Tag: Judicial Employee

Dishonesty in Public Service: Perpetual Disqualification Despite Prior Offense

The Supreme Court affirmed the dismissal of Sarah P. Ampong, a Court Interpreter III, due to dishonesty for impersonating another individual in a civil service exam prior to her employment in the judiciary. The Court emphasized that dishonesty, even if committed before joining the judiciary, renders an employee unfit for public service. This decision underscores the principle that integrity is paramount in public office, leading to the forfeiture of benefits and perpetual disqualification from government employment, reinforcing the high ethical standards expected of judicial employees.

When a Civil Service Exam Impersonation Costs a Career: The Ampong Case

This administrative case originated from a letter by Executive Judge Jaime L. Infante, inquiring about the employment status of Sarah P. Ampong. Despite Ampong’s dismissal from service by the Civil Service Commission (CSC), which was affirmed by the Supreme Court, the Regional Trial Court (RTC) continued to pay her salary. The CSC had previously found Ampong guilty of dishonesty for impersonating Evelyn B. Junio-Decir in the 1991 Civil Service Eligibility Examination for Teachers. This led to her dismissal from service, along with the revocation of her Professional Board Examination for Teachers (PBET) rating.

Ampong contested the CSC’s jurisdiction, arguing that she was already employed in the judiciary when the administrative case was filed. The Court of Appeals (CA), however, rejected this argument, noting that Ampong only raised the jurisdictional issue after the CSC ruled against her, estopping her from challenging it. The Supreme Court upheld the CA’s decision in G.R. No. 167916, affirming Ampong’s dismissal. Despite this ruling, the Financial Management Office (FMO) of the OCA continued to release Ampong’s salaries and allowances until Judge Infante’s letter prompted them to withhold her payments.

In her defense, Ampong requested the Court to revisit its ruling, citing potential complications in its enforcement. She reiterated her argument that the CSC lacked jurisdiction over her case. The Office of the Court Administrator (OCA) recommended Ampong’s dismissal, emphasizing that her act of impersonation constituted dishonesty, a grave offense warranting dismissal from service. The OCA argued that Ampong’s appointment as Court Interpreter III did not strip the CSC of its power to discipline government employees, and the CSC’s ruling effectively disqualified her from holding the position.

The central issue before the Court was whether Ampong had been effectively dismissed from her position as Court Interpreter III. The Court resolved the issue in the affirmative, citing its previous decision in the August 26, 2008 ruling, which found Ampong administratively liable for dishonesty. The Court quoted its earlier decision, emphasizing that Ampong’s impersonation of Decir in the PBET exam constituted dishonesty, rendering her unfit to be a judicial employee. The Court further noted that Ampong should not have been appointed as a judicial employee had her cheating been known.

The Court also addressed Ampong’s jurisdictional concerns, reaffirming the CSC’s authority over civil service examinations and the Supreme Court’s exclusive administrative supervision over all courts and judicial personnel. The Court clarified that administrative jurisdiction over a court employee belongs to the Supreme Court, regardless of whether the offense was committed before or after employment in the judiciary. Citing Civil Service Commission v. Sta. Ana and Bartolata v. Julaton, the Court highlighted its authority to oversee judicial employees’ compliance with laws and regulations.

The doctrine of immutability of judgment prevents the modification or reversal of a final decision, even if it contains errors of fact or law. This principle prevents Ampong from seeking a reversal of the August 26, 2008 Decision. Consequently, the penalty of dismissal from service for dishonesty must be enforced. Section 58(a) of the Uniform Rules on Administrative Cases in the Civil Service (URACCS) outlines the administrative disabilities that accompany dismissal, including the cancellation of civil service eligibility, forfeiture of retirement benefits, and perpetual disqualification from re-employment in government service.

However, the Court clarified that Ampong is entitled to her accrued leave credits, if any, as the URACCS does not include forfeiture of leave credits as part of the penalty. Government employees are entitled to the leave credits earned during their employment, and these may not be deprived despite dismissal. This ruling emphasizes the importance of integrity, uprightness, and honesty for every Judiciary employee, both in their official duties and personal dealings. The image of the court is reflected in the conduct of its personnel, and Ampong failed to meet the stringent standards set for judicial employees.

FAQs

What was the key issue in this case?	The key issue was whether Sarah P. Ampong should be dismissed from her position as Court Interpreter III due to dishonesty for impersonating another person in a civil service exam prior to her employment in the judiciary.
What was Ampong’s offense?	Ampong impersonated Evelyn B. Junio-Decir in the 1991 Civil Service Eligibility Examination for Teachers, which constitutes dishonesty under civil service rules.
Did the Civil Service Commission (CSC) have jurisdiction over Ampong’s case?	Yes, the Supreme Court affirmed that the CSC had jurisdiction over Ampong’s case, even though she was already employed in the judiciary when the administrative case was filed.
What is the doctrine of immutability of judgment?	The doctrine of immutability of judgment states that a final decision can no longer be modified or reversed, even if it contains errors of fact or law.
What penalties are associated with dismissal from service due to dishonesty?	The penalties include cancellation of civil service eligibility, forfeiture of retirement benefits (except accrued leave credits), and perpetual disqualification from re-employment in government service.
Is Ampong entitled to any benefits despite her dismissal?	Yes, Ampong is entitled to her accrued leave credits, if any, as these are not forfeited under the Uniform Rules on Administrative Cases in the Civil Service (URACCS).
Why is honesty important for judicial employees?	Honesty is crucial because judicial employees represent the integrity of the court system, and their conduct reflects on the court’s reputation and standing.
What rule covers administrative cases in Civil Service?	The Uniform Rules on Administrative Cases in the Civil Service (URACCS)

This case reinforces the judiciary’s commitment to upholding the highest standards of integrity and honesty among its employees. The decision serves as a reminder that acts of dishonesty, regardless of when they were committed, can have severe consequences for public servants. The ruling not only impacts Ampong’s career but also sets a precedent for future cases involving similar acts of dishonesty within the government service.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

June 4, 2014

Upholding Ethical Conduct: When a Clerk of Court Oversteps Authority

In Leyrit v. Solas, the Supreme Court addressed the administrative liabilities of a Clerk of Court who notarized documents beyond the scope of their official duties and exhibited unbecoming behavior towards subordinates. The Court emphasized that while Clerks of Court are notaries public ex officio, this authority extends only to matters related to their official functions. The decision underscores the importance of maintaining proper decorum and ethical standards within the judiciary, ensuring that court personnel act with respect and integrity in their interactions with colleagues and the public.

Beyond the Bench: Can Court Clerks Wield Notarial Powers at Will?

This case revolves around two administrative complaints filed against Nicolasito S. Solas, the Clerk of Court IV of the Municipal Trial Court in Cities (MTCC), Iloilo City. Multiple employees accused him of various offenses, including dishonesty, abuse of authority, and conduct unbecoming a public official. These accusations stemmed from Solas’s alleged unauthorized notarization of documents, mistreatment of subordinates, and other questionable practices within the office. The central legal question is whether Solas exceeded his authority as Clerk of Court and violated the ethical standards expected of judicial employees.

The complainants alleged that Solas notarized documents unrelated to his official functions and charged fees without proper accounting. They also claimed that he acted arrogantly, shouted at subordinates, and created a hostile work environment. Further accusations included allowing his personal lawyer to use office resources, engaging in improper relationships with lending institutions, and ordering security guards to monitor employees. Solas defended his actions by arguing that he mistakenly believed some documents required only a jurat, and that the complainants were motivated by personal animosity due to previous administrative cases he had filed against them and their associates.

The Supreme Court, after reviewing the findings of the Investigating Judge and the Office of the Court Administrator (OCA), focused on two key violations committed by Solas. First, the Court addressed the issue of unauthorized notarization, referencing Section 41 of the Administrative Code of 1987, as amended by Republic Act No. 6733, which outlines the officers authorized to administer oaths. This section includes “clerks of court” without specifying the court level, leading to the interpretation that all clerks of court can administer oaths on matters involving official business. However, the Court clarified that while clerks of court are notaries public ex officio, their notarial powers are limited to matters directly related to their official functions. The Court emphasized this point, stating:

Clerks of court are notaries public ex officio and, thus, may notarize documents or administer oaths, but only when the matter is related to the exercise of their official functions. Clerks of court should not in their ex-officio capacity take part in the execution of private documents bearing no relation at all to their official functions.

Solas’s actions, such as notarizing sworn applications for Mayor’s permits and other private documents, clearly exceeded this limited authority. The Court dismissed his defense of mistaking oaths for jurats, highlighting his legal background and the clear distinction between the two acts. The Court also noted that he had been previously penalized for similar conduct in A.M. No. P-01-1484, although it refrained from imposing an additional penalty for the same notarial services to avoid double jeopardy.

Building on this principle, the Court then examined Solas’s behavior towards his subordinates. The complainants testified that he shouted at them, used offensive language, and created a hostile work environment. The Court found these actions to be unbecoming of a court employee, who is expected to maintain proper decorum and treat colleagues with respect. The Court cited Villaros v. Orpiano, where it stressed that:

The behavior of all employees and officials involved in the administration of justice, from judges to the most junior clerks, is circumscribed with a heavy responsibility. Their conduct must be guided by strict propriety and decorum at all times in order to merit and maintain the public’s respect for and trust in the judiciary.

The Court emphasized that high-strung and belligerent behavior has no place in government service, especially within the judiciary. Solas’s failure to foster harmony and cooperation within the office, and his unequal treatment of subordinates, demonstrated a lack of the professionalism expected of a Clerk of Court. The Court concluded that these actions constituted simple misconduct, defined in Office of the Court Administrator v. Judge Fernandez as any unlawful conduct prejudicial to the rights of parties or to the right determination of the cause.

In light of Solas’s compulsory retirement, the Court could not impose a suspension. Instead, it ordered him to pay a fine equivalent to three months’ salary, to be deducted from his retirement benefits. The Court dismissed the remaining charges of dishonesty, willful violation of office regulations, violation of the Anti-Graft and Corrupt Practices Act, and nepotism, due to a lack of substantial evidence.

FAQs

What was the key issue in this case?	The key issue was whether Nicolasito S. Solas, as Clerk of Court, exceeded his authority and violated ethical standards through unauthorized notarization and unbecoming conduct towards subordinates.
Can Clerks of Court notarize any document?	No, Clerks of Court are notaries public ex officio, but their notarial powers are limited to matters related to their official functions. They cannot notarize private documents unrelated to their duties.
What constitutes simple misconduct for a court employee?	Simple misconduct involves any unlawful conduct prejudicial to the rights of parties or the right determination of a cause. This includes actions that fail to uphold the standards of propriety and decorum expected of judicial employees.
What penalty was imposed on Solas?	Due to his compulsory retirement, Solas was ordered to pay a fine equivalent to three months’ salary, deducted from his retirement benefits, instead of a suspension.
What is the significance of this ruling?	This ruling reinforces the importance of ethical conduct and adherence to legal limitations for court personnel. It clarifies the scope of notarial powers for Clerks of Court and emphasizes the need for respectful treatment of colleagues.
What is the Administrative Code of 1987?	The Administrative Code of 1987 is a codified set of laws governing the structure, functions, and responsibilities of various government agencies in the Philippines. Section 41 outlines who is authorized to administer oaths.
What is a notary public ex officio?	A notary public ex officio is someone who holds notarial powers by virtue of their office. Clerks of Court are considered notaries public ex officio, but their powers are limited to matters related to their official functions.
What other charges were filed against Solas?	Other charges included dishonesty, willful violation of office regulations, violation of the Anti-Graft and Corrupt Practices Act, and nepotism. However, these charges were dismissed due to a lack of substantial evidence.

The Supreme Court’s decision in Leyrit v. Solas serves as a reminder to all court employees of the importance of ethical conduct, adherence to legal boundaries, and respectful treatment of colleagues. It reinforces the principle that public office is a public trust, and that those who serve within the judiciary must uphold the highest standards of integrity and professionalism.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: JOANA GILDA L. LEYRIT, ASUNCION ESPINOSA, MARY ANN LASPIÑAS, NATIVIDAD SULLIVAN, ELENA MOLARTE SOLAS, JULIE FELARCA AND RENE F. GANZON, COMPLAINANTS, VS. NICOLASITO S. SOLAS, CLERK OF COURT IV, MUNICIPAL TRIAL COURT IN CITIES (MTCC), ILOILO CITY,RESPONDENT., A.M. No. P-08-2567, October 30, 2009

October 30, 2009

Jurisdiction and Estoppel: CSC’s Authority Over Judicial Employees’ Prior Misconduct

The Supreme Court ruled that while the Civil Service Commission (CSC) generally lacks administrative jurisdiction over judicial employees, an individual’s prior actions can prevent them from challenging CSC jurisdiction. This means that if a person fully participates in CSC proceedings, admits guilt, and seeks leniency, they cannot later argue that the CSC lacked the power to hear their case. The decision underscores the importance of raising jurisdictional challenges early in legal proceedings and reinforces the principle that individuals should not benefit from inconsistent legal positions. It impacts civil servants transitioning to the judiciary, ensuring accountability for past actions.

Can a Court Employee Escape Past Sins? The Case of the Exam Impersonator

Sarah Ampong, a court interpreter, faced administrative charges by the Civil Service Commission (CSC) for actions committed before her appointment to the judiciary. The charge stemmed from a 1991 incident when Ampong, then a public school teacher, impersonated another individual, Evelyn Decir, in a Professional Board Examination for Teachers (PBET). Years later, in 1994, the CSC initiated proceedings against Ampong and Decir for dishonesty, grave misconduct, and conduct prejudicial to the best interest of the service. Ampong voluntarily appeared before the CSRO and admitted to the wrongdoing, even waiving her right to counsel. Based on her admission, the CSC found Ampong guilty of dishonesty and dismissed her from service. Only then did Ampong challenge CSC’s jurisdiction, arguing that as a judicial employee, she was subject to the Supreme Court’s exclusive disciplinary authority.

The Court of Appeals (CA) upheld the CSC’s decision, citing Ampong’s active participation in the proceedings and her failure to raise the jurisdictional issue earlier. The CA reasoned that Ampong was estopped from questioning the Commission’s jurisdiction. The Supreme Court agreed that, generally, it has exclusive administrative supervision over all courts and judicial personnel. It acknowledged its previous rulings stating that impersonating an examinee of a civil service examination is an act of dishonesty and that the CSC typically files the necessary charges before the Office of the Court Administrator (OCA) in cases involving judicial employees.

The Supreme Court addressed the question of which body has jurisdiction when the offense occurred before the employee joined the judiciary. It emphasized that jurisdiction is determined by the law in force at the time the action is instituted, not when the offense was committed. Thus, the administrative jurisdiction over Ampong technically belonged to the Supreme Court because the action was initiated by the CSC when Ampong was already a judicial employee. Even so, the Supreme Court invoked the principle of estoppel against Ampong. Estoppel prevents a party from denying a previously affirmed jurisdiction, especially after seeking affirmative relief. Ampong participated fully in the CSC proceedings, admitted her guilt, and even sought leniency.

The Court emphasized that a party cannot adopt a different legal theory on appeal to challenge the court’s jurisdiction. It highlighted that administrative proceedings do not require assistance of counsel as much as police custodial investigations do. Here, Ampong freely admitted her guilt to the CSC without any coercion. The Supreme Court stressed that Ampong’s dishonest act rendered her unfit to be a judicial employee. Finally, it affirmed its commitment to upholding the integrity of the judiciary, stating that no act diminishing public faith in the judiciary would be tolerated. In doing so, it reinforced the standard for conduct of all people connected with the court as stewards of the temple of justice.

FAQs

What was the key issue in this case?	The key issue was whether the Civil Service Commission (CSC) had administrative jurisdiction over a judicial employee for acts of dishonesty committed before her appointment to the judiciary.
What did the Supreme Court rule?	The Supreme Court ruled that while the CSC generally lacks jurisdiction over judicial employees, the petitioner was estopped from challenging the CSC’s jurisdiction due to her participation in the proceedings and admission of guilt.
What is the principle of estoppel?	Estoppel is a legal principle that prevents a party from denying something they previously affirmed, especially if another party has acted upon that affirmation to their detriment.
Why was the petitioner estopped in this case?	The petitioner was estopped because she voluntarily participated in the CSC proceedings, admitted her wrongdoing, and sought leniency, only to later challenge the CSC’s jurisdiction after an unfavorable ruling.
Does this ruling mean the CSC always has jurisdiction over judicial employees?	No, the ruling clarifies that the Supreme Court generally has exclusive administrative supervision over judicial employees. However, estoppel can prevent an individual from challenging the CSC’s jurisdiction in specific circumstances.
Is assistance of counsel required in administrative proceedings?	No, unlike criminal proceedings, there is no absolute requirement for assistance of counsel in administrative proceedings.
What was the petitioner’s dishonest act?	The petitioner impersonated another individual in a Professional Board Examination for Teachers (PBET), which constitutes dishonesty under civil service rules.
What is the significance of this ruling?	This ruling reinforces the importance of raising jurisdictional challenges early in legal proceedings and upholds the integrity of the civil service by holding individuals accountable for dishonest acts, even if committed before joining the judiciary.

In conclusion, the Ampong case clarifies the interplay between the CSC’s jurisdiction and the Supreme Court’s administrative supervision over judicial employees. The decision serves as a reminder that active participation in legal proceedings can have significant consequences, particularly when it comes to challenging jurisdiction later on. The Court’s message remains clear for all people connected with the judiciary to abide by a standard of integrity and accountability.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

August 26, 2008

Judicial Employees’ Duty: Prompt Service and Accountability in Court Processes

This case underscores the critical importance of promptness and diligence among court personnel in the Philippines. The Supreme Court held that a process server’s failure to serve summons promptly constitutes simple neglect of duty, warranting disciplinary action. This ruling reinforces the principle that all court employees, regardless of their position, are responsible for upholding the integrity and efficiency of the judicial system, and that delays in essential procedural tasks can have significant consequences.

Delayed Justice: When a Process Server’s Neglect Undermines Court Efficiency

In Atty. Perfecto A.S. Laguio, Jr. v. Mila Amante-Casicas, the central issue revolved around the administrative liability of Mila Amante-Casicas, a process server at the Metropolitan Trial Court of Pasig City, for her delay in serving summons in a civil case. Atty. Laguio filed a complaint, paid the service fee, but the summons was not served for over two months. This delay prompted the attorney to file an administrative complaint, alleging neglect of duty. The Supreme Court addressed whether the process server’s failure to promptly serve the summons constituted simple neglect of duty, warranting disciplinary action.

The facts of the case revealed that Atty. Laguio filed a complaint for sum of money and paid the necessary service fee. When he followed up on the service of summons two weeks later, the respondent, Mila Amante-Casicas, initially claimed that no service fee had been paid. Upon presentation of the official receipt, she assured him that the summons would be served promptly. However, despite repeated follow-ups, the summons was not served, leading Atty. Laguio to file an administrative complaint. In her defense, the respondent claimed that she had eventually served the summons through substituted service but cited her heavy workload as the reason for the delay. The Office of the Court Administrator (OCA) found her explanation insufficient and recommended that she be suspended for simple neglect of duty.

The Supreme Court emphasized the vital role of a process server in the administration of justice. Citing Ulat-Marrero v. Torio, Jr., the Court reiterated that:

A process server should be fully cognizant not only of the nature and responsibilities of his task but also of their impact in the speedy administration of justice. It is through the process server that a defendant learns of the action brought against him by the complainant. More importantly, it is through the service of summons of the process server that the trial court acquires jurisdiction over the defendant. As a public officer, the [process server] is bound virtute oficii to bring to the discharge of his duties the prudence, caution, and attention which careful men usually exercise in the management of their affairs.

The Court found that the respondent’s failure to promptly serve the summons constituted simple neglect of duty, which is defined as “the failure of an employee to give one’s attention to a task expected of him, and signifies a disregard of a duty resulting from carelessness or indifference” (Dignum v. Diamla, A.M. No. P-06-2166, April 28, 2006, 488 SCRA 405, 415). The Court held that her heavy workload did not excuse her from fulfilling her primary duty to serve summons promptly. The Court further noted that under the Uniform Rules on Administrative Cases in the Civil Service, simple neglect of duty is classified as a less grave offense, punishable by suspension for the first offense.

The Supreme Court has consistently held that:

heavy work load is, however, not an adequate excuse for him to be remiss in performing his duties as a public servant. Otherwise, every government employee charged with negligence and dereliction of duty would resort to the same convenient excuse to evade punishment, to the great prejudice of public service.

The Court has applied this principle in numerous cases involving administrative lapses by judicial employees. For instance, in Alcover, Sr. v. Bacatan (A.M. No. P-05-2043, December 7, 2005, 476 SCRA 607, 612), a court stenographer’s heavy workload was not accepted as a valid excuse for delaying the transcription of stenographic notes. Similarly, in Salvador v. Serrano (A.M. No. P-06-2104, January 31, 2006, 481 SCRA 55, 71), the Court emphasized that public servants must prioritize their duties despite a heavy caseload.

The Court’s decision underscores the judiciary’s commitment to maintaining the highest standards of conduct among its employees. By holding the process server accountable for her negligence, the Court reaffirmed the importance of each employee’s role in ensuring the efficient and effective administration of justice. The disciplinary action serves as a reminder to all court personnel that their actions have a direct impact on the public’s perception of the judiciary and that any dereliction of duty will be met with appropriate sanctions.

Building on this principle, the Court emphasized that the image of a court of justice is necessarily mirrored in the conduct of its personnel. This means that every employee, from the judge to the process server, has a duty to maintain the court’s good name and standing as a true temple of justice. In this case, the process server’s failure to promptly serve the summons not only caused inconvenience to the complainant but also undermined public trust in the judicial system.

This approach contrasts with a more lenient view, which might have excused the delay due to the process server’s heavy workload. However, the Court explicitly rejected this justification, emphasizing that every government employee is expected to fulfill their duties diligently, regardless of the challenges they may face. This strict stance reflects the judiciary’s commitment to upholding the highest standards of public service.

The Court’s decision has significant implications for the administration of justice in the Philippines. It reinforces the principle that prompt and efficient service of summons is essential for the timely resolution of cases. It also sends a clear message to all court personnel that they will be held accountable for any negligence or dereliction of duty. This accountability is crucial for maintaining public trust in the judicial system and ensuring that justice is served fairly and efficiently.

The ruling in Laguio v. Amante-Casicas is a stern reminder to all court employees that they are expected to perform their duties with utmost diligence and responsibility. The case highlights the importance of promptness in serving summons and other court processes, and the consequences of failing to do so. By upholding these principles, the Supreme Court aims to maintain the integrity and efficiency of the judicial system, thereby fostering public trust and confidence in the administration of justice.

FAQs

What was the key issue in this case?	The key issue was whether a process server’s failure to promptly serve summons constituted simple neglect of duty, warranting disciplinary action.
What is simple neglect of duty?	Simple neglect of duty is defined as the failure of an employee to give attention to a task expected of them, signifying a disregard of duty resulting from carelessness or indifference.
Can a heavy workload excuse a delay in serving summons?	No, a heavy workload is not an adequate excuse for a process server’s failure to promptly serve summons, as every government employee is expected to fulfill their duties diligently.
What is the significance of a process server in the judicial system?	A process server plays a vital role in the administration of justice by ensuring that defendants are properly notified of the actions filed against them, enabling the court to acquire jurisdiction.
What was the OCA’s recommendation in this case?	The Office of the Court Administrator (OCA) recommended that the respondent be suspended for one month and one day for simple neglect of duty.
What is the penalty for simple neglect of duty under the Uniform Rules on Administrative Cases in the Civil Service?	Under the Uniform Rules on Administrative Cases in the Civil Service, simple neglect of duty is classified as a less grave offense, punishable by suspension for one month and one day to six months for the first offense.
What was the Supreme Court’s ruling in this case?	The Supreme Court found the respondent guilty of simple neglect of duty and suspended her for a period of one month and one day without pay, warning that a repetition of the same or similar offense would be dealt with more severely.
Why is prompt service of summons important?	Prompt service of summons is essential for the timely resolution of cases, as it ensures that defendants are informed of the legal action against them and allows the court to exercise jurisdiction.

In conclusion, the Supreme Court’s decision in Atty. Perfecto A.S. Laguio, Jr. v. Mila Amante-Casicas serves as a crucial reminder of the importance of diligence and accountability among court personnel. The ruling reinforces the principle that all judicial employees, regardless of their position, must perform their duties promptly and efficiently to uphold the integrity of the judicial system.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

August 6, 2007