Cyrus Mehta

Handling Confidentiality, Adverse Interests, and Settlements in Group Suits

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By Cyrus D. Mehta and Brad Banias*

Immigration lawyers have filed lawsuits on behalf of several hundred plaintiffs challenging various immigration policies. These lawsuits have involved demanding that the government  speed up the processing of  work permits, or asking the government to reserve visas before the expiration of the program. Many of the lawsuits have resulted in settlements.

What ethical issues must a lawyer consider when signing on plaintiffs as clients? In the event that the government desires to settle, should the lawyer take into account additional ethical considerations?

There are certainly advantages when an attorney represents multiple clients in the same matter. One lawyer representing multiple plaintiffs in a litigation can ensure better coordination and communication. Legal costs are also reduced.  On the other hand, the lawyer will be representing plaintiff clients with different expectations regarding the outcome of the same litigation. Representing clients with differing interests can result in conflicts of interest.

Before representing multiple clients in a lawsuit against the government seeking injunctive relief, the lawyer must get informed consent from the clients.  ABA Model Rule 1.0(e) provides:

“Informed consent” denotes the agreement by a person to a proposed course of conduct after the lawyer has communicated adequate information and explanation about the material risks of and reasonably available alternatives to the proposed course of conduct.

Practice Pointers on What to Communicate to Plaintiff Clients Before Commencing Litigation

Professor Simon recommends that the following pointers, among others, be communicated to multiple clients before embarking on group litigation[1]:

 

  • One lawyer representing multiple plaintiffs can facilitate better coordination and communication, and thus lower expenses.
  • However, if the clients get into a dispute with each other, none of them will be able to claim the attorney client privilege as to each other with respect to communications with the common lawyer
  • Where the lawyer represents multiple clients in any litigation, some clients may accept a settlement offer while others may not. This can cause conflicts. For example:
  • Some plaintiffs may get the benefit they are seeking while others may not, and this can result in competition and jealousy
  • If there is a settlement offer, the lawyer will seek informed consent from the clients before participating in a settlement
  • In group litigation, where plaintiff clients may have different stories, the lawyer may need to emphasize one client’s version of facts over another client’s story.
  • If the lawyer has a long standing relationship with one client, or likes one over the other, then the lawyer may subconsciously tend to favor the client they like or hope to represent again in other matters.
  • If a conflict arises that cannot be resolved, then the lawyer may have to withdraw from representing some or even all the clients. When the lawyer withdraws, then the clients will have to get another lawyer or lawyers, which in turn will result in additional expenses.
  • Some information obtained from one client may be shared with the other clients in the group. Clients agree to waive any confidentiality if one client in the group discloses the information to third parties (such as on social media).
  • If the lawyer will be seeking fees under Equal Access to Justice Act if victorious, whether all of the clients are eligible for such fees or whether each client receives the same pro rata reimbursement (despite actual work on each individual case).

 

Although providing the communication as outlined above to multiple plaintiff clients may be onerous, it may be well worth the effort because a conflict can ruin the relationship not only with the lawyer but also with the other clients. Full disclosure will also alert the clients to the dangers of the multi-party representation, and the lawyer will also be able to get advance notice of any conflicts before launching the litigation on behalf of the group.

Practice Pointers on Communicating with Clients in the event of a Settlement

A settlement may not benefit all the plaintiffs. For instance, if the settlement involves the allocation of a certain number of recaptured visas, then all will not benefit. Moreover, if the settlement in a delay litigation lawsuit only includes the resolution of applications filed as of a certain date, then those plaintiffs who applications were file after that cutoff date will not benefit.

How does the attorney spearheading group immigration litigation of this kind resolve the conflicts that may arise? Another important concern is how must the attorney handle confidentiality issues? If there is a settlement offer involving hundreds of plaintiffs who are likely to communicate every development of the case on social media, how can the attorney ensure confidentiality of such communications?

ABA Model Rule 1.8(g) provides guidance to the lawyer in such instances. It provides as follows:

g)  A lawyer who represents two or more clients shall not participate in making an aggregate settlement of the claims of or against the clients, or in a criminal case an aggregated agreement as to guilty or nolo contendere pleas, unless each client gives informed consent, in a writing signed by the client. The lawyer’s disclosure shall include the existence and nature of all the claims or pleas involved and of the participation of each person in the settlement.

 

Comment 16 to ABA Model Rule 1.8(g) states:

 

[16]  Differences in willingness to make or accept an offer of settlement are among the risks of common representation of multiple clients by a single lawyer. Under Rule 1.7, this is one of the risks that should be discussed before undertaking the representation, as part of the process of obtaining the clients’ informed consent. In addition, Rule 1.2(a) protects each client’s right to have the final say in deciding whether to accept or reject an offer of settlement and in deciding whether to enter a guilty or nolo contendere plea in a criminal case. The rule stated in this paragraph is a corollary of both these Rules and provides that, before any settlement offer or plea bargain is made or accepted on behalf of multiple clients, the lawyer must inform each of them about all the material terms of the settlement, including what the other clients will receive or pay if the settlement or plea offer is accepted. See also Rule 1.0(e) (definition of informed consent). Lawyers representing a class of plaintiffs or defendants, or those proceeding derivatively, may not have a full client-lawyer relationship with each member of the class; nevertheless, such lawyers must comply with applicable rules regulating notification of class members and other procedural requirements designed to ensure adequate protection of the entire class.

 

Although the lawyer already made the appropriate disclosures to obtain informed consent before embarking on litigation, in the event of a settlement offer, Rule 1.8(g) requires the lawyer to again make disclosure before participating in making an aggregate settlement that would “include the existence and nature of all the claims or pleas involved and of the participation of each person in the settlement.”[2] Since  Rule 1.8(g) requires obtaining informed consent from each client, taking a decision regarding a settlement based on a majority vote is disfavored.  The lawyer would need to specifically disclose what claims will be settled if the plaintiffs accept the offer and what claims may remain if they take the offer.

 

Rule 1.8(g) intersects with Rule 1.7, which governs how a lawyer needs to go about representing multiple clients when there is a potential or actual conflict. Rule 1.7(a) prohibits a lawyer from representing two or more clients when the representation of one will be directly adverse to the other, or where there is a significant risk that the representation of one client will be materially limited by the lawyer’s responsibilities to the other client. However, Rule 1.7(b) nevertheless allows such representation even if there is a conflict if the lawyer believes that he or she can still provide competent and diligent representation to the affected client.  Rule 1.8(g) also intersects with Rule 1.2(a) which requires the lawyer to abide by a client’s decision whether to accept a settlement. Underpinning all of these rules is to ensure that the lawyer has obtained informed consent under Rune 1.0(e) and that the lawyer has appropriately communicated with the client under Rule 1.4 to obtain this informed consent.

Finally, a lawyer must also maintain the confidentiality of communications with all the plaintiff clients under Rule 1.6, although when the lawyer is representing multiple clients, information provided by one client may be shared with the other clients. If the lawyer wishes to keep confidential certain communication with one client, then the lawyer must obtain the informed consent from the entire group that certain communication with individual clients may not be shared with other clients so long as maintaining such confidentiality does not adversely impact the lawyer’s ability to represent all the clients competently and diligently. As noted above, plaintiffs may have a propensity to leak out confidential communications with the attorney on social media. While the lawyer may not be able to prevent such disclosure, Rule 1.6(c) states that “a lawyer shall make reasonable efforts to prevent the inadvertent or unauthorized disclosure of, or unauthorized access to, information relating to the representation of a client.”

 

Good Faith Allegations, Candor to the Court, and Hundreds of Clients You Will Never Meet

Twitter and Facebook are replete with attorney advertising directed at potential plaintiffs who live abroad. Recent group suits—sometimes including thousands of plaintiffs each—challenging travel bans and consular delays, by definition, comprise hundreds of plaintiffs who are currently abroad. In such a situation, it may be impossible to investigate the stories and facts (often provided through a standard, self-guided questionnaire) that are provided by your very own clients. So, how can you be sure the facts are true? What do plaintiffs’ counsel need to do to satisfy their obligations under Rule 11 to do a good faith investigation of the facts they aver in a pleading and their ethical obligations of candor toward the tribunal?

● ● ●

 

The relevant rules and controlling principles are as follows:

Federal Rule of Civil Procedure 11(b)(3):

(b) Representations to the Court. By presenting to the court a pleading, written motion, or other paper—whether by signing, filing, submitting, or later advocating it—an attorney or unrepresented party certifies that to the best of the person’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances . . . the factual contentions have evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable opportunity for further investigation or discovery . . .

 

Fed. R. Civ. P. 11(b).

ABA Model Rule 3.3:

(a) A lawyer shall not knowingly:

 

(1) make a false statement of fact or law to a tribunal or fail to correct a false statement of material fact or law previously made to the tribunal by the lawyer . . .

(3) offer evidence that the lawyer knows to be false. If a lawyer, the lawyer’s client, or a witness called by the lawyer, has offered material evidence and the lawyer comes to know of its falsity, the lawyer shall take reasonable remedial measures, including, if necessary, disclosure to the tribunal. A lawyer may refuse to offer evidence, other than the testimony of a defendant in a criminal matter, that the lawyer reasonably believes is false.

 

(b) A lawyer who represents a client in an adjudicative proceeding and who knows that a person intends to engage, is engaging or has engaged in criminal or fraudulent conduct related to the proceeding shall take reasonable remedial measures, including, if necessary, disclosure to the tribunal.

● ● ●

 

Best Pre-Allegation Practices:   

These apply when you are preparing your case and drafting the pleadings. First, demand copies of actual documents from your clients. Require that clients in the far reaches of the world upload official documents substantiating their claims (receipts from State, USCIS, or Labor; Consular emails; Consular returns; Actual payment receipts). This also includes identity documents that match the potential plaintiffs alleged name, date of birth, and nationality. You should also REVIEW these documents and compare them to the information in the questionnaire. Second, require your clients to sign declarations under 28 USC 1746. This provision of federal law allows individuals to declare factual matters subject to penalty of perjury from inside and outside the United States. Whether you attach the declaration to the complaint or not, you now have an additional declaration subject to penalty of perjury to rely upon should a court require you to prove that you had a good faith basis for certain allegations. Third, avoid allegations “upon information and belief.” Such allegations also need a good faith basis, though the attorney has more liability exposure on such allegations. Finally, go easy on hyperbolic allegations. Do you have a good faith basis that the consulate refused a visa because of personal animus, political bias, or sheer prejudice? While you may be able to intimate through such possibilities through circumstantial evidence, be mindful of your obligations to have a good faith basis to make certain factual allegations.

 

Best Post-Allegation Practices:

So, you’ve filed a pleading with factual allegations and, now, you’ve learned they are not true. First, determine whether the allegations are material and require remedial action. If the false allegation relates to something immaterial, there is likely no duty under Rule 3.3 to conduct remedial measures. However, it is a good practice to go ahead and correct any falsity through an errata, footnote, or notice. Again, while it may not be required because the “falsity” is immaterial and will be “fixed” through the course of litigation, there is a strategic benefit to fix the misstatement before the government points it out to attack you and your client’s credibility. Second, if it is a material misrepresentation, you must take “reasonable remedial measures.” Of course, there is no black and white on what is a “reasonable” remedy for correcting falsities. But the remedial measure must fix the misstatement. Reasonable measures may include an amended pleading with the proper information; a notice of correction of certain facts; or a supplemental declaration from the client correcting the information. There is no way to identify all possible remedies, but one principal is clear: you must identify and fix the falsity. And unfortunately, if the client refuses to fix the falsity and demands you push the case forward based on the falsity, you will likely need to withdraw from representation based on an irreconcilable conflict and notify the court of the falsity. This can be very tricky in a group case to have one plaintiff unrepresented (who lives somewhere far, far away) while you continue forward with the remainder of the group.

 

*Guest author Brad Banias is a partner in Wasden Banias, and is a nationally recognized in federal court immigration litigation. See https://www.wasdenbanias.com/

 

[1] See Simon’s New York Rules of Professional Conduct Annotated Volume 1, §1.7:81, 2020-21 Edition.

[2] To bind multiple clients jointly represented by the same lawyer, an aggregate settlement requires the informed written consent of each and every client, and the requirement of  individual informed consent may not be waived by any of the jointly represented clients. See NYC Bar Opinion 2009-06, available at https://www.nycbar.org/member-and-career-services/committees/reports-listing/reports/detail/aggregate-settlements-formal-opinion-2009-06

 

Cyrus Mehta

November 2021 Visa Bulletin Seesaw: Frequently Asked Questions

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By Cyrus D. Mehta and Kaitlyn Box*

On Thursday, October 14,  2021, the Department of State released the November 2021 Visa Bulletin, which has brought significant retrogression in employment-based third preference (EB-3) India dates, among other significant changes. The EB-3 India Date for Filing (DFF) retrogressed to January 22, 2012 and the Final Action Date (FAD) almost two years to January 15, 2012. By contrast, the  India EB-3 DFF  under the October 2021 Visa Bulletin is January 8, 2014 and the EB-3 India FAD is January 1, 2014. On the other hand, the Employment-based Second Preference (EB-2) India DFF has advanced to January 8, 2013 and the FAD to December 1, 2011. As it did in October 2021, USCIS has elected to use the DFF for employment-based adjustment of status applications. Thousands of applicants who filed concurrent I-140 petitions and I-485 applications when India EB-3 DFF dates rapidly advanced under the October 2020 Visa Bulletin, as well as under the November 2020 and December 2020 Visa Bulletins, are now justifiably disappointed that the USCIS has failed to  approve their I-485 applications and will remain stranded in the backlogs if their applications are not approved by October 31. The retrogression of EB-3 India dates, in particular, has thus been the source of much concern and confusion, so we address a few common questions below.

 

Q: I have approved I-140s under both India EB-2 and India EB-3 with the same employer. I filed my I-485 adjustment application concurrently with the EB-3 I-140, but it has yet to be approved due to Service Center backlogs and now EB-2 dates are moving ahead. Should I file a second adjustment at a different Service Center based on the EB-2 I-140?

If the Form I-485 was filed concurrently with the EB-3 I-140, it is generally not advisable to file another I-485 for the EB-2 I-140. There is no guarantee that a separately filed I-485 based on the now current EB-2 I-140 will be processed faster at a different service center than the Texas Service Center, which has been extremely backlogged and processing cases very slowly. USCIS designates the appropriate filing addresses for applications, and the filing location for adjustment applications based on an approved I-140 depends on the applicant’s address.  Thus, many adjustment applications will go to the Texas Service Center regardless, and one cannot select an alternative filing location.

The USCIS has a policy of transferring the underlying basis of an I-485 from one I-140 petition to another. The USCIS Policy Manual contemplates such a transfer of underlying basis from an I-140 filed by one employer to an I-140 filed by another employer, and requires that the applicant write a letter, although USCIS often automatically approves the I-485 based on whichever I-140  is current if both have been filed by the same employer. This used to be USCIS policy some  years ago when the China EB-3 overtook the China EB-2.  Although the USCIS Policy Manual explains that portability cannot be exercised under INA § 204(j) until 180 days upon the  transfer of underlying basis, this applies when the transfer of underlying basis of the I-485 is with an I-140 filed by one employer to an I-140 filed by another employer, or when the second I-140 petition of the same employer is for a different position,  but should not apply when there are two I-140s filed by the same employer for the identical position. Thus, if an employee has two approved I-140s with the same employer and identical position, USCIS should automatically connect the adjustment application to the I-140 that becomes current fastest, without the need for what one may term as  interfiling or filing of a second adjustment application. In fact, filing a second I-485 may cause confusion at USCIS and result in further delays.

 

Q: My family filed I-485s when my priority date was current under EB-3 India DFF, but they are still pending and my priority date will no longer be current in November 2021. Will my child’s age still be protected if he or she turns 21 before our adjustment applications are approved?

 Although we view this policy as erroneous, the USCIS Policy Manual makes clear that the concurrent filing of an I-485 based on a current DFF does not protect a child from aging out under the Child Status Protection Act (CSPA).  The child’s age, according to USCIS, locks in only when the FAD becomes current.  (It may be possible for certain people adversely affected by this policy to challenge it in federal court.)  There is a likelihood that the India EB-2 FAD will advance ahead of the India EB-3 FAD in the next few months. Thus, an I-485 that was filed concurrently with an EB-3 I-140 ought to  lock in the child’s age when the EB-2 I-140 becomes current, even if the I-485 was filed concurrently with the EB-3 I-140 as there is a transfer of basis of the I-485 from the EB-3 to the EB-2 140.  Again, there does not seem any need to file a new I-485 only for the purpose of locking in the child’s age and the USCIS has not issued any guidance that one must do so, although it may be prudent to write a letter to the USCIS requesting the transfer of underlying basis. However, because of the lack of guidance from USCIS, those who want to play 100% safe may want to file a new I-485 in lieu of writing a letter to the USCIS requesting the transfer of underlying basis.

The CSPA ought to apply as the underlying basis of the I-485 filed with the EB-3 I-140 transfers to the I-140 filed under EB-2 provided the other conditions to lock in the child’s age under the CSPA are met. The I-140 must have been filed before the child’s 21st birthday, and on the date when the FAD is current on either of the I-140s, the child is under 21. If the child is over 21 at the time the FAD is current, the CSPA allows the child’s age to be subtracted  by the number of days it  took from the filing of the I-140 petition to its approval. If the child’s CSPA age falls below 21 after the subtraction, it gets locked in until the I-485 is adjudicated. The child would have also sought permanent residency within one year of visa availability based on the I-485 that was filed with the EB-3 I-140, which has been transferred to the EB-2 I-140. The letter requesting transfer of underlying basis should satisfy the requirement that the child sought permanent residency within one year of the EB-2 I-140 becoming current, although the filing of a second I-485 application under this circumstance is recommended in order to be 100% safe in the absence of USCIS guidance.

Even if there is retrogression of the FAD after the CSPA locks in the child’s age, the child’s age will continue to be locked in until the FAD becomes current again and the I-485 is adjudicated.

Our prior blog provides further clarification on CSPA issues.

 

Q: I have approved I-140s under both India EB-2 and India EB-3. I was in the processing of filing my I-485 under EB-3 in October 2021. Should I instead file under EB-2?

Since the USCIS has announced that it will accept I-485  adjustment applications under the DFF for November 2021, applicants in this position should consider filing under the already approved EB-2 I-140 if their priority date is current under the EB-2 Date for Filing, as the EB-2 dates appear to now be moving ahead faster. If the applicant’s priority date will not be current under the EB-2 DFF in November 2021, it is prudent to still catch the first bus and file the I-485 under EB-3 before the end of October. If the priority date subsequently becomes current under EB-2, the basis for the I-485 can then be transferred to the EB-2 I-140, as described above.

(This blog is for informational purposes, and should not be relied as a substitute for legal advice).

* Kaitlyn Box graduated with a JD from Penn State Law in 2020, and works as an Associate at Cyrus D. Mehta & Partners PLLC.

 

Cyrus Mehta

Migration in the Time of COVID-19 Ebook – How Much Has the Pandemic Really Shifted the Immigration Landscape?

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By Kaitlyn Box*

Together with my co-author, Shoba Sivaprasad Wadhia, Associate Dean for Diversity, Equity, and Inclusion, the Samuel Weiss Faculty Scholar, and Founder and Director of the Center for Immigrants’ Rights Clinic (CIRC) at Penn State Law, I recently contributed a chapter to the Frontiers in Human Dynamics e-book “Migration in the Time of COVID-19: Comparative Law and Policy Responses”. A PDF can be downloaded from the Frontiers website.  The e-book “aims to provide one of the first comparative analyses of migration law and policy responses to the COVID-19 pandemic”, by bringing together a collection of articles that “examine and assess destination states’ responses to COVID-19 from the perspective of migration law and policy, and consider how they build upon prior exclusionary regimes, offering suggestions for reform of domestic laws in the wake of the pandemic.”

Our article, entitled “COVID-19 and Immigration: Reflections From the Penn State Law Center for Immigrants’ Rights Clinic”, provides a review of significant COVID-19 -related immigration policy changes, and uses CIRC as a case study to demonstrate how the same tools that immigration advocates have developed to respond to the ever-evolving policies of the Trump administration can also be harnessed to address COVID-related immigration policies. In particular, we discuss three of CIRC’s central response tools: short, accessible fact sheets and FAQ sheets, informational “town hall” forums to discuss new immigration laws or policies as they impact the community, and direct representation of individual clients.

One central thread that emerged across the chapters of the ebook, as well as in last week’s book launch panel, was the idea of continuity, both in repressive immigration policies and the responses to them, both before and during the pandemic. Although the Trump administration, marked by its numerous and draconian immigration policy changes, has now been replaced by the Biden administration, many Trump-era policies still live on, situating COVID-related immigration policies within a broader harsh climate for immigration. Recent federal court decisions, for example, illustrate the revival of many of the Trump administration’s policies, as well as its jaundiced view of immigrants. A federal judge in Texas, for example, recently ordered the Biden administration to reinstate the Migrant Protection Protocols, which force asylum seekers to wait in Mexico for adjudication of their cases, often placing them in grave danger. In August, the Supreme Court refused to overturn the lower court order that would revive the program. Similarly, the U.S. District Court for the Southern District of Texas recently held that Biden’s immigration enforcement priorities, which would have focused removal efforts on only those noncitizens who were a national security risk, entered the United States on or after November 1, 2020, or posed a threat to public safety, were a violation of the Administrative Procedure Act, at least as applied to detention cases. However, the Fifth Circuit has issued a partial stay of the S.D. Texas order, allowing the provisions that provide guidance on when enforcement actions should be initiated to go into effect, among others. The Fifth Circuit’s order left in place only a handful of narrow provisions in the injunction that concern detention. The U.S. District Court for the Southern District of Texas has also held that the DACA program violates the APA, which will bar any new applications for the program.

Many of the COVID-related immigration policies outlined in the chapter continue, at least in some form, as well. For the moment, the slew of COVID travel bans continue, with the suspension on entry into the United States of nonimmigrants who have been physically present in India prior to traveling having been added by the Biden administration after publication of the ebook. As discussed in prior blogs, these bans have a disproportionately harsh impact on nonimmigrants, who are no more likely to transmit COVID-19 than the numerous categories of other travelers exempted by the bans. Although the bans are projected to be lifted in November, to be replaced with testing and vaccination requirements, the harm they created, particularly for nonimmigrants who traveled to be with family at the height of the pandemic and became trapped outside the U.S., is unlikely to be immediately resolved, particularly in light of lingering vaccine inequality issues.

Similarly, the suspension of non-essential travel by land and sea between the United States and Mexico and Canada remains in place for a little while longer. This suspension also includes a number of exemptions, including for U.S. citizens and permanent residents, as well as certain categories of essential workers. First implemented in April 2020, the restrictions were recently extended until at least October 21, 2021.

The chapter also discusses the interruptions to visa processing that occurred when U.S. embassies and consulates suspended routine services. When the travel bans are lifted, some consular services may resume. However, consulates are likely to have significant backlogs and operations may still be disrupted by local COVID conditions. Thus, individuals who are waiting for visa interviews and the like are still likely to experience significant delays.

The climate for asylum seekers, too, has improved little since publication of the ebook. Our article discusses the summary removals that resulted from a CDC and U.S. Department of Health and Human Services regulation and notice that suspended the “introduction” into the United States of individuals who arrived at or between ports of entry without valid travel documents or permission. The Trump administration invoked Title 42, a provision of the 1944 Public Health Services Act permitting the federal government to prevent travel into the country in the event of a public health crisis, as the authority for this order. Despite relaxing the restrictions somewhat for unaccompanied minors and parents with children, the Biden administration has largely continued to rely on Title 42 to summarily remove adults who arrive at the border, effectively denying them any meaningful opportunity to seek asylum. This use of Title 42 plainly contradicts with the United States’ legal obligations to asylum seekers, as laid out at 8 U.S.C. § 1158, which states that any individual “who arrives in the United States…may apply for asylum”.

Although many hostile immigration policies linger on, the conclusion need not be an entirely negative one. Many of the pandemic’s most onerous restrictions, such as the travel bans, are soon to expire, which will provide relief to many. Further, one need not reinvent the wheel when responding to COVID-related immigration laws and policies. Immigration lawyers became very skilled at advising their clients about ever-evolving policies and finding creative solutions during the Trump administration. The tools highlighted in our chapter need not apply only to law school clinics. Practitioners of all varieties continue to support and counsel individual clients as the navigate immigration policy changes, COVID-related and otherwise, and community education can take the form of articles, blogs, webinars, or even social media posts that relay the latest policies in an accurate and digestible way. The same skills and tools that have been honed in recent years can still be utilized during the pandemic, however long it may last.

(This blog is for information purposes, and should not be relied upon as a substitute for legal advice).

* Kaitlyn Box graduated with a JD from Penn State Law in 2020, and works as an Associate at Cyrus D. Mehta & Partners PLLC.