A lawyer should instruct a paralegal employee to disclose at the beginning of any dealings with a client that he is not an attorney. Whenever any person dealing with a paralegal has reason to believe that the paralegal is a lawyer or associated with a lawyer, the paralegal shall make clear that he is not a lawyer. Even if a paralegal appears before an administrative agency or court in which a lay person is entitled to represent a party, the paralegal should nevertheless disclose his status to the tribunal. Routine early disclosure of nonlawyer status is necessary to ensure that there will be no misunderstanding as to the responsibilities and role of the paralegal. Disclosure may be made in any way that avoids confusion.
Common sense suggests a routine disclosure at the out-et of communication.