Washington, D.C., immigration attorney Paul S. Haar didn’t think twice when he deposited two clients’ prepaid legal fees into his operating account in the late 2000s.

He was doing what he always did with advanced legal fees: he placed them into his operating account with the understanding that he could spend that money prior to doing any work on the cases. At least, that’s what then-Rule 1.15(d) instructed when he was admitted to the Bar in 1983.

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