Sanctions Recommended for Irell & Manella Attorneys Over Altered Document Incident
March 20, 2025, 3:02 pm CDT
This incident highlights ethical responsibilities in legal practice, with an associate modifying a document during a deposition.
A special master has indicated that two lawyers from Irell & Manella should face disciplinary measures following an incident in which a deposition witness was misled by an altered document. The recommended sanctions focus on associate Benjamin Manzin-Monnin, who modified a schematic drawing, and partner Jason Sheasby, who overlooked critical communications about the action.
According to the findings of special master David Folsom dated March 18, Manzin-Monnin altered the date on the schematic to illustrate the unreliability of dates in legal documents. During a deposition, he initially presented the accurate document but later introduced the altered version, subsequently disclosing the modification without marking it formally as an exhibit.
Folsom described the witness’s experience as being “tricked” and “obviously confused” by the line of questioning related to the altered date. Folsom asserted that the manner in which Manzin-Monnin managed the deposition was unethical, emphasizing the obligation lawyers hold to maintain integrity in their practices.
The implications of the incident extend beyond individual sanctions. Folsom has proposed that both Manzin-Monnin and Sheasby participate in an additional 30 hours of ethics education. He also suggested that the firm be responsible for covering costs related to the special master’s proceedings and the sanctions motion. Furthermore, it was recommended that Irell & Manella’s client, CogniPower, lose an hour of trial time in an ongoing patent infringement lawsuit against Samsung Electronics in a federal court in Texas.
The deposition involved a witness who is an executive from a company that purportedly has an invention predating CogniPower’s patents. Prior to the deposition, a member of the firm had advised Manzin-Monnin to seek clear guidance from a senior attorney regarding the adjusted dates on evidence. Manzin-Monnin acknowledged having reached out to Sheasby, who later admitted to missing the relevant email.
In his statement, Sheasby recognized his duty to read all communications but noted that during the deposition, both the correct and altered documents were presented side by side to the witness, eventually revealing the manipulations made. The lack of formal documentation of the alteration did not mitigate the incident’s severity, according to Folsom.
To address the ethical breach and prevent recurrence, Irell & Manella’s general counsel swiftly organized an ethics seminar for all attorneys within the firm following the incident.
As of now, neither Manzin-Monnin nor Sheasby has provided commentary to requests for their perspectives on the matter.
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