To,

OREGON STATE BAR CLIENT ASSISTANCE OFFICE,

The Oregon State Bar,
16037 SW Upper Boones Ferry Road,
P.O. Box 231935 Tigard,
OR97281-1935
Email: dbclerk@[Link]

Reference:
IN THE CIRCUIT COURT OF THE STATE OF OREGON, FOR
THE COUNTY OF MULTNOMAH, CASE NO. 19CV47761,
FATTAH ABUALAYA VS ALL STOP PIPES AND TOBACCO,
LLC

Subject:
PROFESSIONAL MISCONDUCT COMPLAINT AGAINST ATTORNEY
JUSTIN STEFFEN [OFFICE CHAMBER : 205 SE Spokane St. #300
Portland, OREGON-97202, Mobile:-971-570-9225, Email:
info@[Link]] UNDER RULES 1.1, 1.2, 1.3, 1.4, 1.16
OF THE OREGON RULE OF PROFESSIONAL CONDUCT, read with DR
2-110(A), DR 7-101(A), DR 7-106(A)&(C), DR 1-102(A),
DR 7-102(A), DR 6-101(A)&(B) of the Oregon Code of
Professional Responsibility.

Dear Sir/Madam,

This is a formal complaint against my ex-attorney Justin Steffen,

Attorney at Law, Steffen Legal Services, LLC for intentional gross violation of
professional conduct and criminal breach of trust.

Following are brief facts of my formal complaint:

1. My service was terminated illegally & wrongfully from “All Stop Pipes
and Tobacco, LLC (the “Company”)” in July 2019, by the company
without following due process of law. I hired an attorney Justin Steffen
on 11th September 2019 to defend my illegal and wrongful service
termination case from “All Stop Pipes and Tobacco, LLC (the
“Company”)”. I paid attorney Justin Steffen $5,000/- (USD five

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 thousand dollars only) on September 11th 2019 as advance fees for
the entire legal representation (Flat rate, per rep agreement) in my
case.(Pay order is attached as “Annex-A”)

2. The attorney Justin Steffen, since appointed as my attorney on

September 11th 2019, acted deliberately in a negligent and mala fide
manner by not sending the demand letter to the company on time. He
deliberately sent the demand letter to the company after about five
weeks since appointed, which amounts to gross professional
misconduct. Therefore the attorney Justin Steffen violated rules 1.1,
1.2, 1.3, 1.4 of Oregon Rules Of Professional Conduct.

3. The attorney Justin Steffen on September 11th 2019 abruptly

withdrew his legal representation from my case by a phone call, just
before the commencement of court trial dates on 6th & 7th of
December 2021, without assigning any reasons. I was unable to
arrange the legal services of other competent attorneys to represent
my case due to the very abrupt withdrawal of legal representation by
the attorney. I suffered unliquidated damages due to the abrupt
withdrawal of the legal representation by the attorney. Therefore the
attorney Justin Steffen violated rules 1.1, 1.2, 1.3, 1.4, 1.16 of Oregon
Rules Of Professional Conduct, read with DR 2-110(A), DR 7-101(A),
DR 7-106(A)&(C), DR 1-102(A), DR 7-102(A), DR 6-101(A)&(B) of the
Oregon Code of Professional Responsibility.

4. The attorney knew very well that I can neither arrange new competent
attorney nor an attorney who can represent my case in a very short
time span due to abrupt withdrawal of legal representation from my
case. The attorney cited trivial & ridiculous reason that he lost his
interest in my case through a phone call, which amounts to gross
professional misconduct.

5. Due to intentional, mala fide, and gross professional misconduct by the

attorney Justin Steffen, I didn't get any benefit in the case arising out
of my illegal & wrongful service termination including my hard-earned
unpaid wages from my service.

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6. The attorney Justin Steffen acted deliberately in a negligent and mala
fide manner having caused loss, destruction, & disappearance of all
documents. The documents are my medical reports in my service
days, witnesses. He never informed me about the progress of my case
on time, as he should act as per prescribed professional ethics, rules
and regulations. I have been prompt in giving him all required
documents for my case since his appointment. Whenever I called him
regarding progress of my case, the attorney used to say that he forgot
and lost all documents. Then again he asked me to replace all the
documents lost by him. Then without delay, I sent him all the
documents by email and text messages.

7. The attorney Justin Steffen lost all my documents required in my case

twice, between September 2019 to September 2021.

8. The attorney Justin Steffen acted deliberately in a negligent and mala

fide manner, by extraordinary inordinate delays in his legal drafting
and pleading.

9. The attorney Justin Steffen acted deliberately in a negligent and

mala fide manner, by intentional misrepresentation and wrongful legal
advice pertaining to my deposition. For instance, when I asked him if I
was required to disclose personal information not relevant in my case.
The attorney said that I/plaintiff should disclose all information and
whatever you say in the deposition would not count in the trial and
would not affect my case. He gave me intentional wrong legal advice
before my deposition date. After my deposition he changed his stance
citing that he never gave any such legal advice. The attorney Justin
Steffen consistently and repeatedly lied, and rendered intentional
wrong legal advice to me in every occasions. Due to intentional gross
professional misconduct by the attorney, my deposition was
unsuccessful.

10. The attorney Justin Steffen acted deliberately in a negligent and

mala fide manner, never examined plaintiff witnesses in the case. The
attorney was supposed to depose plaintiff witnesses such as a current
employee named Anna and also former employees, since he took my
case on 11th September 2019. He was lagging in my case, and never

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 informed me about the stage & progress throughout the case. It was
only I, who called my attorney to enquire about the stage & progress
of my case, since he was appointed in my case.

11. The attorney Justin Steffen acted deliberately in a negligent and

mala fide manner, rarely shared any court document, papers in my
case like plaint, written statement, exhibits, etc. The attorney Justin
Steffen never shared with me, the defendant's received documents in
the case. I have been kept in absolute darkness about my case by the
attorney about each and every aspect of my court case. The attorney
deliberately advised false fabricated legal advice.

12. After attorney Justin Steffen withdrew from my case, I emailed

him to send me copies of court case documents. The attorney never
took any steps to return those documents till date. The attorney Justin
Steffen therefore violated DR 2-110(A) of the Oregon Code of
Professional Responsibility read with Rule 1.16 (d) of the Oregon Code
of Professional Conduct.

13. On the basis of foregoing paragraphs, attorney Justin Steffen is

liable for disciplinary action and appropriate proceedings under Oregon
Code of Professional Responsibility (as approved by the Oregon
Supreme Court through June 17, 2003) and Oregon Rules Of
Professional Conduct.

14. The attorney Justin Steffen is liable for disciplinary proceedings

under the following disciplinary code of Oregon Code of Professional
Responsibility (as approved by the Oregon Supreme Court through
June 17, 2003):-
I. DR 2-110 (A) of the Oregon Code of Professional Responsibility
(the “Oregon Code”) for his, inter alia, withdrawal from the
case, without giving me any notice and time for engaging any
other attorney which has seriously prejudiced my case. The DR
2-110 reads as follows:-
“(2) In any event, a lawyer shall not withdraw from
employment until the lawyer has taken reasonable steps to
avoid foreseeable prejudice to the rights of the lawyer’s
client, including giving due notice to the lawyer’s client,

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 allowing time for employment of other counsel, delivering
to the client all papers and property to which the client is
entitled, and complying with applicable laws and rules.

(3) A lawyer who withdraws from employment shall refund

promptly any part of a fee paid in advance that has not
been earned.”

II. DR 7-101 (A) of the Oregon Code of Professional Responsibility

(the “Oregon Code”) for his, inter alia, withdrawal from the
case, without giving me any notice and time for engaging any
other attorney which has seriously prejudiced my case. The DR
7-101 (A) reads as follows:-
“(A) A lawyer shall not intentionally:-
(1) Fail to seek the lawful objectives of the lawyer’s client
through reasonably available means permitted by law and
these disciplinary rules except as provided by DR 7101(B).
A lawyer does not violate this Disciplinary Rule, however,
by acceding to reasonable requests of opposing counsel
which do not prejudice the rights of the lawyer’s client, by
being punctual in fulfilling all professional commitments,
by avoiding offensive tactics, or by treating with courtesy
and consideration all persons involved in the legal process.

(2) Fail to carry out a contract of employment entered into

with a client for professional services but the lawyer may
withdraw as permitted under DR 2110, DR 5102 and DR
5105.

(3) Prejudice or damage the lawyer’s client during the

course of the professional relationship except as required
under DR 7102(B)"

III. DR 7-106 (A) & (C) of the Oregon Code of Professional

Responsibility (the “Oregon Code”) for his, inter alia,
withdrawal from the case, without giving me any notice and time
for engaging any other attorney which has seriously prejudiced
my case. The DR 7-106 (A) & (C) reads as follows:-

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 “(A) A lawyer shall not disregard or advise the lawyer’s
client to disregard a standing rule of a tribunal or a ruling of a
tribunal made in the course of a proceeding but the lawyer may
take appropriate steps in good faith to test the validity of such
rule or ruling.
(C) In appearing in the lawyer’s professional capacity
before a tribunal, a lawyer shall not:
(7) Intentionally or habitually violate any established
rule of procedure or of evidence."

IV. DR 1-102 (A) of the Oregon Code of Professional Responsibility

(the “Oregon Code”) for his, inter alia, withdrawal from the
case, without giving me any notice and time for engaging any
other attorney which has seriously prejudiced my case. The DR
1-102 (A) reads as follows:-
"It is professional misconduct for a lawyer to:
(1) Violate these disciplinary rules, knowingly assist or induce
another to do so, or do so through the acts of another;
(3) Engage in conduct involving dishonesty, fraud, deceit or
misrepresentation;
(4) Engage in conduct that is prejudicial to the administration of
justice;

V. DR 7-102 (A) of the Oregon Code of Professional Responsibility

(the “Oregon Code”) for his, inter alia, withdrawal from the
case, without giving me any notice and time for engaging any
other attorney which has seriously prejudiced my case. The DR
1-102 (A) reads as follows:-
"(A) In the lawyer’s representation of a client or in representing
the lawyer’s own interests, a lawyer shall not:
(3) Conceal or knowingly fail to disclose that which the
lawyer is required by law to reveal.

(5) Knowingly make a false statement of law or fact.

(8) Knowingly engage in other illegal conduct or conduct

contrary to a Disciplinary Rule"

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 VI. DR 6-101 (A) & (B) of the Oregon Code of Professional
Responsibility (the “Oregon Code”) for his, inter alia,
withdrawal from the case, without giving me any notice and time
for engaging any other attorney which has seriously prejudiced
my case. The DR 6-101 (A) & (B) reads as follows:-
"(A) A lawyer shall provide competent representation to a client.
Competent representation requires the legal knowledge, skill,
thoroughness and preparation reasonably necessary for the
representation.
(B) A lawyer shall not neglect a legal matter entrusted to the
lawyer."

15. A lawyer is professionally bound to explain a matter to the

extent reasonably necessary to permit the client to make informed
decisions regarding the representation. Rule 1.4 (b) of the Model Rules
of Professional Conduct by American Bar Association (the “Rules of
Professional Conduct”) the Rules of Professional Conduct reads as
under:
“(b) A lawyer shall explain a matter to the extent reasonably
necessary to permit the client to make informed decisions
regarding the representation.”

16. The attorney Justin Steffen badly managed my case and

exhibited gross negligence and unprofessionalism in my case.
Following facts may kindly be taken into consideration:

I. The attorney Justin Steffen deliberately kept on delaying my

case which seriously prejudiced my case in fragrant disregard
to the rule 3.2 of the Rules of Professional Conduct which
states as under:
“A lawyer shall make reasonable efforts to expedite
litigation consistent with the interests of the client.”

II. The attorney Justin Steffen lost my valuable documents twice

and was not even able to trace my documents which amount
to gross negligence and show carelessness, misconduct and
lack of professionalism in my case.

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 III. The attorney Justin Steffen kept on ignoring my text
messages and did not bother to respond to my text
messages. He always lied to me that he received my text
messages and when I showed him text messages, he said he
lost his interest in my case;
(text messages are attached as “Annex-B”)

17. Under facts and circumstances, I most humbly seek to draw up

disciplinary proceedings against attorney Justin Steffen on the grounds
of intentional, gross professional misconduct which entail his
permanent suspension from your honorable bar on the following
grounds:-
I. Rule 1.16 (d) of the Oregon Rules of Professional Conduct (the
“Oregon Rules”)clearly states that he was bound to give me the
reasonable notice of termination of his services and allowing me
reasonable time to employ another attorney. Rule 1.16 (d) of the
Oregon Rules reads as under:
“(d) Upon termination of representation, a lawyer shall take
steps to the extent reasonably practicable to protect a client's
interests, such as giving reasonable notice to the client, allowing
time for employment of other counsel, surrendering papers and
property to which the client is entitled and refunding any
advance payment of fee or expense that has not been earned or
incurred. The lawyer may retain papers, personal property and
money of the client to the extent permitted by other law."
[Emphasis Supplied]

II. The attorney Justin Steffen also violated Rule DR 2-110 of the
Oregon Code of Professional Responsibility (the “Oregon Code”)
for his, inter alia, withdrawal from the case, without giving me
any notice and time for engaging any other attorney which has
seriously prejudiced my case. The DR 2-110 reads as follows:
“(2) In any event, a lawyer shall not withdraw from
employment until the lawyer has taken reasonable steps to
avoid foreseeable prejudice to the rights of the lawyer’s
client, including giving due notice to the lawyer’s client,
allowing time for employment of other counsel, delivering

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 to the client all papers and property to which the client is
entitled, and complying with applicable laws and rules.

(3) A lawyer who withdraws from employment shall refund

promptly any part of a fee paid in advance that has not
been earned.”

III. The attorney Justin Steffen has failed to communicate with me

on every occasions about the progress and stage of my case,
hence he violated rule 1.4 of the Oregon Rules which reads as
under:-

“(a) A lawyer shall keep a client reasonably informed about

the status of a matter and promptly comply with
reasonable requests for information.

(b) A lawyer shall explain a matter to the extent

reasonably necessary to permit the client to make
informed decisions regarding the representation.”

IV. The attorney Justin Steffen agreed to return to me the full fee
paid for his legal services i.e. $5,000/-. However, he did not
return the full amount. Rule 1.5 (f) of the Rules of Professional
Conduct states:-
“A fee that is nonrefundable in whole or in part shall be
agreed to in a writing, signed by the client, that explains
the intent of the parties as to the nature and amount of
the non-refundable fee.”

Under facts and circumstances specified in the foregoing paragraphs, I most

humbly request that Justin Steffen’s, Attorney at Law, Steffen Legal
Services, LLC license may kindly be permanently suspended, for the offence
in violating rules 1.1, 1.2, 1.3, 1.4, 1.16 of Oregon Rules Of Professional
Conduct, read with DR 2-110(A), DR 7-101(A), DR 7-106(A)&(C), DR 1-
102(A), DR 7-102(A), DR 6-101(A)&(B) of the Oregon Code of Professional
Responsibility.

I also humbly seek Justin Steffen Attorney be asked to my reimburse my

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financial losses, and also pay unliquidated damages for causing me immense
psychological and mental distress, in interest of justice, equity and fair play.

I most humbly request you to kindly inform me through email & post, about
the disciplinary proceedings against attorney Justin Steffen. I also seek
opportunity of being heard on all hearing dates in the disciplinary
proceedings against Justin Steffen Attorney, and allow me to provide
additional evidences against the attorney Justin Steffen to substantiate his
intentional, mala fide, gross professional misconduct in my illegal and
wrongful service termination case against the company.

With warm regards,

___________________________
FATTAH ABUALYA

Address: 3204 NE Stapleton Rd, #J Vancouver WA 98661

Mobile: +1-3606090956
Email: alyafattah707@[Link]

CC:Justin Steffen, Attorney at Law, Steffen Legal Services, LLC

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