DANIEL A. MILLER, P.A.

PRIVACY / CONFIDENTIALITY POLICY

Confidentiality Policy

A lawyer's work for a client is confidential. Therefore, all work performed and information received in this office will be considered confidential and shall not be discussed outside this office or with any unauthorized person.

Daniel A. Miller, P.A.’s (the “Firm”) policy is to comply with the rules of professional conduct that impose on lawyers and their staff a duty to preserve and protect confidential information about their clients ("Confidentiality Policy"). Client information should not be disclosed to any person other than to persons in the Firm engaged in the representation of such clients or who otherwise have a legitimate need to know. For this purpose, all information obtained in the course of the representation of a client should be regarded as confidential unless it is, beyond any doubt, widely known and is not detrimental to the client. The Firm's policy covers not only information protected by the attorney-client privilege, but also other information that might be embarrassing or detrimental to the client if disclosed. The duty to preserve confidential information continues after a lawyer or staff member is no longer associated with the Firm.

To implement the Firm's Confidentiality Policy and to safeguard client confidential information, the following should be observed:

1. Avoid Casual Conversation Concerning Client Information. All Firm personnel should refrain from discussing any personal or business matters of the Firm's clients with anyone other than Firm personnel who have a need to know to be able to serve the client's needs. Accordingly, maximum care and circumspection must be used at all times. Conversations in public places, such as restaurants, elevators, and airplanes, should be limited to matters that do not pertain to information of a sensitive or confidential nature. Lawyers and employees of the Firm should be sensitive to the risk of inadvertent disclosure and, for example, should not use a speaker telephone to discuss confidential matters if the conversation could be heard by persons who do not have a need to know, or leave papers or documents where unintended persons could glance at them, or fail to properly dispose of unneeded documents.
2. Specific Security Requirements. The lawyer in charge of a client matter will impose whatever security measures he or she deems necessary and appropriate under the circumstances to minimize the risk of premature or inadvertent disclosure, including protecting the identity of the parties, maintaining in confidence the nature of the matter, or, as necessary, limiting access to the files. In selecting appropriate measures, the lawyer in charge should remember that the goal is to avoid communicating sensitive information to any person, inside or outside the Firm, who does not require access to the information.
3. File and Memoranda Opening.File opening or new-matter memoranda should not disclose sensitive information but should be limited to identifying information and general statements concerning the nature of the representation.
4. Documents.Documents brought into the office or outside the office should be kept in envelopes or folders.
5. Use of Common Sense.Good judgment and care must be exercised at all times to avoid unauthorized or improper disclosures.
6. "Personal" or "Confidential."Envelopes or folders marked "personal" or "confidential" should be opened only by the addressee.
7. Lawyer's Absence.In most cases outsiders should not be advised where a lawyer can be reached (this may well indicate the client and possibly the nature ofthematter being discussed with that client). Normally, stating that the lawyer will be contacted and given the message should be sufficient.
8. Extra Precautions.When particularly sensitive information is involved, the disclosure of which would cause harm or serious embarrassment, additional precautions should be taken (such as sealing the information in an envelope marked "confidential" when transmitting by mail or messenger, inside or outside the office; keeping the information and related word-processing disks or tapes in a locked cabinet or drawer or other secure place; arranging for special handling of files; exercising extra caution when speaking on the telephone to avoid being overheard).

Use of Firm Work Product. Eachmember ofthe Firm,including lawyers, paralegals, secretaries, and all other employees, will treat and hold confidential all lawyer work product information, including, but not limited to, legal brief banks, legal memoranda, office legal forms (including briefs, estate planning documents, business forms, and other lawyer-prepared documents) irrespective of who created, modified, or amended such work product. All work product created, modified, or amended by lawyers, paralegals, secretaries, and others while employed by or acting on behalf of the Firm is considered by the Firm as proprietary work product belonging to the Firm. The use ofsuch work product by anyone for personal purposes, or personal gain, without permission of the shareholders is prohibited.

Office Privacy. At times, lawyers must keep sensitive material that may be of a very confidential nature, regarding the Firm, its personnel, the lawyers themselves, or their clients. To avoid accidental violations of that confidentiality in a lawyer's absence, under no circumstances should a lawyer's office or computer be offered for use to a client, vendor, or other unauthorized person without the direct consent of that lawyer or the lawyer's assistant or, in their absence, William Maguire or Daniel Miller. Whenever possible, all notes, e-mails, faxes, and so on belonging to an absent lawyer should be left with the lawyer's assistant or put in the lawyer's inbox.

Internet, Computer, and Telecommunications Protocols. All lawyers, employees, independent contractors, and others("Users") who use the Firm computer and telecommunications systems and services (“Firm Systems”) have the responsibility to use these Firm Systems in an efficient, effective, ethical, and lawful manner. Therefore each User should be aware of the Firm's expectations regarding the use of the Firm Systems. The following rules and conditions apply to all Users of the Firm Systems, wherever the Users are located.

Firm Systems refer to host computers, files servers, workstations, standalone computers, laptops, software, voice mail, fax transmissions, telephones of any type, and internal or external communications networks providing access to the Internet, commercial online services, bulletin board systems, Internet telephony, forms, instant messaging, and wireless solutions, including but not limited to wireless e-mail, wireless Web browsing, text messaging, and e-mail systems, whether accessed directly or indirectly from the Firm's computer or telecommunications facilities. The term Users as used in this policy refers to all lawyers, employees, independent contractors, and other persons or entities accessing or using the Firm’s computer or telecommunication resources and services.

The term Users as used in this policy refers to all lawyers, employees, independent contractors, and other persons or entities accessing or using the Firm’s computer or telecommunication resources and services.

Business-Only Use. The Firm Systems resources and any information transmitted by, received from, or stored therein or thereon are the sole property of the Firm, and are provided as business tools to be used for legitimate Firm business only. Users may not install software onto their individual computer or the network without first receiving express authorization to do so from Daniel Miller on behalf of the Firm. As a general rule, Firm Systems should not be used for personal reasons, except for in emergencies and in unusual circumstances.

Passwords. Any and all passwords utilized forthe FirmSystemsremain the property ofthe Firm and are only on loan to Firm Users. The User's password must be relinquished to the Firm when requested. Users are responsible for safeguarding their passwords and passwords should not be printed, stored online, or given to others. Users are personally responsible to the Firm for all transactions made using their passwords.

Restricted System Information. Access to information on Firm Systems is limited to those with a need to know. Thus, information from Firm Systems should only be disclosed to authorized personnel. Employees are not permitted to use passwords or retrieve another lawyer's or employee's files or messages other than for legitimate business purposes, and then only after obtaining the express, specific permission of that person. Users also shall not forward e-mail to any other person or entity without the express permission of the sender. To avoid confidential messages being delivered into the wrong hands, Users of e-mail and fax should be very careful when addressing or sending messages. It is easy to address a message to the wrong person (or group of persons). Once sent, a message cannot be stopped from being delivered to the addressed recipient.

Harassment Protections. Users encountering or receiving material that they consider to be harassing must immediately report the incident to Daniel Miller.

Right to Monitor. The Firm reserves the right to monitor Firm Systems(a) in order to investigate or otherwise protect against violations of law or of Firm rules, policies, or requirements; (b) to determine that the Firm Systems are being used appropriately; (c) to accessinformation when a lawyer or employee is not otherwise available; or (d) for repair or maintenance purposes. The existence of passwords, delete functions, or any other functions does not waive this right.

No Privacy. Users have no personal rights in any materials created, received, orsent through the Firm Systems. Anything created on the Firm's computer may be, and likely will be, reviewed by others. These systems are not appropriate mediums for private or confidential information.

Software Use Restrictions. The Firm purchases and licenses the use of various computer software for business purpose and does not own the copyright to this software or its related documentation. Unless authorized by the software developer, the Firm does not have the right to reproduce such software for use on more than one computer. Users may only utilize software on local area networks or on multiple machines according to software license agreements. The Firm prohibits the illegal duplication of software and its related documentation.

Copyright Issues. The Firm Systems may not be used to unlawfully or improperly copy or transmit documents, software, images, or other information protected by copyright. In addition, users must comply with all other state and federal laws governing intellectual property.

Storage Protocols. Computer files, e-mail, and voice-mail messages may be preserved on electronic or other storage media by the Firm for appropriate periods in accordance with its business policies and applicable laws and rules. If the Firm becomes involved in an investigation, litigation, or any other proceeding that may necessitate the review or production of its records, the Firm reserves the right to review the stored messages.

Systems Accessibility Limitations. Just because a User has the ability to do something with Firm Systems does not necessarily mean that he or she has the right to do so. Users should not alter or copy a file that is the work of another user without first obtaining permission from that person. Additionally, a User's ability to connect to other computer systems through the network does not imply a right to do so or to make use of those systems unless specifically authorized by the operators responsible for those systems.

E-mail. E-mail messages may be subject to disclosure pursuant to legal proceedings. Consequently, the same level of care and professionalism should be used in preparing e- mail communications as in other writings.

Individual User Responsibility. The Firm is not responsible for the actions of individual Users.

Discipline. Users who violate the Firm's Internet, computer, and telecommunications protocols as set forth above are subject to discipline up to and including discharge. Also,some violations may result in legal action.