Footnote 21

This injunction is crucial - and often violated. See, e.g., Sue Augustus, Respect Your Clients, 15-May CBA REC. 38, 38 (2001) (most common complaint author hears "is that lawyers do not return their telephone calls, or respond to their letters"). E. Spencer Walton, Jr., Respect and Dignity, 44-Feb. RES GESTAE 5, 5 (2000-2001) ("each of us has been guilty of getting caught up 'in the rat race' or not returning calls on a timely basis"). See also William D. Frumkin, President's Column, NELA: THE NEW YORK EMPLOYEE ADVOCATE, Feb.2004, at I, 12 (recommending that lawyer be proactive in reaching out to the client even when latter's case is dormant).