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STROUD v. TUNZI
Modifications of attorney fee agreement were invalid as noncompliant with Business and Professions Code Sec. 6147, a State Bar Act provision setting requirements for contingent fee agreements, where clients did not sign the documents, and the documents did not state the contingency rate, did not discuss costs, and did not disclose that fees were negotiable and not established by law. Modifications of a contingent fee agreement must comply with Sec. 6147, and a noncompliant modification will not be enforceable even if the original contract complied. Trial court did not violate due process in ordering attorneys to refund the portion of their fees exceeding that to which they were entitled under valid, original fee agreement, where attorneys participated in the hearing from which the order ensued. Court of Appeal had no reason to report client's new counsel to State Bar based on prior attorneys' allegations of fraud, where the alleged fraud occurred before the trial court, trial court's entry of order over objection was an implied rejection of the claims, and State Bar had already rejected similar claims.

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