected and billed for fees that were 

unreasonable, and filed a frivolous lawsuit. The attorney’s conduct violated Maryland 

Attorneys’ Rules of Professional Conduct: 1.4 (Communication), 1.5 (Fees), 1.7 (Conflict 

of Interest—General Rule), 1.16(a)(1) (Declining or Terminating Representation), 3.1 

(Meritorious Claims and Contentions), 5.5(a) (Unauthorized Practice of Law; MultiJurisdictional Practice of Law), and 8.4(a) (Misconduct).

 
Circuit Court for Montgomery County

Case No.: C-15-CV-21-000332

Argued: November 4, 2022

IN THE SUPREME COURT

OF MARYLAND*

AG No. 41

September Term, 2021

______________________________________

ATTORNEY GRIEVANCE COMMISSION

OF MARYLAND

v.

GEORGE L. FARMER

______________________________________

Fader, C.J.,

Watts,

Hotten,

Booth,

Biran,

Gould,

Eaves,

 

JJ.

______________________________________

Opinion by Gould, J.

______________________________________

Filed: July 10, 2023

* At the November 8, 2022 general election, the voters of Maryland ratified a constitutional 

amendment changing the name of the Court of Appeals of Maryland to the Supreme Court 

of Maryland. The name change took effect on December 14, 2022.
On December 1, 2021, pursuant to Maryland Rule 19-721, the Attorney Grievance 

Commission of Maryland (the “Commission”), acting through Bar Counsel, filed a Petition 

for Disciplinary or Remedial Action (the “Petition”) against George L. Farmer. The 

Petition alleged that Mr. Farmer violated the following provisions of the Maryland 

Attorneys’ Rules of Professional Conduct (“MARPC”):

1 1.4 (Communication) (Rule 19-

301.4), 1.5 (Fees) (Rule 19-301.5), 1.7 (Conflict of Interest—General Rule) (Rule 19-

301.7), 1.16(a)(1) (Declining or Terminating Representation) (Rule 19-301.16), 3.1 

(Meritorious Claims and Contentions) (Rule 19-303.1), 5.5(a) (Unauthorized Practice of 

Law; Multi-Jurisdictional Practice of Law) (Rule 19-305.5), and 8.4(a) (Misconduct) (Rule 

19-308.4).

In accordance with Maryland Rules 19-722(a) and 19-727, we assigned the Petition 

to the Honorable Karla N. Smith of the Circuit Court for Montgomery County (the “hearing 

judge”) to hold an evidentiary hearing and issue findings of fact and conclusions of law. 

The hearing was held virtually on May 16, 17, and 23, and June 1, 2022, via the 

application Zoom for Government, by consent of the parties. 

Prior to the hearing, the hearing judge resolved several motions, including:

1. Mr. Farmer’s Motion to Dismiss the Petition Due to Lack of Jurisdiction and 

Venue – Denied; and

1 Effective July 1, 2016, the Maryland Lawyers’ Rules of Professional Conduct,

which employed the numbering format of the American Bar Association Model Rules, 

were renamed the MARPC and recodified without substantive modification in Title 19, 

Chapter 300 of the Maryland Rules. For ease of reference and comparison with our prior 

opinions and those of other courts, we will refer to the MARPC rules using the numbering 

of the model rules, as permitted by Rule 19-300.1(22) and as identified in the paragraph to 

which this footnote is appended. 
2

2. The Commission’s Motion to Quash Subpoenas to Bar Counsel – Granted.

At the evidentiary hearing, the Commission presented its case with four witnesses

and 46 exhibits. Mr. Farmer testified on his own behalf and presented 14 exhibits. 

On July 18, 2022, the hearing judge issued a written statement containing findings 

of fact and conclusions of law (the “findings”), concluding by clear and convincing 

evidence that Mr. Farmer violated MARPC 1.4 (Communication), 1.5 (Fees), 1.7 (Conflict 

of Interest—General Rule), 1.16(a)(1) (Declining or Terminating Representation), 3.1 

(Meritorious Claims and Contentions), 5.5(a) (Unauthorized Practice of Law; MultiJurisdictional Practice of Law), and 8.4(a) (Misconduct). The hearing judge also found 

one mitigating factor and five aggravating factors.

Mr. Farmer filed exceptions to multiple findings pursuant to Maryland Rule 19-

728(b). The Commission excepted to one finding.

2

Oral argument was held before this Court on November 4, 2022. As explained 

below, we overrule Mr. Farmer’s exceptions and the Commission’s exception, adopt the 

hearing judge’s findings, and determine that indefinite suspension is the appropriate 

sanction under the facts and circumstances of this case. 

2 Although the Commission filed no formal or separate exceptions, in a footnote to 

its Recommendation for Sanction, it stated that, to the extent that the hearing judge’s failure 

to reference a violation of Rule 8.4(b) and (c) indicated its conclusion that Mr. Farmer did 

not violate those rules, it excepts. 
3

I

FACTS

A. Background Facts

In 1996, Mr. Farmer was admitted to the bars of the Commonwealth of Pennsylvania 

and the State of New Jersey. He was admitted to the bar of the State of Colorado in 1999. 

He has never been a member of the Maryland bar. 

In 2018, Thuan Nguyen, a family friend of Mr. Farmer, began working for Maryland 

resident, Louise Williams Marsh, as her full-time caretaker. At that time, Ms. Marsh was 

a 92-year-old widow who suffered from dementia. Ms. Marsh was represented by J. 

Laurence Kent, a Maryland attorney who had provided estate and trust planning services 

to Ms. Marsh, her late husband, Richard Wade Marsh, Sr. (“Mr. Marsh”), and their son 

Richard Marsh, Jr. (“Rick”) for approximately three decades. In 2018, Ms. Marsh and Rick 

lived together in Ms. Marsh’s house in Silver Spring, Maryland. 

In 1988, Mr. Kent set up a trust for the Marshes (the “Trust”), which initially named 

Mr. Marsh and Ms. Marsh as the grantors, trustees, and beneficiaries, with Rick as the 

successor beneficiary. The assets of the Trust included the Marshes’ Silver Spring house

and various bank and brokerage accounts. The Trust’s bank accounts were maintained at 

Sandy Spring Bank. 

Mr. Marsh passed away on January 22, 2009. 

After her husband passed away, Ms. Marsh succeeded her husband as the sole 

trustee. She amended the Trust in 2010 to name herself as the sole beneficiary during her 

lifetime, with Rick as the successor beneficiary upon her death. The Trust also provided 
4

that if Rick predeceased Ms. Marsh, the Trust assets would pass to various charities. Under 

the amended Trust, Ms. Marsh continued as trustee, and Mr. Kent was named successor 

trustee. 

In 2015, Ms. Marsh executed an amendment to the Trust prepared by Mr. Kent to 

provide that upon Ms. Marsh’s death, if Rick was surviving, her house would pass to him

free of the Trust, and the remaining assets would be held in trust for his benefit. 

In late 2018 or early 2019, Ms. Nguyen and Rick were married. Ms. Nguyen moved 

into the residence and continued working as Ms. Marsh’s paid caretaker.

3

 

In 2019, Rick retained Mr. Kent for estate planning services, including preparation 

of his own will and power of attorney, both of which he duly executed. 

In early March 2020, Rick fell ill and was hospitalized. Because Ms. Marsh was no 

longer able to serve as trustee, Mr. Kent assumed the trustee’s duties, as provided under 

the 2010 amendment to the Trust. With Mr. Kent now serving as trustee, the Trust needed 

a new successor trustee in case something happened to Mr. Kent that rendered him unable 

to serve. And because Rick was unable to serve due to his declining health,4 Mr. Kent 

prepared an amendment to the Trust on March 3, which Ms. Marsh signed, appointing his 

law partner, Helen Dankos, as successor trustee. 

3 The Trust paid Ms. Nguyen $2,000 per week for her caretaking services.

4 Rick died on April 21, 2020. 
5

B. Mr. Farmer Enters the Scene

Ms. Nguyen was never a beneficiary of the Trust, but she was a beneficiary under 

Rick’s will. After Ms. Marsh executed the amendment to the Trust, Ms. Nguyen reached 

out to her brother who notified Mr. Farmer that she needed assistance. On March 3, Ms. 

Nguyen spoke to Mr. Farmer, and the next day, he drove from New Jersey to Maryland to 

meet with Ms. Nguyen, Ms. Marsh, and Rick Marsh. Initially, Mr. Farmer met with Ms. 

Nguyen and Ms. Marsh at Ms. Marsh’s residence. They then went to the hospital to speak 

with Rick. While at the hospital, Mr. Farmer asked Rick how much money was in the 

Trust; Rick said it held about five million dollars. Mr. Farmer then returned to New Jersey. 

He had several conversations with Ms. Nguyen, and she ultimately retained him to

represent her. 

On March 5, Mr. Farmer sent a letter to Mr. Kent titled “Louise Williams Marsh’s 

Instructions to J. Laurence Kent, Esq.,” which was drafted by Mr. Farmer and signed by 

Ms. Marsh in the presence of a notary public. In these instructions, Ms. Marsh told Mr. 

Kent to (1) rescind the power of attorney naming Mr. Kent as her agent;

5

(2) draft a new 

power of attorney in favor of Mr. Kent and Ms. Nguyen jointly, so that neither could act 

individually on her behalf; and (3) send Mr. Farmer copies of the Trust documents and Ms. 

Marsh’s will. 

On March 6, Mr. Kent visited Ms. Marsh’s residence. While there, he spoke with 

Mr. Farmer by telephone. Mr. Kent informed Mr. Farmer that he would not provide the 

5 The instructions reflect a mistaken assumption that Ms. Marsh had previously 

signed a power of attorney appointing Mr. Kent as her agent. 
6

requested information and documentation. Mr. Kent contended that Mr. Farmer did not 

have the authority to instruct him because he was not a Maryland attorney, and Ms. Marsh 

“didn’t have the capacity to appoint him.” 

Because Mr. Farmer believed that he needed to become Ms. Marsh’s attorney to 

compel Mr. Kent to send him the Trust and will documents, on March 6, he prepared a 

“Legal Representation Retainer Agreement” addressed to Ms. Marsh. The agreement was 

executed by Ms. Marsh, and she paid Mr. Farmer a retainer of $8,500. 

The agreement was printed on letterhead from Mr. Farmer’s Northfield, New Jersey 

office and stated, in relevant part: 

Please accept this letter as my request for me to represent your interests in 

reviewing Mr. Kent’s prior services and documents, as well as the financial 

accounts including, but not limited to the documents he had you sign 

recently, the trust agreement(s), your will, the financial accounts, the 

expenditures from the accounts, etc. with the purpose of determining if there 

are any improprieties. 

By signing this retainer letter of engagement, you are authorizing me to 

perform these services, obtain the aforementioned documents, and take 

whatever steps I deem necessary (if any) to protect your interests depending 

upon the information I discover. 

In light of the fact that I represent your daughter-in-law as well, you will need 

to waive any conflicts that might exist as well as any appearance of conflicts. 

By entering into this retainer agreement, you hereby do waive said conflicts 

and appearance of conflicts. 

On or about March 10, Ms. Nguyen executed a separate conflict of interest waiver, 

which stated merely that she waived any conflict of interest created by Mr. Farmer’s 

representation of both her and Ms. Marsh. 
7

On March 13, Mr. Farmer again demanded that Mr. Kent comply with the 

instructions in the March 5 letter and threatened an ethics complaint against Mr. Kent if he 

refused. 

On April 7, Ms. Marsh signed a document entitled “Third Amendment to Louise W. 

Marsh, Second Amended and Restated Trust Agreement” (the “Third Amendment”).6

Under the Third Amendment, Ms. Marsh remained trustee, and Mr. Kent was removed as 

co-trustee. In Mr. Kent’s place, the Third Amendment appointed one John L. Hoffmann, 

a CPA who happened to share Mr. Farmer’s New Jersey office and with whom Mr. Farmer 

had a professional relationship for about twenty years. Mr. Farmer sent a copy of this 

amendment to Mr. Kent and broke the news that Mr. Kent was no longer co-trustee. 

On April 7, Mr. Farmer sent a letter to Sandy Spring Bank declaring that any actions 

by Mr. Kent were “hereby ineffective” and that the Trust’s money was to be transferred to 

a Wells Fargo account being established by Mr. Hoffmann. Sandy Spring Bank declined 

to follow these requests, prompting Mr. Farmer to file a complaint against the bank.7 

6 When questioned by Bar Counsel as to who drafted this Third Amendment, Mr. 

Farmer asserted his Fifth Amendment right against self-incrimination and did not answer 

the question. In addition to the adverse inference she drew from his assertion of this right, 

the hearing judge found that there was sufficient evidence to find that Mr. Farmer drafted 

the document, noting that: Mr. Farmer began purportedly representing Ms. Marsh on 

March 6; he came into possession of the amendment the same day that Ms. Marsh signed 

it; Mr. Hoffman, a person unknown to Ms. Marsh but a longtime associate of Mr. Farmer, 

was appointed as the new co-trustee; and Mr. Kent was not aware of this amendment until 

Mr. Farmer sent it to him. 

7 According to Mr. Farmer’s testimony, he filed the complaint with the “Department 

of Banking with the state.” 
8

On April 9, Mr. Farmer sent a letter to Mr. Kent demanding that he cease and desist 

acting as co-trustee and requesting the Trust’s Federal Employer Identification Number. 

After Mr. Kent did not respond, Mr. Farmer sent several emails to Mr. Kent requesting the 

Trust documents. Meanwhile, Sandy Spring Bank froze the Trust’s accounts. 

C. Mr. Kent Files a Petition for Appointment of Guardian of the Person and Property 

of Ms. Marsh

Concerned that others were trying to gain improper access to Ms. Marsh’s finances,

on April 17, Mr. Kent filed in the Circuit Court for Montgomery County an Emergency 

Petition for the Appointment of Temporary and Permanent Guardians of the Person and 

Property of Ms. Marsh. Mr. Kent supported his petition with a certification from Ms. 

Marsh’s primary care physician stating that: (1) Ms. Marsh had been examined in her care 

for over ten years; (2) in December 2019, she determined that Ms. Marsh was suffering 

from severe dementia; (3) Ms. Marsh’s overall mental health would decline; (4) she 

believed Ms. Marsh needed a guardian of her property; and (5) the dementia “prevent[ed] 

[Ms. Marsh] from making or communicating responsible decisions concerning her 

personal affairs and her property.” 

On April 20, the circuit court granted the emergency petition and issued four orders: 

(1) compelling an independent examination to determine Ms. Marsh’s capacity; 

(2) appointing Mr. Kent as temporary guardian of Ms. Marsh’s person; (3) appointing a 
9

local attorney, Robert McCarthy, as temporary guardian of Ms. Marsh’s property; and 

(4) appointing another local attorney, Catherine McQueen, as counsel for Ms. Marsh.

8

Mr. McCarthy then spoke with Mr. Farmer and suggested that Mr. Farmer had a 

conflict of interest in representing both Ms. Marsh and Ms. Nguyen. Mr. Farmer disagreed.

Mr. McCarthy also noted that Mr. Farmer was not authorized to practice law in Maryland. 

Mr. Farmer dismissed the concern as not a problem. 

D. Mr. Farmer’s Attempt to Obtain Local Counsel

Meanwhile, Mr. Farmer was searching for a Maryland lawyer to serve as local 

counsel. He consulted with Zhia Shepardson and Mary Lombardo, two attorneys at the 

Rismiller Law Group, LLC (“Rismiller”). Initially, Rismiller agreed to sponsor Mr. 

Farmer’s pro hac vice petition to represent Ms. Marsh and Rick in potential trust litigation. 

Rismiller sent a retainer agreement to Ms. Marsh and Rick, but it was never executed. 

Mr. Farmer also sought Rismiller’s assistance in connection with Ms. Marsh’s Trust 

and the alleged impropriety by Mr. Kent. Rismiller initially agreed, and on April 29, sent 

an Attorney Fee Agreement (the “Fee Agreement”) addressed to Ms. Nguyen.

9 Mr. Farmer

proposed several revisions and returned the Fee Agreement to Rismiller.

10

 

8 Mr. Kent’s petition suggested the appointments of himself and Mr. McCarthy as 

guardians and Ms. McQueen as counsel. 

9 The Fee Agreement indicated that the scope of the work was “Reviewing and 

advising pertaining to the guardianship litigation regarding Louise Marsh in Montgomery 

County[.]” Mr. Farmer was not mentioned in the Fee Agreement. 

10 Mr. Farmer additionally changed the address on the Fee Agreement to “Louise 

Williams Marsh c/o George L. Farmer,” added that Rismiller would appear as local counsel 
10

Ms. Shepardson and Mr. Farmer then communicated by email. Ms. Shepardson 

stated that “[i]f we need to loop Louise into being a client as well, then we can cross that 

bridge. We are simply trying to do what we need to do in order to begin review [of the 

documents].” Mr. Farmer said that he had no problem with Rismiller reviewing the 

documents but that he wanted clarification that they would appear in court, be local 

counsel, and sponsor his pro hac vice application. Ms. Shepardson responded: “Yes, we 

can still do that – we just need to review the documents to help determine exactly what it 

is we will be doing.” 

After they reviewed the documents, Rismiller informed Mr. Farmer that the firm 

would not undertake the representations because Ms. Marsh had a court-appointed attorney 

and because Ms. Nguyen lacked standing in the guardianship proceeding.

E. Enforcement of the April 20 Orders

Although one of the court’s April 20 orders required Ms. Marsh to be examined by

Dr. Carole Guinta for the purpose of determining her capacity, Ms. Nguyen on several 

occasions prevented Dr. Guinta from conducting the examination. This prompted Mr. Kent 

to file an emergency motion for an order requiring Ms. Nguyen to comply with the court 

order. 

Mr. Kent then consulted with Mr. McCarthy and rescheduled the examination. On 

May 8, with police escorts to ensure Ms. Nguyen’s compliance, Mr. Kent and Mr. 

McCarthy went to Ms. Marsh’s home to take her to the appointment. While at the home, 

for Ms. Marsh and sponsor Mr. Farmer’s pro hac vice motion, and changed the agreement 

to indicate that Rismiller would represent Ms. Marsh and Ms. Nguyen, and not Rick. 
11

Mr. McCarthy observed that Ms. Marsh looked “very childlike” and that Ms. Nguyen 

appeared to have moved her family into Ms. Marsh’s residence. He also found a 

prescription bottle of Ms. Marsh’s that contained several different medications as well as 

peanuts. Mr. Kent and Mr. McCarthy then took Ms. Marsh to her appointment with Dr. 

Guinta. Dr. Guinta found Ms. Marsh to be severely impaired and in need of a guardian of 

her person and property. 

On May 1, Ms. McQueen filed an emergency motion for a hearing on the court’s 

appointment of a temporary guardian of Ms. Marsh’s person and property because the 

appointments had been made without the hearing required under Maryland Rules 10-

205(b), 10-212, and 10-304. 

F. Mr. Farmer’s Motions

In response, on May 8, Mr. Farmer filed two motions: one on behalf of Ms. Marsh 

to dismiss Ms. McQueen’s emergency petition, vacate the April 20 orders, and award 

attorneys’ fees due to the bad faith filing of the petition (the “Motion to Dismiss”); and the 

second, a motion for admission pro hac vice as Ms. Marsh’s counsel. Mr. Farmer filed the 

pro hac vice motion on his own, without the sponsorship of a Maryland-licensed attorney. 

In the Motion to Dismiss, Mr. Farmer also claimed that Ms. McQueen’s appointment was 

unnecessary because he was already representing Ms. Marsh. Mr. Farmer further alleged

that Mr. Kent was engaged in significant misconduct that was harming Ms. Marsh. 

Mr. Farmer then sent Mr. McCarthy a letter accusing both him and Mr. Kent of 

misconduct, including kidnapping Ms. Marsh by taking her to her court-ordered medical 

appointment. Mr. Farmer also filed a letter with the court on Ms. Marsh’s behalf, 
12

requesting that the court hear the motions on an expedited basis, citing Ms. Marsh’s poor 

health, Mr. Kent’s alleged misconduct, and alleged collusion between Mr. Kent and Dr. 

Guinta. 

On May 18, Ms. Nguyen filed a motion that purported to be pro se, requesting that

the court dismiss the petition, vacate the court’s April 20 orders, and appoint her as the sole 

decision-maker pertaining to Ms. Marsh’s health care. When questioned as to who drafted 

this motion, Mr. Farmer again asserted his Fifth Amendment rights against selfincrimination. The hearing judge found that Mr. Farmer either drafted or assisted in 

drafting the motion, noting among other things, the similarity in style and format to the 

Motion to Dismiss. 

On May 20, Ms. McQueen filed a motion requesting that the court strike the Motion 

to Dismiss. 

A hearing on the pending motions was held on May 20. The court denied Mr. 

Farmer’s pro hac vice motion with prejudice and denied the Motion to Dismiss. The court 

found that Ms. Marsh was represented by Ms. McQueen, and, as a result, ruled that Mr. 

Farmer was prohibited from communicating with her. 

G. Mr. Farmer’s Request for Fees

After the hearing, Mr. Farmer presented Mr. McCarthy with an invoice in the 

amount of $158,589.18 for expenses and for “legal services” purportedly rendered on 

behalf of Ms. Marsh between March 2020 and May 2020. Mr. McCarthy refused to pay 

Mr. Farmer. 
13

H. The Federal Complaint

On June 12, Mr. Farmer filed a complaint in the United States District Court for the 

District of Maryland against Mr. Kent, Mr. Kent’s law partner, and their law firm, alleging 

tortious interference with contract, tortious interference with economic relationship, legal 

malpractice, and “willful and malicious acts,” all based on his relationship and agreement 

with Ms. Marsh. Mr. Kent and the other defendants moved to dismiss the complaint. 

On February 23, 2021, the court dismissed the complaint with prejudice. he court 

held that because Mr. Farmer was not licensed to practice law in Maryland, his retainer 

agreement with Ms. Marsh was invalid and against public policy. Additionally, the court 

found that Mr. Farmer’s claim that Mr. Kent was engaged in willful and malicious acts was 

“not grounded in any cognizable common law tort under Maryland law.”

II

STANDARD OF REVIEW

This Court has original jurisdiction over attorney discipline proceedings and 

conducts an independent review of the hearing judge’s findings of fact and conclusions of 

law. Attorney Grievance Comm’n v. Hamilton, 444 Md. 163, 178 (2015). We review the 

hearing judge’s conclusions of law without deference. Md. Rule 19-740(b)(1). 

Either party may file exceptions to the hearing judge’s findings of fact or 

conclusions of law. Md. Rule 19-728(b). We may treat any facts not challenged by 

exceptions as established. Md. Rule 19-740(b)(2)(A). “If exceptions are filed,” we 

determine “whether the findings of fact have been proved by the requisite standard of proof 

set out in Rule 19-727(c).” Md. Rule 19-740(b)(2)(B). 
14

Under Rule 19-727(c), the Commission must prove its allegations of misconduct by 

clear and convincing evidence. As we stated in Attorney Grievance Comm’n v. Johnson, 

472 Md. 491, 526 (2021) (citations omitted):

If a party excepts to the hearing judge’s findings, this Court “shall determine 

whether the findings of fact have been proved by the requisite standard of 

proof set out in Rule 19-727(c).” . . . “We may confine our review to the 

findings of fact challenged by the exceptions, mindful though, that the 

hearing judge is afforded due regard to assess the credibility of witnesses.” . 

. . This Court will not disturb the hearing judge’s findings “where ‘there is 

any competent evidence to support the’ finding of fact.” . . . Therefore, “[i]f 

the hearing judge’s factual findings are not clearly erroneous and the 

conclusions drawn from them are supported by the facts found, exceptions to 

conclusions of law will be overruled.” . . . 

In contrast, the respondent must prove any affirmative defenses and any mitigating 

or extenuating factors by a preponderance of the evidence. Md. Rule 19-727(c).

III

DISCUSSION

In one form or another, through general or specific allegations, Mr. Farmer excepted 

to virtually every adverse factual finding made by the hearing judge. Fortunately, the 

hearing judge meticulously supported each factual finding with citations to the relevant 

portions of the transcript and exhibits. We have independently reviewed the record and 

conclude that none of the hearing judge’s factual findings are clearly erroneous. To the 

extent that Mr. Farmer excepts to any of the factual findings not specifically discussed 
15

below, such exceptions are overruled.11 The Commission did not file any exceptions to the 

hearing judge’s factual findings. 

A. General Exceptions

Mr. Farmer excepts to the introduction section of the hearing judge’s findings, 

contending that she failed to consider his side of the story and that she admitted and credited 

hearsay. Mr. Farmer claims the hearing judge was biased against him, disregarded his 

arguments, defenses, and testimony, and rubber-stamped the Commission’s submissions. 

He also contends that the hearing judge’s decision lacked “normalcy, reasonableness, and 

compassion.” These exceptions lack merit and are summarily overruled. 

Mr. Farmer also criticizes Bar Counsel. He contends that Bar Counsel had unclean 

hands by pressing charges against him while ignoring the alleged misdeeds of Mr. Kent. 

Mr. Farmer also contends that Bar Counsel pursued this matter as retaliation for the ethics 

complaint he filed against Mr. Kent. Further, Mr. Farmer contends that he was denied due 

process because he was not allowed to elicit testimony from Bar Counsel about its

relationship to Mr. Kent and its motivation in investigating him. We summarily overrule 

these baseless objections as well.

11 Mr. Farmer’s exceptions, especially as to the factual findings, are disjointed, 

rambling, and repetitive. We have consolidated the exceptions, as appropriate.
16

B. Exceptions to the Hearing Judge’s Factual Findings 

1. Thoroughness of the Findings.

Mr. Farmer complains that the hearing judge’s factual findings are incomplete and 

omit key information.12 A judge is not required to specifically mention each piece of 

evidence in its findings, and the failure to do so does not indicate a failure to consider the 

evidence. Attorney Grievance Comm’n v. Chanthunya, 446 Md. 576, 599 (2016) (quoting 

Attorney Grievance Comm’n v. Vanderline, 364 Md. 376, 385 (2001)). Further, a judge is 

free to disregard any testimony she deems not credible. Id. We therefore overrule this 

exception.

2. Exceptions to the Finding that Mr. Farmer Represented Ms. Nguyen

Mr. Farmer excepts to the finding that he represented Ms. Nguyen. According to 

Mr. Farmer, “[t]he hearing judge fails to mention the most important aspect of [his]

representation of [Ms. Nguyen]: the scope of my representation.” Mr. Farmer contends 

that he was supposed to assist Ms. Nguyen “in her efforts to find out what Mr. Kent was 

up to, and to see if he had done anything improper with respect to her mother in law, Mrs. 

Marsh.” 

The record is replete with evidence that Mr. Farmer represented Ms. Nguyen. His 

retainer agreement with Ms. Marsh says that he represented Ms. Nguyen. The conflict of 

interest waiver he had Ms. Nguyen sign says that he had been representing Ms. Nguyen 

12 For example, Mr. Farmer contends that the hearing judge failed to mention Ms. 

Nguyen’s education, the motivation for Mr. Kent’s allegedly wrongful actions, including 

his motivation for filing the emergency petition, and that Mr. Farmer sent the March 5, 

2020 letter before he was retained. 
17

and would continue to do so. The complaint he filed in federal court said he represented 

Ms. Nguyen. We overrule Mr. Farmer’s exception.

3. Exception to the Finding that the Instructions were Drafted by Mr. Farmer 

Mr. Farmer excepts to the hearing judge’s finding that the instructions to Mr. Kent 

in his March 5 letter emanated from him. He contends that that he was only a conduit for 

Ms. Marsh and that he only typed up Ms. Marsh’s instructions because she was blind. We 

are unpersuaded. In 2019, Ms. Marsh was evaluated by a physician who found that she 

suffered from severe dementia and that her condition would decline. On May 8, 2020, Dr. 

Guinta examined her and concluded that she had a “Major Neurocognitive Disorder 

(Dementia) due to Alzheimer’s Disease.” The hearing judge’s finding that Mr. Farmer 

drafted the instructions was not clearly erroneous. We overrule this exception.

4. Exception to the Finding that Mr. Farmer Drafted the Third Amendment 

Mr. Farmer excepts to the hearing judge’s finding that he drafted the Third 

Amendment—the amendment that, among other things, named his New Jersey office 

suitemate as successor trustee. Mr. Farmer complains that the hearing judge based this 

finding solely on an adverse inference drawn from his assertion of his Fifth Amendment

privilege against self-incrimination, and contends that there is no evidence he drafted the 

amendment. This exception is without merit. 

First, because this is not a criminal matter, the hearing judge was entitled to draw 

an adverse inference from Mr. Farmer’s assertion of his Fifth Amendment right. See 

Robinson v. Robinson, 328 Md. 507, 515-16 (1992). Second, the hearing judge cited to 

substantial evidence to support her conclusion that Mr. Farmer drafted the Third 
18

Amendment. Specifically, Mr. Farmer began purportedly representing Ms. Marsh on 

March 6, and Mr. Farmer came into possession of the Third Amendment on April 7, the 

same day Ms. Marsh signed it. The co-trustee appointed in the Third Amendment, Mr. 

Hoffman, happens to share an office with Mr. Farmer in New Jersey. And Mr. Kent, who 

had represented the Marsh family for over 30 years, was not aware of this amendment until 

Mr. Farmer—not some other unknown lawyer—sent it to him. We note further that Mr. 

Farmer’s redacted invoice for April indicates that on April 6 and 7, he drafted a status letter 

and then prepared something13 that took him 4.5 hours. The inferences the hearing judge 

drew from such evidence are logical, sound, and well-reasoned. See Attorney Grievance 

Comm’n v. Ross, 428 Md. 50, 87 (2012); Attorney Grievance Comm’n v. Hekyong Pak, 

400 Md. 567, 608 (2007). Accordingly, we overrule this exception.

5. Exception to the Finding that Ms. Marsh was Incompetent 

Mr. Farmer excepts to the hearing judge’s finding that Ms. Marsh was incompetent, 

claiming that a determination of her competency on May 8 was irrelevant to her mental 

capacity two months prior, when she entered into the retainer agreement with him. The 

evidence before the hearing judge included two certifications, one dated before Ms. Marsh 

signed the retainer agreement and one dated after, signed by a physician and psychologist 

who each examined Ms. Marsh, both of which support the hearing judge’s finding. We 

overrule this exception.

13 Mr. Farmer redacted that little detail.
19

C. Exceptions to the Hearing Judge’s Conclusions of Law

From the foregoing factual findings, the hearing judge found by clear and 

convincing evidence that Mr. Farmer violated MARPC 1.4 (Communication), 1.5 (Fees), 

1.7 (Conflict of Interest—General Rule), 1.16(a)(1) (Declining or Terminating 

Representation), 3.1 (Meritorious Claims and Contentions), 5.5(a) (Unauthorized Practice 

of Law; Multi-Jurisdictional Practice of Law), and 8.4(a) (Misconduct). Mr. Farmer 

excepts to each conclusion. 

As noted above, we review all conclusions of law without deference. We conclude 

that the hearing judge’s conclusions are supported by clear and convincing evidence and 

therefore overrule Mr. Farmer’s exceptions. 

1. Mr. Farmer Violated Multiple Rules of Professional Conduct by Representing 

Clients With Conflicting Interests

Mr. Farmer violated three different rules of professional conduct, MARPC 1.4, 1.7, 

and 1.16(a)(1), when he represented both Ms. Nguyen and Ms. Marsh, two clients with 

conflicting interests.

MARPC 1.4 provides:

(a) An attorney shall:

(1) promptly inform the client of any decision or circumstance with 

respect to which the client’s informed consent, as defined in Rule 19-

301.0(g) (1.0), is required by these Rules;

(2) keep the client reasonably informed about the status of the matter;

(3) promptly comply with reasonable requests for information; and

(4) consult with the client about any relevant limitation on the 

attorney’s conduct when the attorney knows that the client expects 

assistance not permitted by the Maryland Attorneys’ Rules of 

Professional Conduct or other law.

(b) An attorney shall explain a matter to the extent reasonably necessary to 

permit the client to make informed decisions regarding the representation.
20

This Rule is violated when an attorney undertakes joint representation of clients but 

fails to explain a potential conflict of interest. Attorney Grievance Comm’n v. Olszewski, 

441 Md. 248, 267 (2015). 

MARPC 1.7 provides: 

(a) Except as provided in section (b) of this Rule, an attorney shall not 

represent a client if the representation involves a conflict of interest. A 

conflict of interest exists if: 

(1) the representation of one client will be directly adverse to another 

client; or 

(2) there is a significant risk that the representation of one or more 

clients will be materially limited by the attorney’s responsibilities to 

another client, a former client or a third person or by a personal 

interest of the attorney. 

(b) Notwithstanding the existence of a conflict of interest under section (a) 

of this Rule, an attorney may represent a client if: 

(1) the attorney reasonably believes that the attorney will be able to 

provide competent and diligent representation to each affected client; 

(2) the representation is not prohibited by law; 

(3) the representation does not involve the assertion of a claim by one 

client against another client represented by the attorney in the same 

litigation or other proceeding before a tribunal; and 

(4) each affected client gives informed consent, confirmed in writing.

Under MARPC 1.7, a conflict of interest exists in a dual representation if the parties 

have adverse competing interests. See Olszewski, 441 Md. at 257. 

MARPC 1.16(a)(1) provides: “Except as stated in section (c) of this Rule, an 

attorney shall not represent a client or, where representation has commenced, shall 

withdraw from the representation of a client if: the representation will result in violation of

the Maryland Attorneys’ Rules of Professional Conduct or other law[.]”

The hearing judge found conflicts of interest with respect to both the guardianship 

proceedings and the Trust. According to the hearing judge, at the inception of the dual 
21

representation, Mr. Farmer should have recognized “the impropriety of representing both 

Ms. Marsh, who needed funds from the Trust for her daily needs and medical care, and Ms. 

Nguyen, who wanted control of the Trust for her own benefit. Those two interests were 

diametrically opposed to each other.” 

The hearing judge concluded that Mr. Farmer violated MARPC 1.4(a)(1) and (b) 

“when he failed to adequately explain the conflict of interest presented by his dual 

representation of Ms. Marsh and Ms. Nguyen.” According to the hearing judge, at most, 

Mr. Farmer explained to Ms. Nguyen and Ms. Marsh that a potential conflict existed arising 

from the fact that Ms. Nguyen was Ms. Marsh’s daughter-in-law. He failed to explain the 

significant conflicts involved because he contended that no conflict existed. The hearing 

judge further concluded that Mr. Farmer’s “insistence on gaining pro hac vice admission 

to represent Ms. Marsh in the guardianship proceeding while he continued to represent Ms. 

Nguyen, indicates” either that he was not fully aware of the conflict of interest or chose to 

ignore it. 

The hearing judge concluded that Mr. Farmer violated MARPC 1.7(a)(1) by

representing directly adverse parties in the guardianship proceedings. Mr. Farmer drafted 

or helped draft a motion on behalf of Ms. Nguyen that sought to place Ms. Marsh under 

her care while simultaneously representing the alleged disabled person. According to the 

hearing judge, this motion demonstrated that Ms. Nguyen’s interests were directly adverse 

to those of Ms. Marsh, and therefore, that the conflict was not waivable. 

Similarly, the hearing judge found that Mr. Farmer’s representation of both Ms. 

Nguyen and Ms. Marsh with regard to the Trust violated MARPC 1.7(a)(2) because:
22

there was a “significant risk” from the outset that [his] representation of Ms. 

Marsh would be “materially limited” by his representation of Ms. Nguyen. 

Ms. Marsh needed funds from the Trust for her own support, particularly as 

her mental and physical health declined in her advanced age. Meanwhile, 

the evidence and testimony produced during the hearing demonstrates Ms. 

Nguyen, who was not a beneficiary of the Trust, sought to assert control over 

the Trust for her own benefit.

The hearing judge also found that as to the Trust, Ms. Marsh’s court-appointed attorney, 

Ms. McQueen, informed the court that Ms. Marsh desired a guardian of her person or 

property, contrary to Mr. Farmer’s contention. 

The hearing judge concluded that Mr. Farmer violated MARPC 1.16(a)(1) because 

“his representation of Ms. Marsh and Ms. Nguyen could not be performed without violating 

the MARPC or other law.” Specifically, his representation was tainted by an unwaivable 

conflict of interest and because he was not authorized to practice law in Maryland. 

Mr. Farmer excepts to these conclusions, reiterating his claim that there was no 

conflict, contending that the conclusions were based on erroneous findings of fact, and 

asserting that Ms. McQueen never stated that Ms. Marsh desired a guardian. He further 

denies that he drafted or assisted in drafting the motion on behalf of Ms. Nguyen, and 

contends that, even if he did, any conflict was resolved in the waivers that Ms. Marsh and 

Ms. Nguyen signed.14 

14 It is noteworthy that, although Mr. Farmer contends that there was no conflict in 

the dual representation of both Ms. Marsh and Ms. Nguyen, the record reflects that Mr. 

Farmer billed only Ms. Marsh for his services, and not Ms. Nguyen, even though the first 

charge on the invoice was for his travel to Maryland on March 4, before he had any contact 

with Ms. Marsh.
23

As noted above, the hearing judge’s factual findings were amply supported by the 

record, thus, the conclusions based on such findings are sustained. Mr. Farmer’s 

exceptions are overruled. See Attorney Grievance Comm’n v. Neverdon, 473 Md. 631, 686 

(2021) (finding that the attorney’s failure to withdraw, despite a conflict of interest, 

violated MARPC 1.7 and 1.16(a)(1)).

2. MARPC 1.5 (Fees)

MARPC 1.5 provides, in relevant part:

(a) An attorney shall not make an agreement for, charge, or collect an 

unreasonable fee or an unreasonable amount for expenses. The factors to be 

considered in determining the reasonableness of a fee include the following:

(1) the time and labor required, the novelty and difficulty of the 

questions involved, and the skill requisite to perform the legal service 

properly;

(2) the likelihood, if apparent to the client, that the acceptance of the 

particular employment will preclude other employment of the 

attorney;

(3) the fee customarily charged in the locality for similar legal 

services;

(4) the amount involved and the results obtained;

(5) the time limitations imposed by the client or by the circumstances;

(6) the nature and length of the professional relationship with the 

client;

(7) the experience, reputation, and ability of the attorney or attorneys 

performing the services; and

(8) whether the fee is fixed or contingent.

(b) The scope of the representation and the basis or rate of the fee and 

expenses for which the client will be responsible shall be communicated to 

the client, preferably in writing, before or within a reasonable time after 

commencing the representation, except when the attorney will charge a 

regularly represented client on the same basis or rate. Any changes in the 

basis or rate of the fee or expenses shall also be communicated to the client. 

The hearing judge concluded that Mr. Farmer violated this Rule by collecting the 

$8,500.00 retainer fee from Ms. Marsh and billing her $158,589.18 for legal services. 
24

As to the $8,500.00 retainer, the hearing judge noted that although that amount 

initially may have been reasonable, it became unreasonable because of Mr. Farmer’s 

“unauthorized practice of law and failure to perform any services of benefit on behalf of 

Ms. Marsh.” We agree. Regardless of whether an initial retainer was a reasonable amount, 

the fee can become unreasonable if the attorney does not perform the anticipated services. 

Attorney Grievance Comm’n v. Planta, 467 Md. 319, 350-51 (2020); Attorney Grievance 

Comm’n v. Barton, 442 Md. 91, 131 (2015); Attorney Grievance Comm’n v. Garrett, 427 

Md. 209, 224 (2012); Attorney Grievance Comm’n v. Patterson, 421 Md. 708, 732 (2011) 

(an attorney’s lack of diligence and competence may cause a fee to be unreasonable at the 

conclusion of representation). Here, because of the conflict of interest inherent in his 

representation and that he was not authorized to practice law in Maryland, Mr. Farmer 

could not lawfully perform the services for which he charged Ms. Marsh. As such, clear 

and convincing evidence supported the hearing judge’s conclusion that Mr. Farmer 

violated Rule 1.5 by collecting and retaining the $8,500 retainer. 

The hearing judge further concluded that the $158,589.18 charge was unreasonable 

because Mr. Farmer charged Ms. Marsh for services allegedly rendered while engaging in 

the unauthorized practice of law. According to the hearing judge, most of Mr. Farmer’s 

time was spent on phone calls, emails, texts, and other communications to redacted parties. 

Thus, Mr. Farmer “billed Ms. Marsh over $150,000.00 for the purposes of conducting 

baseless persecutions against her longtime attorney and bank, while seeking to assert 

control over her Trust. None of Respondent’s actions therefore represent any meaningful 

legal services taken for the benefit of Ms. Marsh.” 
25

The hearing judge noted that Mr. Farmer spent over 416 hours at a total cost of more 

than $160,000.00 without obtaining a single result for Ms. Marsh. As the hearing judge

observed:

During this time, [he] drafted a single estate planning document, prepared for 

a single hearing, in which Ms. Marsh already had court-appointed counsel, 

requested records from a single bank, and otherwise persecuted Mr. Kent. 

Respondent had no prior relationship with Ms. Marsh, and lacked any 

experience in Maryland guardianship or trust law. With respect to [Mr. 

Farmer’s] $400.00 hourly fee, while the AGC did not put forward a fee 

customarily charged in Montgomery County, the Court notes Mr. McCarthy, 

a guardianship attorney with twenty four years of experience in Maryland 

guardianship law, testified that he only charges $325.00 an hour.

Mr. Farmer excepts to this conclusion, arguing that the hearing judge was biased 

against him, that he could not have violated the rule on legal fees because he provided nonlegal services, that the litigation against Mr. Kent was justified, and that the fees would not 

have been considered unreasonable had he recovered money from Mr. Kent. We overrule 

these objections.

The hearing judge correctly concluded that Mr. Farmer violated this Rule by 

charging $158,589.18, representing 416.3 hours of “legal services” provided over a threemonth period, plus $569.18 in expenses for travel, copying, postage, and flash drives. For 

the period of April 18, 2020, through May 20, 2020 alone, Mr. Farmer billed Ms. Marsh 

$105,258.88 for 262.4 hours.15 Mr. Farmer testified that his time was spent pursuing Mr. 

Kent, attempting to obtain Ms. Marsh’s bank records, filing a complaint against Ms. 

15 During that time period, Mr. Farmer’s time sheets reflect multiple entries for the 

same date, including 19 separate entries for April 21, 2020, 12 separate entries for April 

22, 2020, and 15 separate entries for April 27, 2020. 
26

Marsh’s bank, filing an ethics complaint against Mr. Kent, and other miscellaneous 

activities. 

Mr. Farmer’s contention that he escapes application of Rule 1.5 on the theory that 

he provided non-legal services is frivolous. His invoice, which says “Legal Services 

Rendered,” sent under a cover letter on his “Attorney at Law” stationary, indicates 

otherwise. The rate he charged, which he defended as reasonable based on his experience 

as an attorney, indicates otherwise. His fee agreement with Ms. Marsh, which says that he 

would review Mr. Kent’s work, indicates otherwise. Clear and convincing evidence thus 

supports the conclusion that Mr. Farmer violated Rule 1.5. Accordingly, we overrule Mr. 

Farmer’s exceptions.

3. MARPC 3.1 (Meritorious Claims and Contentions)

MARPC 3.1 provides:

An attorney shall not bring or defend a proceeding, or assert or controvert an 

issue therein, unless there is a basis for doing so that is not frivolous, which 

includes, for example, a good faith argument for an extension, modification 

or reversal of existing law. An attorney may nevertheless so defend the 

proceeding as to require that every element of the moving party’s case be 

established.

This Rule “can be violated when an attorney utilizes a legal process ‘merely [as] a 

device to apply pressure to the other part[y]’ in ‘an effort to extract legal fees by any 

means.’” Attorney Grievance Comm’n v. Conwell, 462 Md. 437, 467 (2019) (internal 

quotation marks omitted). 

Here, the hearing judge concluded by clear and convincing evidence that Mr. 

Farmer violated this Rule when he filed the frivolous lawsuit in federal court against Mr. 
27

Kent and his firm, concluding that Mr. Farmer filed the lawsuit “to bully Mr. Kent into 

compliance in furtherance of [Mr. Farmer’s] agenda.” 

Mr. Farmer excepts to this conclusion, claiming that the violation was not 

established through clear and convincing evidence. He contends that the lawsuit was not 

frivolous, and once again maintains that his retainer was to provide non-legal services, and 

that the work he performed was not the practice of law. 

Contrary to these contentions, in his federal complaint, Mr. Farmer alleged that “he 

represented [Ms. Nguyen],” that he had a retainer agreement with Ms. Marsh “to represent 

her, and among other things, to conduct the investigation to which she previously had 

authorized defendant Kent to provide documentation,” and that Mr. Kent interfered with 

his “performance of his duties under the contract plaintiff had with Ms. Marsh.” The 

complaint further states that he “presented his invoice for the legal services he provided for 

Mrs. Marsh[.]” 

Moreover, in his federal complaint, Mr. Farmer alleged that Ms. Nguyen “retained 

[his] services,” that he “entered into a written retainer agreement with Mrs. Marsh whereby 

he received authorization from Mrs. Marsh to represent her[,]” that Mr. Kent acted 

wrongfully by “not inform[ing] his attorney that [Mr. Farmer] represented Mrs. Marsh, and 

thus should be served with a copy of the pleadings,” and that Mr. Kent interfered with his 

contract to represent Ms. Marsh. Mr. Farmer’s exceptions are baseless, and, as such, are 

overruled. 
28

4. MARPC 5.5 (Unauthorized Practice of Law; Multi-Jurisdictional Practice of 

Law)

MARPC 5.5(a) provides:

An attorney shall not practice law in a jurisdiction in violation of the 

regulation of the legal profession in that jurisdiction, or assist another in 

doing so.

According to the hearing judge, because Mr. Farmer conceded that he was never 

admitted to practice law in Maryland, the question before her was whether Mr. Farmer did, 

in fact, practice law in Maryland. She concluded that clear and convincing evidence 

established that he did. As stated by the hearing judge:

Under Md. Code Ann., Bus. Occ. & Prof. 10-101(h)(1), practicing law 

includes (i) giving legal advice; (ii) representing another person before a unit 

of the State government or of a political subdivision; or (iii) performing any 

other service that the Court of Appeals defines as practicing law. To 

determine whether an individual has engaged in the practice of law, the focus 

of the inquiry is on “whether the activity in question required legal 

knowledge and skill in order to apply legal principles and precedent.” . . .

The Court readily concludes [Mr. Farmer] engaged in the practice of law 

almost immediately upon setting foot in the State of Maryland. For instance, 

the March 5, 2020 letter from Respondent to Mr. Kent indicates Respondent 

advised Ms. Marsh on legal matters including her power of attorney, the 

Trust, and Ms. Marsh’s will, and proceeded to take legal action on behalf of 

Ms. Marsh by sending a letter to Mr. Kent identifying Respondent as an 

attorney at law. This legal action Respondent purportedly took on behalf of 

Ms. Marsh was in accordance with the “Legal Representation Retainer 

Agreement” Ms. Marsh signed on March 6, 2020. Respondent proceeded to 

request records from Ms. Marsh’s bank while identifying himself as her 

attorney.

Respondent further engaged in the practice of law on April 7, 2020 when he 

drafted the Third Amendment to the Trust. Then, Respondent filed multiple 

motions in the Montgomery County Circuit Court on behalf of Ms. Marsh 

and Ms. Nguyen. Respondent finally concluded his work in Maryland by 

submitting an invoice to Ms. Marsh for “legal services rendered.” 

Throughout the foregoing events, Respondent was engaged in the practice of 
29

law in Maryland. Respondent provided legal advice, drafted Trust 

documents, and even filed several motions in ongoing litigation. 

Respondent’s attempt to argue the foregoing does not constitute the practice 

of law is simply incredible. 

(Footnotes omitted).

Mr. Farmer excepts to this conclusion, claiming that the hearing judge did not state 

how any of the incidents referenced constituted the practice of law and contending that 

none do. He further argues that his conduct did not violate the Rule because he anticipated 

being admitted pro hac vice and that he should not be faulted just because the software he

uses automatically says, “Legal Services Rendered.” 

To determine whether an individual engaged in the unauthorized practice of law,

we focus “on whether the activity in question required legal knowledge and skill in order 

to apply legal principles and precedent.” Attorney Grievance Comm’n v. Tanko, 427 Md. 

15, 45 (2012) (internal quotation marks omitted). Examples of activities we have held 

constitute the practice of law are preparing or interpreting legal documents and “the giving 

of legal advice, or the application of legal principles to problems of any complexity[.]” 

Attorney Grievance Comm’n v. Lang, 461 Md. 1, 33 (2018) (quoting Attorney Grievance 

Comm’n v. Hallmon, 343 Md. 390, 397 (1996)).

We need not scrutinize every service listed on his invoices to conclude that, at a 

minimum, Mr. Farmer engaged in the unauthorized practice of law when he filed the 

motions in the Circuit Court for Montgomery County. Mr. Farmer responds to this charge 

by insisting that under Rule 19-217(d), he was permitted to move for admission pro hac 
30

vice without a sponsoring member of the Maryland bar. Mr. Farmer is simply wrong. Rule 

19-217(d) provides:

An attorney specially admitted pursuant to this Rule may act only as cocounsel for a party represented by an attorney of record in the action who is 

admitted to practice in this State. The specially admitted attorney may 

participate in the court or administrative proceedings only when 

accompanied by the Maryland attorney, unless the latter’s presence is waived 

by the judge or administrative hearing officer presiding over the action. An 

attorney specially admitted is subject to the Maryland Attorneys’ Rules of 

Professional Conduct during the pendency of the action or arbitration.

The plain language of this Rule states that the judge or administrative hearing judge 

may waive only the requirement that the Maryland attorney be present during proceedings; 

nowhere does this Rule provide that an out-of-state attorney may sponsor himself for 

admission. 

That Mr. Farmer was hoping or anticipating that he would be admitted pro hac vice 

without obtaining a sponsor does not absolve him of this violation.

16

 Accordingly, on this 

16 Section 10-215 of the Business Occupations and Professions Article of the 

Annotated Code of Maryland (2014, 2021 Repl. Vol.) provides:

(a) Subject to subsections (b) and (c) of this section, on a motion filed as 

required by rules adopted by the Court of Appeals, a court may grant special 

admission to practice law in a particular case to an individual who is:

(1) admitted to the bar of another state; and

(2) employed by a party in the case before:

(i) a court or other unit of the State government; or

(ii) a unit of a political subdivision of the State.

(b) A special admission to practice law may be granted only:

(1) by the court hearing the case for which an individual requests the 

special admission; or

(2) if the case is before a unit other than a court, by:

(i) the circuit court for the county where the unit has its 

principal office; or
31

basis alone, we overrule his exception to the hearing judge’s conclusion that he violated 

Rule 5.5. 

5. MARPC 8.4 (Misconduct)

MARPC 8.4 states:

It is professional misconduct for an attorney to:

(a) violate or attempt to violate the Maryland Attorneys’ Rules of 

Professional Conduct, knowingly assist or induce another to do so, or do so 

through the acts of another;

(b) commit a criminal act that reflects adversely on the attorney’s honesty, 

trustworthiness or fitness as an attorney in other respects;

(c) engage in conduct involving dishonesty, fraud, deceit or 

misrepresentation[.]

An attorney violates Rule 8.4(a) when “he or she violates any other Rule under the 

MARPC.” Attorney Grievance Comm’n v. Hoerauf, 469 Md. 179, 214 (2020) (citation

omitted). The hearing judge found that clear and convincing evidence supported a finding 

that Mr. Farmer violated Rule 8.4(a) because he violated six other MARPC rules. 

According to the hearing judge, “[t]he number and significance of [Mr. Farmer’s] 

violations of the preceding six rules necessarily means he engaged in misconduct and 

therefore violated this provision as well.” 

Mr. Farmer excepts to this conclusion, reiterating his unsupported claim that Mr. 

Kent was the attorney who violated the rules and not him. Because we have concluded

(ii) any circuit court to which the case may be appealed.

(c) An individual may practice law under this section only in connection with 

the case for which the special admission is granted.

(d) An individual who practices law under this section is subject to 

disciplinary proceedings as the Maryland Rules provide.
32

that Mr. Farmer violated multiple rules of conduct, we conclude that he also violated Rule

8.4(a) and overrule his exception. 

D. Petitioner’s Exception

The hearing judge made no finding as to whether Mr. Farmer violated any 

subsection of Rule 8.4 other than subsection (a). In a footnote to its Recommendation for 

Sanction, the Commission states:

The hearing judge did not articulate which section(s) of Rule 8.4 were found 

to have been violated. The Rule 8.4(b) and (c) charges were based entirely 

on the unauthorized practice of law. See Petitioner’s Proposed Findings of 

Fact and Conclusions of Law at 35 citing Att’y Griev. Comm’n v. Shryock, 

408 Md. 105, 124 (2009) (concluding that attorney who engaged in the 

unauthorized practice of law committed a criminal act that constitutes a 

violation of Rule 8.4(b) and (c)). To the extent this Court finds that the 

hearing judge concluded the Respondent did not violate Rule 8.4(b) and (c), 

the Petitioner excepts. 

It is unclear whether the hearing judge failed to make a finding as to whether Mr. Farmer 

violated Rules 8.4(b) and (c) or whether the hearing judge concluded that Mr. Farmer did 

not violate these subsections. We note, however, that the hearing judge viewed as a 

mitigating factor the fact that Mr. Farmer at least attempted to be admitted pro hac vice and 

advised his clients that he was not authorized to practice in Maryland. Nevertheless, 

because resolution of the matter would not affect the sanction in this case, we decline to 

address the Commission’s exception.

E. Remedial Action Taken by Mr. Farmer

The hearing judge found no evidence that Mr. Farmer took any remedial action to 

cure his misconduct: he did not return the $8,500 retainer fee, recant his accusations against 

Mr. Kent and Sandy Spring Bank, or help clarify for Ms. Marsh that she was represented 
33

by Ms. McQueen and not him. The hearing judge found that Mr. Farmer instead “doubled 

down on his ethical violations by filing an entirely frivolous lawsuit against Mr. Kent for 

the purpose of regaining access to Ms. Marsh.” 

Mr. Farmer excepts to this finding, reiterating his claims against Mr. Kent and his 

accusations of bias by the hearing judge. He further argues that “[t]here can be no dispute

that [he] expended a considerable amount of time trying to assist Mrs. Marsh” and that he 

represented Ms. Marsh. 

These exceptions are without merit. The hearing judge’s findings were supported 

by the record. We overrule these exceptions.

F. Mitigating Factors

We recognize the following mitigating factors in considering the appropriate 

sanction: 

(1) the absence of prior attorney discipline; (2) the absence of a dishonest or 

selfish motive; (3) personal or emotional problems; (4) timely good faith 

efforts to make restitution or to rectify the misconduct’s consequences; 

(5) full and free disclosure to [the Commission] or a cooperative attitude 

toward the attorney discipline proceeding; (6) inexperience in the practice of 

law; (7) character or reputation; (8) a physical disability; (9) a mental 

disability or chemical dependency, including alcoholism or drug abuse, 

where: (a) there is medical evidence that the lawyer is affected by a chemical 

dependency or mental disability; (b) the chemical dependency or mental 

disability caused the misconduct; (c) the lawyer’s recovery from the 

chemical dependency or mental disability is demonstrated by a meaningful 

and sustained period of successful rehabilitation; and (d) the recovery 

arrested the misconduct, and the misconduct’s recurrence is unlikely; (10) 

delay in the attorney discipline proceeding; (11) the imposition of other 

penalties or sanctions; (12) remorse; (13) remoteness of prior violations of 

the M[A]RPC; and (14) unlikelihood of repetition of the misconduct. 
34

Attorney Grievance Comm’n v. Allenbaugh, 450 Md. 250, 277-78 (2016) (quoting Attorney 

Grievance Comm’n v. Shuler, 443 Md. 494, 507 (2015)). 

The hearing judge found one potential mitigating factor: that Mr. Farmer made a 

good faith effort to be admitted pro hac vice and informed his clients that he was not 

licensed to practice law in Maryland. However, the hearing judge tempered her finding by

stating that these actions were “somewhat tainted . . . by the fact that [Mr. Farmer] failed 

to withdraw his representation after failing to gain admission, sought to bill Ms. Marsh for 

his unauthorized practice of law, and agreed to represent both Ms. Marsh and Ms. Nguyen 

despite the clear conflicts of interest.” 

In his exceptions, Mr. Farmer contends that there was no process to withdraw as he 

had never been admitted and that he ceased representing Ms. Marsh and Ms. Nguyen once 

his petition for admission pro hac vice was denied. We overrule this meritless exception. 

G. Exceptions to the Hearing Judge’s Aggravating Factors

The Court considers the following aggravating factors:

(1) prior attorney discipline; (2) a dishonest or selfish motive; (3) a pattern 

of misconduct; (4) multiple violations of the [MARPC]; (5) bad faith 

obstruction of the attorney discipline proceeding by intentionally failing to 

comply with the Maryland Rules or orders of this Court or the hearing judge; 

(6) submission of false evidence, false statements, or other deceptive 

practices during the attorney discipline proceeding; (7) a refusal to 

acknowledge the misconduct’s wrongful nature; (8) the victim’s 

vulnerability; (9) substantial experience in the practice of law; 

(10) indifference to making restitution or rectifying the misconduct’s 

consequences; (11) illegal conduct, including that involving the use of 

controlled substances; and (12) likelihood of repetition of the misconduct. 

Attorney Grievance Comm’n v. Sperling, 459 Md. 194, 275 (2018). 
35

The hearing judge found five aggravating factors: (1) prior attorney discipline; (2) a 

pattern of misconduct; (3) refusal to acknowledge the misconduct’s wrongful nature; 

(4) the victim’s vulnerability; and (5) substantial experience in the practice of law. 

In his exceptions, Mr. Farmer argues that his prior disciplinary actions were not 

related to this case, that one disciplinary matter in two months cannot constitute a pattern, 

and that he did not practice law in Maryland. We overrule those exceptions. That there 

have been prior disciplinary actions is an aggravating factor; there is no requirement that 

the prior disciplinary actions relate to the current charge. 

Moreover, the hearing judge’s factual findings reveal a pattern of misconduct. A

pattern of misconduct can be demonstrated “by multiple violations over time, or a series of 

acts with one goal.” Sperling, 459 Md. at 276. In Attorney Grievance Comm’n v. Coppola, 

419 Md. 370, 406 (2011), we noted that an attorney’s actions formed a pattern of 

misconduct, notwithstanding the fact that he engaged in a series of acts over only a number 

of days. 

Here, Mr. Farmer engaged in a series of wrongful acts over a period of a few months. 

Those acts included representing Ms. Nguyen and Ms. Marsh despite a clear conflict of 

interest, making frivolous accusations against Mr. Kent and Sandy Spring Bank, retaining 

the $8,500 retainer to which he was not entitled, and billing Ms. Marsh over $150,000 for 

services allegedly rendered while engaging in the unauthorized practice of law. A pattern 

of misconduct was established by clear and convincing evidence. As such, we overrule 

Mr. Farmer’s exceptions to the hearing judge’s aggravating factors.
36

H. Mr. Farmer’s Defenses

Mr. Farmer raises several defenses, each of which were addressed by the hearing 

judge. We will take each in turn.

Mr. Farmer argues that this Court lacks subject matter jurisdiction and personal 

jurisdiction. Relatedly, he claims that this action was initiated in the wrong venue. These 

defenses are without merit. This Court has “‘original and complete’ jurisdiction over 

attorney discipline proceedings arising out of conduct alleged to have occurred anywhere 

in Maryland.” Attorney Grievance Comm’n v. Sucklal, 418 Md. 1, 5 (2011). This Court’s 

jurisdiction is grounded in Article IV, Section 18 of the Maryland Constitution,17 Section 

17 Section 18 of Article IV of the Maryland Constitution provides:

(a) The Supreme Court of Maryland from time to time shall adopt rules and 

regulations concerning the practice and procedure in and the administration 

of the appellate courts and in the other courts of this State, which shall have 

the force of law until rescinded, changed or modified by the Supreme Court 

of Maryland or otherwise by law. The power of courts other than the Supreme 

Court of Maryland to make rules of practice and procedure, or administrative 

rules, shall be subject to the rules and regulations adopted by the Supreme 

Court of Maryland or otherwise by law.

(b) (1) The Chief Justice of the Supreme Court of Maryland shall be the 

administrative head of the Judicial system of the State. The Chief Justice of 

the Supreme Court of Maryland shall from time to time require, from each 

of the judges of the Circuit Courts, of the District Court and of any 

intermediate courts of appeal, reports as to the judicial work and business of 

each of the judges and their respective courts.

 (2) Subject to paragraphs (3) and (4) of this subsection, the Chief 

Justice of the Supreme Court of Maryland may, in case of a vacancy, or of 

the illness, disqualification or other absence of a justice or judge or for the 

purpose of relieving an accumulation of business in any court assign any 
37

justice or judge except a judge of the Orphans’ Court to sit temporarily in 

any court except an Orphans’ Court.

 (3) A retired judge of the Circuit Court for Montgomery County that 

sits as the Orphans’ Court for Montgomery County may be assigned by the 

Chief Justice of the Supreme Court of Maryland, upon approval of a majority 

of the Supreme Court of Maryland, to do an act that a judge of the Orphans’

Court for Montgomery County is authorized to perform.

(4) A retired judge of the Circuit Court for Harford County that sits as 

the Orphans’ Court for Harford County may be assigned by the Chief Justice 

of the Supreme Court of Maryland, upon approval of a majority of the 

Supreme Court of Maryland, to do an act that a judge of the Orphans’ Court 

for Harford County is authorized to perform.

(5) Any justice or judge assigned by the Chief Justice of the Supreme 

Court of Maryland pursuant to this section has all the power and authority 

pertaining to a justice or judge of the court to which the justice or judge is so 

assigned; and the justice’s or judge’s power and authority shall continue with

respect to all cases (including any motion, or other matters incidental thereto) 

which may come before the justice or judge by virtue of such assignment 

until the justice’s or judge’s action thereon shall be completed. In the absence 

of the Chief Justice of the Supreme Court of Maryland, the provisions of this 

section shall be applicable to the senior justice present in the Supreme Court 

of Maryland. The powers of the Chief Justice set forth in this section shall be 

subject to any rule or regulation adopted by the Supreme Court of Maryland.
38

1-201(a) of the Courts and Judicial Proceedings Article of the Maryland Annotated Code 

(“CJP”),

18 and Maryland Rule 19-308.5.19

Mr. Farmer also raises the defense of unclean hands. He alleges that the 

Commission: (1) failed to bring charges against others whom he claims had conflicts of 

interests similar to those alleged against him; (2) failed to tell him which rules he allegedly 

violated; (3) “misrepresented” legal standards in various filings; and (4) pursued this matter 

as retaliation for the complaint he filed against Mr. Kent. The hearing judge rejected all of 

18 CJP § 1-201(a) provides:

The power of the [Supreme Court of Maryland] to make rules and regulations 

to govern the practice and procedure and judicial administration in that court 

and in the other courts of the State shall be liberally construed. Without 

intending to limit the comprehensive application of the term “practice and 

procedure,” the term includes the forms of process; writs; pleadings; 

motions; parties; depositions; discovery; trials; judgments; new trials; 

provisional and final remedies; appeals; unification of practice and procedure 

in actions at law and suits in equity, so as to secure one form of civil action 

and procedure for both; and regulation of the form and method of taking and 

the admissibility of evidence in all cases, including criminal cases.

19 Rule 19-308.5 provides:

(1) An attorney admitted by the Supreme Court to practice in this State is 

subject to the disciplinary authority of this State, regardless of where the 

attorney’s conduct occurs.

(2) An attorney not admitted to practice in this State is also subject to the 

disciplinary authority of this State if the attorney:

(A) provides or offers to provide any legal services in this State,

(B) holds himself or herself out as practicing law in this State, or

(C) has an obligation to supervise or control another attorney 

practicing law in this State whose conduct constitutes a violation of 

these Rules.
39

these defenses, and having independently reviewed the record, we too find no merit to 

them. 

Finally, Mr. Farmer alleges that he was deprived of due process when the hearing 

judge quashed his subpoena for a deposition of Bar Counsel. He sought the deposition of 

Bar Counsel to question her about, among other things, her relationship with Mr. Kent, her 

staff’s relationship with Mr. Kent, whether Mr. Farmer irritated Bar Counsel by filing an 

ethics complaint against Mr. Kent and challenging her decision to dismiss the complaint 

against Mr. Kent, and whether Bar Counsel has an “inherent bias against out of state 

attorneys.” The hearing judge quashed the subpoena to protect Bar Counsel from 

“‘annoyance, embarrassment, oppression, or undue burden or cost’ as any relevant 

testimony Bar Counsel could conceivably offer [was] privileged under the work-product 

doctrine.” The hearing judge was well within her discretion to do so. 

SANCTION

Having overruled Mr. Farmer’s exceptions and adopted the hearing judge’s factual 

findings and conclusions of law, it falls upon us to determine the appropriate sanction. In 

doing so, we are mindful that the purpose of sanctioning an attorney is to protect the public 

from those unfit to practice law, not to punish the attorney. Attorney Grievance Comm’n 

v. Karambelas, 473 Md. 134, 176-77 (2021). We consider a variety of factors, including

the rules that were violated, the mental state of the attorney, the injuries, if any, caused by

the attorney’s misconduct, and the relevant aggravating and mitigating factors. 

Allenbaugh, 450 Md. at 277. 
40

The Commission, relying primarily on Attorney Grievance Commission v. Lang, 

461 Md. 1 (2018), urges us to indefinitely suspend Mr. Farmer. In that case, we indefinitely 

suspended an out-of-state attorney who engaged in the unauthorized practice of law in two 

separate client matters, including negotiating a settlement in one matter and failing to 

timely move for pro hac vice admission or withdraw in the second. Id. at 15, 35. The 

attorney repeatedly represented himself as a Maryland attorney, made misrepresentations 

to Bar Counsel, and failed to disclose Bar Counsel’s investigation when applying to the 

Maryland bar. Id. at 68. 

Although Mr. Farmer insists that he committed no violations and therefore should 

not be sanctioned, he suggests that if this Court is inclined to sanction him, he should 

receive no more than a reprimand. He argues that indefinite suspensions are used in cases 

involving unauthorized practice of law for repeat offenders who had previously been 

suspended, unlawfully held themselves out as Maryland attorneys, made 

misrepresentations to clients, improperly used funds in trust accounts, or engaged in bad 

faith. He argues that none of those circumstances apply to him. With a touch of sarcasm, 

he claims that his “intentional and willful” conduct consisted only of properly moving for 

admission pro hac vice and immediately ceasing any work for Ms. Marsh once his motion 

was denied. And, he adds, “we would not be here if the Guardianship Court granted my 

pro hac vice application. It did not grant it through no fault of mine.”

Mr. Farmer clearly does not grasp the nature and extent of his misconduct. Although 

he represented a vulnerable, elderly widow at the same time he was representing the 

widow’s caretaker who was attempting to seize control over the widow’s estate, he still 
41

maintains there was no conflict of interest. Mr. Farmer still insists that he properly moved 

for admission pro hac vice in the guardianship case, even though Rule 19-217 plainly 

requires a sponsoring Maryland-licensed attorney to file the motion on his behalf. Mr. 

Farmer still insists he was not acting as a lawyer in representing Ms. Marsh, even though 

he filed papers on her behalf in a Maryland court, drafted estate planning documents, issued 

demands to her long-standing counsel and bank, had her sign a retainer agreement on his 

law firm letterhead, and issued invoices for “Legal Services Rendered.” 

When others failed to bend to his will, Mr. Farmer lashed out, sparing nobody. He 

filed an ethics complaint and federal lawsuit against Mr. Kent. He filed a regulatory 

complaint against Sandy Spring Bank. He accused Bar Counsel of waging a personal 

vendetta against him. He accused the hearing judge of bias, pointing to no evidence other 

than the fact that she credited the evidence against him. And at oral argument before this 

Court, he continued to insist that Mr. Kent had misappropriated funds as trustee, but could 

not point to a single shred of evidence supporting his allegations.20 All of this reinforces 

the hearing judge’s finding, as an aggravating factor, that Mr. Farmer refused to accept the 

wrongful nature of his conduct.

As noted above, the purpose of a sanction is to protect the public, not to punish the 

attorney. Pursuant to Maryland Rule 19-701(w), an indefinite suspension for an attorney 

20 According to Mr. Farmer, Rick’s hospital-bed statement that the Trust had about

five million dollars, combined with a brokerage statement indicating a balance of 

approximately four million dollars, supports the allegation that Mr. Kent misappropriated 

trust funds. Those two vague and unspecific data points, however, do not even remotely 

indicate wrongdoing. 
42

not admitted to practice law in Maryland “means the . . . indefinite exclusion from the 

admission to or the exercise of any privilege to practice law in this State.” Having 

considered the facts and circumstances and having applied the governing principles of law, 

we conclude that an indefinite suspension is the appropriate sanction for Mr. Farmer’s 

misconduct. See Attorney Grievance Comm’n v. Maiden, 480 Md. 1, 23-24 (2022) 

(indefinitely suspending attorney for, inter alia, creating an impermissible conflict of 

interest between herself and her client); Olszewski, 441 Md. at 274-75 (sanctioning attorney 

with indefinite suspension for, inter alia, representing client in lawsuit against another 

client); Attorney Grievance Comm’n v. Brisbon, 422 Md. 625, 644, 646 (2011) (sanctioning 

attorney with indefinite suspension for, inter alia, the unauthorized practice of law);

Attorney Grievance Comm’n v. Brown, 353 Md. 271, 296 (1999) (indefinitely suspending 

attorney for wrongful actions, including filing frivolous lawsuit).

IT IS SO ORDERED; RESPONDENT 

SHALL PAY ALL COSTS AS TAXED BY 

THE CLERK OF THIS COURT, 

INCLUDING COSTS OF ALL 

TRANSCRIPTS, PURSUANT TO 

MARYLAND RULE 19-709(d), FOR 

WHICH SUM JUDGMENT IS ENTERED 

IN FAVOR OF THE ATTORNEY 

GRIEVANCE COMMISSION AGAINST 

GEORGE L. FARMER.