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March 25, 2020

Michael J. Lampe
Law Office of Michael J. Lampe
Michael P. Smith
108 West Center Avenue
Visalia, California 93291

Re:

Tulare Local v. Greene
Our File No.: XBHZ.119108.1

Dear Michael:
On behalf of our clients Bruce Greene and Baker & Hostetler, I am responding to the
Tulare Local Health District proposed Resolution 886 and the draft State Bar Complaint that was
unnecessarily published on the District’s website.
It is obvious that the District’s action in publishing the proposed State Bar Complaint is a
mere litigation tactic designed to pressure the firm and Mr. Greene in the ongoing lawsuit which
was filed more than one year ago and is now pending in Kern County. The draft complaint is
factually inaccurate and legally unsupportable. Your decision to make public a document that is
usually filed privately with the Bar is very telling. Your actions certainly raise issues for the
District’s General Counsel under RPC Rule 3.10.
If the District desires to pursue a Bar complaint, normal course of business would be to
consider such action in executive session and then privately file it with the Bar. The fact of
making the proposed complaint public is evidence of the District’s bad faith and may subject the
and its Board members to a damage claim by Mr. Greene and the law firm, which they expressly
reserve the right to make.

 Michael J. Lampe
Tulare Local v. Greene
March 25, 2020
Page 2
I am disappointed that you have chosen this course of action. It is short-sighted and will
not inure to the District’s benefit.
Very truly yours,

James A. Murphy
JAM.3684350.docx

 Michael J. Lampe
Tulare Local V. Greene
March 25, 2020

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