Instructions:

1. Cite the applicable rule(s).
2. Analyze the facts by applying the rule(s).
3. Provide your concluding answer.

Larry Lawyer is a recent law school graduate and was admitted to the bar roughly five months ago. While Larry had dreams of working at a big law firm, he hasn't been able to find a position that is right for him. As such, he recently opened up his own firm, Larry Lawyer & Associates, and has decided to focus on plaintiff side personal injury cases and both plaintiff and defense side employment work.

In an attempt to get clients in the door, Larry decides to engage in various advertising campaigns. First, he decides to rent a billboard. For his billboard advertisement, he includes a picture of several individuals dressed in suits standing in front of a bookcase full of law books with the following language: "Have you been injured in a car accident? If so, look no further. Larry Lawyer & Associates will bring experience and dedication to your case and will get you the compensation you deserve. Just call 1-800-THE-BEST"

Next, Larry sends an email to everyone he knows soliciting work. In that email, Larry tells his contacts that if they send prospective clients his way, he will be happy to send them a $250 gift card for each prospective client who retains him as an expression of gratitude for helping him get his new firm up and running.

Finally, Larry knows that Molly, his great aunt's cousin, was recently in a car accident. Larry obtains Molly's contact information from his mother and gives her a call. Larry tries to persuade Molly to retain him, but she says she already has counsel representing her in her case.

As a result of Larry's efforts, his phone starts to ring off the hook with prospective clients. Since Larry is the only employee of his firm, he starts to have trouble keeping track of all of the prospective clients. One day, Larry receives a call from an individual named Joe Jones, who was recently in a car accident. After an initial consultation, Joe decides he wants to retain Larry to represent him in connection with litigation stemming from that accident. Larry is overwhelmed with work, so he sends Joe an email setting forth their agreed upon arrangement whereby Larry will get a 70% contingency fee for the matter and asks that Joe simply respond to that email confirming his acceptance. Joe responds quickly confirming the arrangement.

A few months later, Larry gets a call from a company called ACME. ACME's CHRO is Larry's ex-wife and she recommended Larry to the company. ACME wants to retain Larry to represent it in connection with a lawsuit it has just been served with wherein an individual named Joe Jones has sued the company for wrongful termination. This is Larry's first company client and he is excited to move forward with the representation.

A few weeks later, it occurs to Larry that Joe Jones is the same Joe Jones that he is representing in the car accident case. While Larry doesn't perceive a conflict, he decides it is best to terminate his relationship with Joe so as to avoid any perception of impropriety. He calls Joe and tells him he can no longer represent him, that Joe must immediately find new counsel to substitute in for Larry, and that Larry is going to perform no further work on the matter. Joe is upset and confused but agrees to try to find another lawyer to handle the case. Larry thanked Joe and reminded him that he would still be entitled to a portion of any recovery for the work he had performed to date.

A week later, Larry receives a call from Paula Peters, a lawyer who purports to represent Joe. She tells Larry he must immediately send her a copy of Joe's client file. She also tells Larry that she believes she has a duty to report him to the bar for his actions in connection with his termination of Joe's representation. Larry isn't worried. He doesn't think he has done anything wrong. He promptly sends a copy of Joe's file to Paula.

What ethical violations, if any, have been committed?