[Until this opinion appears in the Ohio Official Reports advance sheets, it may be cited as Ohio 

State Bar Assn. v. Naumov, Slip Opinion No. 2019-Ohio-4381.] 

NOTICE 

This slip opinion is subject to formal revision before it is published in an 

advance sheet of the Ohio Official Reports. Readers are requested to 

promptly notify the Reporter of Decisions, Supreme Court of Ohio, 65 

South Front Street, Columbus, Ohio 43215, of any typographical or other 

formal errors in the opinion, in order that corrections may be made before 

the opinion is published. 

SLIP OPINION NO. 2019-OHIO-4381

OHIO STATE BAR ASSOCIATION v. NAUMOV.

[Until this opinion appears in the Ohio Official Reports advance sheets, it 

may be cited as Ohio State Bar Assn. v. Naumov, Slip Opinion No. 

2019-Ohio-4381.] 

Unauthorized practice of law—Bringing eviction actions on behalf of limitedliability companies—Amended proposed consent decree approved and 

permanent injunction issued. 

(No. 2018-0870—Submitted July 9, 2019—Decided October 29, 2019.) 

ON CERTIFIED REPORT by the Board on the Unauthorized Practice of Law, No. 

UPL 17-01. 

_______________________ 

Per Curiam.

{¶ 1} In a January 2017 complaint, relator, Ohio State Bar Association 

(“OSBA”), charged respondent, Dusko Naumov, with engaging in the unauthorized 

practice of law by bringing eviction actions on behalf of limited-liability companies 

even though Naumov has never been licensed to practice law in Ohio. On June 20, 
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2

2018, the Board on the Unauthorized Practice of Law recommended that we 

approve a proposed consent decree pursuant to Gov.Bar R. VII(5b). We rejected 

the proposal and remanded the matter for the parties to include an additional 

requirement in the proposed consent decree. Ohio State Bar Assn. v. Naumov, 153 

Ohio St.3d 1446, 2018-Ohio-2928, 103 N.E.3d 826. 

{¶ 2} On June 18, 2019, the board filed an amended report recommending 

approval of an amended proposed consent decree that incorporated the requirement 

we had instructed the parties to include. We accept the board’s recommendation 

and approve the following amended proposed consent decree that was submitted 

by the parties: 

I. Agreed Facts 

1. OSBA is a Bar Association whose members include 

attorneys-at-law admitted to the practice of law in Ohio and who 

practice throughout the State of Ohio. OSBA, through its 

Unauthorized Practice of Law Committee, is authorized by Gov.Bar 

R. VII to file a Complaint with the Board regarding the unauthorized 

practice of law. 

2. Respondent is an individual residing and transacting 

business in the State of Ohio. At all relevant times hereto, 

Respondent has been engaged in business as a landlord of residential 

real estate in and around Columbus, Ohio. 

3. Respondent is not, nor has he ever been, an attorney 

admitted to practice, granted active status, or certified to practice 

law in the State of Ohio pursuant to Rules I, II, III, IV, VI, IX, or XI 

of the Rules of the Government of the Bar of Ohio. 

4. At all relevant times hereto, Respondent drafted, 

signed, and litigated in a representational capacity civil actions for 
January Term, 2019 

3

eviction and related claims for monetary damages against tenants 

and/or former tenants residing in property owned by third-parties. 

5. As shown in Exhibit A attached to Relator’s 

Complaint, from January 1, 2014, to the present, Respondent signed 

and filed 50 civil complaints, each of which constitutes a separate 

occurrence of the unauthorized practice of law. 

6. Upon learning of the alleged unauthorized practice 

of law by Respondent, OSBA sent him a letter notifying him of the 

allegation. Respondent has stopped engaging in the unauthorized 

practice of law after October 2015. 

II. Applicable law 

7. R.C. 4705.01 provides: “No person shall be 

permitted to practice as an attorney and counselor at law, or to 

commence, conduct[,] or defend any action or proceeding in which 

the person is not a party concerned * * * unless the person has been 

admitted to the bar by order of the supreme court in compliance with 

its prescribed and published rules.” 

8. The unauthorized practice of law is the rendering of 

legal services for another by any person not admitted to practice law 

in Ohio. Gov.Bar R. VII(2)(A). 

9. Non-attorneys cannot file complaints for forcible 

entry and detainer and recovery of unpaid rent or other money 

damages on behalf of a property owner. Cleveland Bar Ass’n v. 

Picklo, 96 Ohio St.3d 195, 2002-Ohio-3995, 772 N.E.2d 1187. 

III. Joint Recommendation 

10. OSBA and Respondent[] hereby agree that the 

conduct described in paragraphs four and five herein—specifically, 

drafting and signing complaints for forcible entry and detainer and 
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money damages on behalf of a property owner and representing that 

property owner in related legal proceedings—constitutes the 

unauthorized practice of law. 

11. Respondent Dusko Naumov has ceased the conduct 

described in paragraphs four and five herein and he shall not engage 

in such conduct in the future [and] is hereby permanently enjoined 

from engaging in such conduct in the future and from otherwise 

engaging in the unauthorized practice of law in the State of Ohio. 

12. Further, Respondent Dusko Naumov shall have an 

attorney seek to vacate any outstanding money judgments and 

dismiss those cases within 60 days of the final order in this case. 

13. The parties jointly recommend that no civil penalty 

be imposed against Respondent. The factors of Gov.Bar R. 

VII(8)(B) apply as follows: 

(1) The degree of cooperation provided by the respondent 

in the investigation: Respondent has cooperated fully in both the 

pre-filing and post-filing investigation of this matter. Respondent 

promptly ceased all conduct that allegedly constituted the 

unauthorized practice of law upon receiving notice from OSBA in 

2015. 

(2) The number of occasions that unauthorized practice of 

law was committed: from January 1, 2014, through the present, 

Respondent committed at least 50 violations. 

(3) The flagrancy of the violation: the violations were 

unknowing or unwitting, and are far from the most severe, 

deliberate, ill-willed, or damaging conduct OSBA and the Board 

have seen. It is understood that Respondent owns and manages the 

limited liability companies that were the deeded owners of the real 
January Term, 2019 

5

properties that were the subjects of the eviction actions at issue in 

this case. 

(4) Harm to third parties arising from the offense: there was 

no known harm to the limited liability companies which owned the 

real estate in question. Respondent owns and manages those 

companies. Most of the defendant-tenants in those cases were 

evicted. However, several of the claims in those cases were 

dismissed for failure to prosecute, upon agreement of the parties, or 

by the Respondent. Respondent has not collected on the money 

judgments obtained in those cases; nor will Respondent take further 

action to collect on any such judgments. 

(5) Any other relevant factors: none. 

The parties accordingly agree that a civil penalty should not 

be imposed and, because no costs have been incurred by either party, 

costs should not be assessed on either party. 

(Boldface, ellipsis, and italics sic.) 

So ordered. 

O’CONNOR, C.J., and KENNEDY, FRENCH, FISCHER, DEWINE, DONNELLY, 

and STEWART, JJ., concur. 

_________________ 

Kaufman & Florence and William Robert Kaufman; and Robin L. McGuire 

Rose, for relator. 

Ira B. Sully, for respondent. 

_________________