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NORTHERN CALIFORNIA RECORD

Friday, April 19, 2024

State Bar Court of California suspends four attorneys for failing to pass exam

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LOS ANGELES — The State Bar Court of California recently suspended several California State Bar members due to their alleged failure to pass the Multistate Professional Responsibility Exam (MPRE). 

According to the March court decisions, Jeffrey Alan Dickstein, a Tulsa, Oklahoma, attorney and licensed in California, was ordered suspended in December 2015 for two years and ordered to take the MPRE. The discipline stemmed from a federal conviction of contempt. He was admitted to the California State Bar in 1976 and is a graduate of the California Western School of Law.

On March 13, Theodore Edward Malpass, a Laguna Beach attorney, was ordered suspended due to failure to pass the MPRE. The Orange County attorney was admitted to the State Bar in 1984 and has two prior instances of discipline. In February 2016, he accepted fees for a bankruptcy proceeding without gaining the approval of the bankruptcy court beforehand. In September 2016, he accepted funds from two clients without the court’s approval and allegedly struck his legal assistant after she refused to let him speak with a client. Malpass is a graduate of the University of Colorado School of Law.

Dane Paul Miller, a Los Angeles attorney, was suspended on March 13 for his failure to pass the MPRE. He was ordered to take the exam as part of a suspension and probation order in January 2016 when he was disciplined for not promptly providing a client with settlement funds. Miller was admitted to the State Bar in 2003 upon graduation from the University of California Berkeley School of Law.

James Hsiaosheng Li, a Buena Park attorney, was suspended March 20 for failing to pass the MPRE as part of a previous suspension order. In February 2016, Li was found guilty in six counts of misconduct surrounding the acceptance of advanced fees. He is a graduate of the UCLA School of Law and was admitted to the State Bar in 1995.

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