Unbundling Resource Center

Document Preparation

Articles

Barrie Althoff, Ethics and the Law: Ethical Considerations for Lawyers and Judges When Dealing with Unrepresented Persons, Washington State BarNews (Jan. 2000).

Barrie Althoff, Limiting the Scope of Your Representation: Questions of Cost, Candor, and Disclosure, Washington State Bar News (Jul. 1997).

Debra Cassens Weiss, Law firm that filled in petition blanks wasn't ghostwriting, 11th Circuit says, ABA Journal (September 2013)

Melissa Darigan, Changes in How We Practice: Limited Scope Representation is Here (Rhode Island Bar Journal, Nov-Dec, 2015)

Joe Forward, Are You Ready? New Limited-Scope Representation Rules Take Effect in 2015, State Bar of Wisconsin Inside Track (November 5, 2014)

Jona Goldschmidt, In Defense of Ghostwriting, 29 Fordham Urban L J 1145 (2002).

David Grunfeld, Ghostwriting: Limited Scope Agreements Are Allowed Under Pennsylvania Rules of Professional Conduct, The Philadelphia Lawyer (Spring 2012)

Samson Habte, Contract Lawyer May ‘Ghostwrite’ Pleading Without Notice to Court, Opposing Counsel, Bloomberg BNA (April 2014)

William Hornsby, Improving the Delivery of Affordable Legal Services Through the Internet: A Blueprint for the Shift to a Digital Paradigm, ABA Standing Committee on the Delivery of Legal Services (Nov. 1999).

William Hornsby, Unbundling and the Lawyer's Duty of Care, American Bar Association Family Advocate (Fall 2012)

Stephanie Kimbro, Using Technology to Unbundle in the Legal Services Community, Harvard Journal of Law and Technology (February 2013)

Stephanie Kimbro, Unbundling: What Is It? American Bar Association Family Advocate (June 2012)

Tamara M. Kurtzman, The Implications of Ghostwriting in State and Federal Courts (Los Angeles Lawyer, March 2016, Pg. 11)

Adam W. Lasker, New supreme court rules a boon to limited-scope representation, Illinois Bar Journal (August 2013)

James M. McCauley, Current Ethical and Unauthorized Practice Issues Relating to Endeavors to Assist Pro Se Litigants, Virginia Lawyer, Vol. 51, p. 43 (December 2002).

Nicole Cudiamat Minnis, Improving Access to Justice – “Unbundling” Legal Services in Illinois, The National Law Review (August 2013)

Dianne Molvig, Unbundling Legal Services, The Wisconsin Lawyer, Vol. 70, No. 9, at 10 (Sept. 1997).

Forrest S. Mosten, Unbundled Legal Services Today -- And Predictions for the Future, American BAr Association Family Advocate (Fall 2012)

Kim Prochnau, Slicing the Onion: Rules of Professional Conduct and Court Rules Make It Easier for Private and Non-Profit Legal Practitioners to Provide "Unbundled" Legal Services, Washington State Bar News (Apr. 2003).

John C. Rothermich, Ethical and Procedural Implications of "Ghostwriting" for Pro Se Litigants: Toward Increased Access to Civil Justice, 67 Fordham L Rev 2687 (1999).

Alexander R. Rothrock, Limited Scope and Lawyer Liability: How courts view the lawyer's role in unbundling, American Bar Association Family Advocate (Fall 2012)

Effie D. Silva, Diverging Views on Ghostwriting Documents for Pro Se Litigants, Litigation News (July 6, 2010).

Diane Slomowitz, BRIEFS FOR THE BRIEF WRITER: Ghostwriting a scary, gray area, Wisconsin Law Journal (October 16, 2014)

Unbundled Services & Assisting the Pro Se Litigant, New Hampshire Bar Association Ethics Committee (May 12, 1999).

Anthony Zapata, Legal Ghostwriting in Indiana: An Analysis, Res Gestae (September 2005).

Books & Reports

Caught in the Middle: 2003 Report and Recommendations of the North Carolina Bar Association Pro Se Task Force (Dec. 2003).

An Analysis of Rules that Enable Lawyers to Serve Self-Represented Litigants, A White Paper, ABA Standing Committee on the Delivery of Legal Services (August 2014)

Handbook on Limited Scope Legal Assistance, ABA Section of Litigation (2003).

Reinventing the Practice of Law: Emerging Models to Enhance Affordable Legal Services, Luz Herrera, Editor, ABA Standing Committee on the Delivery of Legal Services (2014)

Report and Recommendations on "Unbundled" Legal Services, Commission on Providing Access to Legal Services for Middle Income Consumers, New York State Bar Association (Dec. 2002).

Report on Limited Scope Legal Assistance with Initial Recommendations, Limited Representation Committee of the California Commission on Access to Justice (Oct. 2001). Appendix

Unbundling Legal Services: A Guide to Delivering Legal Services a la Carte, Forrest S. Mosten, American Bar Association (2000).

Cases

FIA Card Services, N.A. v. Pichette, No. 2012-272-Appeal (R.I. 2015)

The Rhode Island Supreme Court has decided that an attorney's involvement in the preparation of pleadings for a self-represented litigant (ghostwriting) requires full disclosure. This decision was in response to a set of appeals from three attorneys who did not disclose their identities when they authored pleadings on behalf of pro se defendants in three different debt collection cases. The Supreme Court considered (1) whether Rule 11 of the Superior Court Rules of Civil Procedure applies to an attorney who neither signed a pleading nor entered his or her appearance in the case; and (2) whether the anonymous preparation of pleadings for self-represented litigants is a permissible under the Rules of Professional Conduct. Ultimately, the Court found that an attorney "shall not assist a pro se litigant with the preparation of pleadings, motions, or other written submissions unless the attorney signs the document and discloses thereon his or her identity and the nature and extent of the assistance that he or she is providing to the tribunal and to all parties to the litigation. The attorney shall also indicate on the written document, if applicable, that his or her signature does not constitute an entry of appearance."

In re Fengling Liu, 2nd U.S.Circuit Court of Appeals, No. 09-90006 (2011)
The Committee on Attorney Admission and Grievances recommended an attorney who provided undisclosed ghostwriting services for a pro se litigant receive a public reprimand.  While the Court ultimately found the attorney had committed misconduct related to other issues, it found that the attorney’s ghostwriting did not constitute sanctionable misconduct.  Since no rule or precedent governs attorney ghostwriting, the Court found that the attorney did not have an obligation to disclose participation.

Burgess v. Vitola, 2008 WL 821539 (N.C.Super.)
In a legal dispute that surfaced over an alleged invasion of personal property, the plaintiff resided in North Carolina and the defendant resided in California. The defendant filed papers with the assistance of a California attorney but, on record, represented herself. The plaintiff sought recourse, arguing that assistance from counsel amounted to the unauthorized practice of law since the attorney was not licensed in North Carolina. As the Rules of Professional Conduct do not require an attorney who has provided drafting assistance to make an appearance as counsel of record, the court found that it had no authority to sanction the California attorney. It did, however, require that the defendant file an affidavit that she intended to proceed pro se and not seek legal assistance unless the attorney is licensed to practice in North Carolina.

Ellis v. Maine, 448 F.2d 1325, 1328 (1st Cir. 1971)
Pro se petitioner who asserted complete ignorance of the law subsequently presented a brief that was manifestly written by a person with legal knowledge. Court held that a brief prepared in any substantial part by a member of the bar must be signed by that member.

Johnson v. Board of County Comm'rs, 868 F.Supp. 1226 (D. Colo. 1994)
Former sheriff department workers bring sexual harassment suit against county sheriff in his individual and official capacities. Attorney representing sheriff enters limited appearance on behalf of his official capacity. Court finds that attorney cannot enter limited appearance on behalf of sheriff's official capacity. Attorney representing sheriff must act for the entire person, including individual and official capacities. Entering such limited appearance is not competent and zealous representation as required by ethical rules as it leaves officer undefended on individual capacity claims. Court further finds that ghostwriting of documents for pro se litigants may subject lawyers to contempt of court. Ghostwriting gives litigants unfair advantage in that pro se pleadings are construed liberally and pro se litigants are granted greater latitude in hearings and trials. Ghostwriting also results in evasion of obligations imposed on attorneys by statute, code, and rule, and involves lawyers in litigants' misrepresentation of pro se status in violation of ethical rules.

Laremont-Lopez v. Southeastern Tidewater Opportunity Ctr., 968 F.Supp. 1075 (E.D. Va. 1997)
Over a period of time, pro se plaintiffs submitted pleadings that had been written by attorneys pursuant to discrete-task representation contracts. The attorneys did not sign the pleadings, and in most cases did not appear as counsel of record. When ordered to show cause by the court as to why they should not be held in contempt of court, attorneys argued that the professional relationships created with the litigants ended once they had drafted the pleadings. Court held that there was insufficient evidence to show that the attorneys knowingly misled the court or intentionally violated ethical or procedural rules and declined to impose sanctions. However, court stated that the practice of ghostwriting pleadings without acknowledging authorship and without asking court approval to withdraw from representation was inconsistent with Fed. R. Civ. P. 11 and Rule 83.1(G) of the Local Rules for the United States District Court for the Eastern District of Virginia. Court stated that allowing attorneys to ghostwrite pleadings for pro se plaintiffs abused additional leeway given to pro se filings.

Wesley v. Don Stein Buick, Inc., 987 F.Supp. 884 (D.Kan. 1997)
In suit brought by pro se plaintiff, defendants sought order requiring plaintiff to disclose whether she was an attorney or received the assistance of a lawyer. In expressing legal and ethical concerns regarding the ghostwriting of pleadings by attorneys, the court held the defendants were entitled to the order.

U.S. v. Eleven Vehicles, 966 F.Supp. 361 (E.D.Pa. 1997)
Court finds that ghostwriting by attorney for a pro se litigant implicates an attorney's duty of candor to the court, interferes with the court's ability to supervise the litigation, and misrepresents the litigant's right to more liberal construction as a pro se litigant.

Ricotta v. California, 4 F.Supp.2d 961 (S.D. Cal. 1998)
Attorney licensed in the State of California did not violate procedural, substantive, and professional rules of a federal court by lending some assistance to friends, family members, and others with whom she shared specialized knowledge. Attorney performed research and prepared rough drafts of portions of pro se litigant's pleadings in an action against various official defendants, but did not sign the documents. Because attorney did not gather and anonymously present legal arguments with the actual or constructive knowledge that plaintiff would use them in court, and because attorney did not engage in extensive, undisclosed participation that permitted plaintiff to falsely appear as being without professional assistance, attorney had notviolated any rules.

Ostrovsky v. Monroe (In re Ellingson), 230 B.R. 426 (Bankr.D.Mont. 1999)
Paralegal who helped a business draft and file bankruptcy papers was found to be engaged in the unauthorized practice of law. Court notes that if an attorney acted in the same manner as paralegal, that person would be guilty of "ghost writing," which is described as the act of undisclosed attorney who assists a self-represented litigant by drafting his or her pleadings as part of "unbundled" or limited legal services. Court also notes that ghostwriting violates court rules, particularly Fed.R.Civ.P. 11, as well as ABA Standing Committee Opinion 1414 in Ethics and Professional Responsibility.

Ostevoll v. Ostevoll, 2000 WL 1611123 (S.D. Ohio)
Respondent argues that the Petition should be stricken pursuant to Fed.R.Civ.P. 11 because, although allegedly filed pro se, petitioner clearly received substantial assistance from counsel in the preparation and filing of the Petition. Court finds that if a pleading is prepared in any substantial part by a member of the bar, it must be signed by that attorney to avoid misrepresentation.

Duran v. Carris, 238 F.3d 1268 (10th Cir. 2001)
Lawyer participated in ghostwriting appellate brief for a pro se litigant. Court holds that participation by an attorney in drafting otherwise pro se appellate brief is per se substantial legal assistance, and must be acknowledged by signature. An attorney must refuse to provide ghostwriting assistance unless purported pro se client specifically commits to disclose attorney's assistance to the court upon filing.

Court Rules

Alabama

Alabama Rule of Civil Procedure 11 establishes procedures for preparing pleadings in the limited scope representation context.

California

California Family and Juvenile Rule 5.70 allows a lawyer to draft documents in family law proceedings without disclosing the assistance, as long as the attorney is not making an appearance in the case.

California Civil Rule 3.37 allows a lawyer to draft documents in civil proceedings without disclosing the assistance, as long as the attorney is not making an appearance in the case.

Colorado

Colorado Rule of County Court 311(b), requires attorneys to include their name, address, telephone and registration number on prepared documents, but clarifies that doing so does not create an entry of appearance or authorize service on the attorney. It allows the attorney to rely upon the self-represented party’s representation of the facts.

Colorado Rule of County Court 11(b), requires attorneys to include their name, address, telephone and registration number on prepared documents, but clarifies that doing so does not create an entry of appearance or authorize service on the attorney. It allows the attorney to rely upon the self-represented party’s representation of the facts.

Florida

Comment to Florida Rule of Professional Conduct 1.2, indicates that a lawyer is not required to sign pleadings prepared for pro se litigants; the lawyer must instead include, on each pleading, the statement “Prepared with the Assistance of Counsel.”

Florida Family Law Rule of Procedure 12.040(d) requires pleadings filed by pro se litigants, and prepared with the assistance of an attorney, to contain a certification that the party received assistance from an attorney.

Florida Family Law Rule of Procedure 12.040(e) requiring an attorney who has filed a limited appearance to include specific language on pleadings filed with the court.

Florida Family Law Rule of Procedure 12.040(f) governing service in conjunction with limited appearances, and requiring that all pleadings or other documents and all notices of hearings be served upon both the attorney and the party.  When the attorney receives a notice of a hearing that is outside the scope of the representation, it instructs the attorney to notify the court and opposing party that the attorney will not attend proceeding or hearing.

Illinois

Illinois Supreme Court Rule 137 makes it clear that an attorney may assist a person who is representing him or herself in drafting or reviewing a pleading or other paper without making a general or limited scope appearance and without the attorney signing the pleading or other paper, as otherwise would be required.

Iowa

Iowa Rules of Civil Procedure addressing document preparation include:

  • Rule 1.423(1), requiring every pleading or paper that is prepared with the drafting assistance of an attorney to state that fact before the signature line at the end of the document while also requiring the document to contain the attorney’s name, personal identification number – but not the attorney’s signature;
  • Rule 1.423(2) allowing the attorney providing drafting assistance to rely on the pro se party’s representation of the facts; and
  • Rule 1.423(3) clarifying that providing identifying information on pleadings or papers does not constitute an entry of appearance and does not authorize service on the attorney;

Kansas

Kansas Supreme Court Rule 115A(c) allowing an attorney to assist in the preparation of pleadings as long as "prepared with assistance of a Kansas licensed attorney" is inserted at the bottom of the paper. The attorney is not required to sign the paper.

Maine

Maine Rule of Civil Procedure 11(b) requiring an attorney signature on documents filed as part of a limited appearance.

Massachusetts

Supreme Judicial Court Order In Re: Limited Assistance Representation  allows an attorney to assist in preparing a pleading, motion or other document as long as the phrase “ Prepared with the Assistance of Counsel” is included on the document.

Mississippi

Mississippi Rules of Professional Conduct Comment to Rule 1.2(c) indicating that lawyers may provide counseling, advice, draft letters or pleadings, with or without appearing as counsel of record.

Missouri

Missouri Rule of Civil Procedure 55.03 addresses document preparation and includes:

  • Rule 55.03(a) permitting a lawyer to draft pleadings or motions for self represented litigants without signing the documents; and
  • Rule 55.03(c) permitting a lawyer who assists with drafting to rely on the self-represented party’s representation of facts. 

Montana

Montana Rule of Civil Procedure 11 permits an attorney to draft a document without signing it and allows the attorney who assists with drafting to rely on the self-represented party's representation of facts.

Nebraska

Nebraska Rules of Professional Conduct RPC 501.2(c) permits a lawyer to prepare court filings for pro se litigants so long as the filings include “Prepared By” with the name, business address and bar number of the attorney. It clarifies that such disclosure does not create an entry of appearance while also requiring the pro se litigant to sign the filing.

Nebraska Court Rule of Pleading in Civil Cases 6-1111(b) permitting attorneys who do not appear as attorney of record to prepare pleadings, briefs and other documents to be filed with the court as long as the filings include the "Prepared By" along with identifying information, and clarifying that doing so does not create an appearance by the lawyer.

Nevada

Rules of Practice of the Eighth Judicial District Court of the State of Nevada, Rule 5.28 requires an attorney who offers limited scope representation to include that limitation on the first paragraph of the first paper or pleading filed on behalf of the client.

New Hampshire

New Hampshire Rules of Civil Procedure RCP 17(g) permits an attorney to prepare documents without signing them so long as the statement “This pleading was prepared with the assistance of a New Hampshire attorney” appears on the document.

New Mexico

New Mexico Rules of Civil Procedure 3-107(C) permitting limited appearances in metropolitan courts as long as the attorney files a limited entry of appearance that identifies the nature of the limitation and notes the limitation in the signature block of any paper filed with the court.

Oregon

Oregon Uniform Trial Court Rule 2.010(7) requires a pro se litigant to file a Certificate of Document Preparation, disclosing whether he or she had paid assistance from a lawyer in selecting or completing a pleading.

Form 2.010.7 Certificate of Document Preparation provides a court approved form that is required to accompany any document not bearing the name and bar number of an attorney.

Tennessee

Tennessee Rule of Civil Procedure 5.02 governs the requirements in service and filing of pleadings and other papers in the limited scope representation context.

Washington

Washington Civil Rule 11, permits a lawyer who assists with drafting to rely on the self-represented party's representation of facts.

Washington Civil Rule of Limited Jurisdiction 11, permits a lawyer who assists with drafting to rely on the self-represented party's representation of facts.

Wisconsin

Wisconsin Supreme Court Rule 1.2 (cm) governing ghostwriting, requiring that filings include "this document was prepared with the assistance of a lawyer," and providing that such actions do not constitute an appearance.

Wisconsin Supreme Court Rule 3.1 (am) governing meritorious claims and contentions and permitting a lawyer who assists with drafting to rely on the self-represented party’s representation of facts.

Wisconsin Statute 802.05 (2m) governing ghostwriting, providing that the attorney is not required to sign the document, requiring that it must contain the statement "this document was prepared with the assistance of a lawyer" (802.05(2m) for briefs), and permitting a lawyer who assists with drafting to rely on the self-represented party’s representation of facts.

Wyoming

Rule of Professional Conduct 1.2[7] requires documents prepared by attorneys to include a statement indicating that the document was prepared with the assistance of counsel, along with the name and address of the attorney, and clarifies that such a statement does not constitute an entry of appearance.

The Uniform Rule of the District Court of the State of Wyoming 102(a)(1)(B)  clarifies that an attorney who has assisted in the preparation of a pleading and whose name appears on the pleading shall not be deemed to have entered an appearance in the matter.

Ethics Opinions

ABA Formal Opinion 07-446 (2007)
A lawyer may provide legal assistance to litigants appearing before tribunals "pro se" and help them prepare written submissions without disclosing or ensuring the disclosure of the nature or extent of such assistance.

Alabama

Alabama State Bar Ass’n Ethics Op. 2010-01
The Alabama Rules of Professional Conduct allow a lawyer to limit the scope of the representation. Ordinarily, a lawyer is not required to disclose drafting assistance to the court.

Arizona

Arizona State Bar Ass’n Op. 06-03 (2006)
An attorney who limits the scope of representation and coaches the client or ghost writes papers must direct the client to be truthful and candid in the client’s activities.  While an attorney is not required to disclose to opposing counsel that the attorney is providing limited-scope representation, the attorney must maintain client confidentiality if doing so.

California

Orange County Bar Association Formal Opinion 2014-1 (Ghostwriting by Contract Lawyers and Out-of-State Lawyers)
A lawyer may use another contract lawyer or out-of-state lawyer to ghostwrite court documents without having to disclose that assistance to the court.

Los Angeles Cnty Bar Ass'n Prof. Resp. and Ethics Comm. Ethics Op. 502 (1999)
Attorneys may limit scope of representation of a litigation client to consultation, preparation of pleadings to be filed by client, and participation in negotiations, as long as client consents to the limitation in advance. Attorney must still tell the client about reasonably apparent legal problems even if they fall outside the scope of representation.

Delaware

Delaware State Bar Ass'n Comm. On Prof. Ethics Op. 1994-2
A legal services organization may properly limit its involvement in matters to advice and document preparation, but must disclose any significant assistance it provides to an otherwise pro se litigant. If it prepares pleadings or other documents, or provides advice or assistance on an ongoing basis, it should disclose the extent of its involvement.

Florida

Florida State Bar Ass'n Op. 79-7 (Reconsideration 2000)
Any pleadings or other papers prepared by an attorney and filed with the court on behalf of a pro se litigant must clearly indicate that the litigant was aided by an attorney. Specifically, such filings should state, "Prepared with Assistance of Counsel."

Illinois

Illinois State Bar Ass’n Prof. Conduct Comm. Op. 04-03
A lawyer who mediated a divorce settlement between unrepresented husband and wife may not prepare a proposed judgment of dissolution of marriage, a marriage separation agreement and joint parenting agreement for husband and wife and allow husband and wife to file said documents as pro se litigants.

Illinois State Bar Ass’n Prof. Conduct Comm. Op. 94-01
A lawyer aids in the unauthorized practice of law, and may violate rules pertaining to confidentiality, conflicts, and the duty to communicate with and explain matters to a client, by limiting his role in a real estate transaction to the drafting of documents and delegating the gathering and dissemination of information, the resolution of problems arising from such the documents drafted, and other problems which may arise at the closing, to the real estate broker.

Iowa

Iowa State Bar Ass'n Op. 96-31 (1997)
An attorney may draft a dissolution petition without charge for an indigent client who wishes to proceed pro se where the attorney indicates on the petition that he or she drafted it. As long as the court is informed of the lawyer who prepared the pleading, no ethical violation would occur and it would not be improper.

Iowa State Bar Ass'n Op. 94-35 (1995)
Ghostwriting that represents pleadings to be pro se is a deception on the court when it is in fact a product of the lawyer "who is counseling the party and not accepting the inherent lawyer responsibilities to the court and to the law."

Kansas

Kansas Ethics Opinion No. 09-01
An attorney may offer limited scope representation.  Any lawyer who prepares a pleading for an otherwise pro se litigant must disclose such assistance, including the phrase “Prepared with Assistance of Counsel” on the pleading. The attorney need not provide identifying information such as name, bar number or address.

Kentucky

Kentucky Bar Ass'n Op. E-343 (1991)
A lawyer may limit his or her undertaking and provide assistance in preparation of initial pleadings. However, the lawyer should not aid a litigant in the deception that the litigant is not represented when, in fact, the litigant is represented behind the scenes.

Massachusetts

Massachusetts Bar Ass'n Committee on Professional Ethics, Op. 98-1 (1998)
An attorney may provide limited background advice and counseling to pro se litigants. However, providing more extensive services, such as drafting pleadings, i.e., ghostwriting, would usually be misleading to the court and other parties and therefore would be prohibited.

Michigan

State Bar of Michigan Op. RI-347 (2010)
An attorney may assist a pro se litigant by giving advice or preparing documents as long as the attorney complies with the Michigan Rules of Professional Conduct.  An attorney who assists a pro se litigant is not required to appear in any proceeding and is not required to disclose the assistance to the court or opposing counsel.

Nevada

State Bar of Nevada Formal Ethics Opinion No. 34 (2006, Revised 2009)A lawyer who provides substantial assistance to a self-represented litigant must disclose such assistance to the court. The lawyer’s identity must be disclosed by signing all papers filed with the court for which the lawyer gave substantial assistance to the pro se litigant, by drafting or otherwise. In non-litigation settings, any attorney that provides substantial assistance to a pro se litigant must disclose such assistance, in writing, to the opposing party.

New York

New York County Law Association Committee on Professional Ethics Op. 742 (2010)
It is ethically permissible for an attorney to prepare pleadings and other submissions for pro se litigants. Lawyers are not required to disclose such assistance, except in certain, limited situations.

North Carolina

North Carolina State Bar Formal Op. 3 (2008)
A lawyer may assist a pro se litigant by drafting pleadings and giving advice without making an appearance in the proceeding and without disclosing or ensuring the disclosure of his assistance to the court unless required to do so by law or court order.

North Carolina State Bar Op. 6 (2002)
A lawyer may not represent one party in a divorce and prepare pleadings for the other (pro se) party to sign, regardless of the willingness of the parties.

South Carolina

South Carolina Bar Ethics Advisory Op. 90-18
A lawyer may draft and submit a responsive pleading and waiver of appearance on behalf of an opposing party in a divorce action while representing the interest of his or her own client when he or she determines that the preparation and submission of the pleadings does not constitute representation.

Tennessee

Bd. of Prof. Resp. of the Sup. Ct. of Tenn. Op. 2007-F-153
An attorney may prepare pleadings for a pro se litigant without disclosing the name of the attorney on the pleading in circumstances where doing so allows the pro se litigant to protect his or her claim or matter from being barred by a statute of limitation, administrative rule or other proscriptive rule where the assisting attorney will not provide further assistance. An attorney may not prepare pleadings and other legal documents to assist a pro se litigant in the conduct of his or her litigation where doing so creates the false impression that the litigant is without substantial legal assistance.

Bd. of Prof. Resp. of the Sup. Ct. of Tenn. Op. 2005-F-151
Attorneys may offer limited representation through a pro se clinic if they obtain client’s consent, preferably in writing. Attorneys may draft proceedings for clients, if the attorney notifies the Court that counsel has assisted a pro se litigant. The phrase "Prepared with Assistance of Counsel" is recommended for inclusion on such pleadings in a prominent manner. Attorneys who draft proceedings need not appear and represent the client.

Utah

Utah State Bar Ethics Advisory Op. Comm. Op. 08-01 (2008)
A lawyer may provide legal assistance to litigants appearing before tribunals pro se and help them prepare written submissions without disclosing or ensuring the disclosure to others of the nature or extent of such assistance. Undertaking to provide limited legal help does not generally alter any other aspect of the attorney’s professional responsibilities to the client.

Utah State Bar Ethics Advisory Op. Comm. Op. 02-10 (2002)
It is permissible for an attorney to review the contents of a divorce agreement resulting from mediation on behalf of one party and inform that party about the options and advisability of the agreement. However, it is inappropriate for an attorney to limit his or her services to assisting in the drafting of pleading and failing to advise about the relevant law.

Viriginia

Standing Comm. On Legal Ethics, Virginia State Bar Ass'n Legal Ethics Op. 1761 (2002)
Legal aid staff may provide legal forms to pro se litigants, so long as no assistance is provided in the completion of those forms.

Standing Comm. On Legal Ethics, Virginia State Bar Ass'n Legal Ethics Op. 1127 (1988)
It is ethically permissible for a lawyer to advise and assist a pro se litigant and provide: general legal advice, recommendations for a course of action to follow discovery, legal research, and redrafting of documents prepared by the pro se litigant. A lawyer may prepare discovery requests, pleadings or briefs for signature by the pro se litigant. However, failure to disclose that the attorney provided active or substantial assistance may constitute a misrepresentation to the court.

Washington

Washington State Bar Ass'n Informal Ethics Op. 1763 (1997)
Unbundled legal services is defined as a party engaging an attorney to take limited measures, such as helping prepare initial pleadings and perform child support calculations, without either the lawyer or the client being obligated to the other for the duration of the proceedings.

West Virginia

West Virginia Lawyer Disciplinary Board L.E.O 2010-01
Ghostwriting is permissible under the West Virginia Rules of Professional Conduct as long as a lawyer discloses his or her identity when preparing documents and pleadings filed before a tribunal.  A lawyer must follow procedures to ensure that the client is fully aware of and consents to the specific limitations and possible ramifications.

Wisconsin

State Bar of Wisconsin Formal Opinion E-97-1
A lawyer may limit the scope of representation, after client consultation, to the preparation of deed and transfer return. When the scope of representation is limited in this way, it is the lawyer's responsibility to insure that the client understands and accepts the limited nature of the representation. A lawyer who limits the scope of representation to the drafting of deeds and transfer returns does not solely by that limitation assist a title company in the unauthorized practice of law.