In re Boyd, No. 06-32628, 2012 WL 370093, at *2 (Bankr. S.D. Tex. Feb. 3, 2012) (Isgur)

Applying State Unauthorized Practice of Law Committee v. Paul Mason & Associates, Inc., 46 F.3d 469 (5th Cir. Feb. 21, 1995) (Smith, Garza, Berrigan), Rule 9010(a) only allows property locator to take purely administrative action, such as filing proof of claim; when applications to pay unclaimed funds require departure from routine administrative acts, property locator must be represented by counsel. “Although a non-attorney agent may file the initial application [for unclaimed funds], the non-attorney agent may not appear without counsel when a complexity arises. By this test, the Court—not American Property Locators—determines when the representation of counsel is necessary. Accordingly, American Property Locators is prohibited from filing a brief or appearing at any hearing, other than through an attorney.”

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