These summaries were prepared by McGuireWoods LLP lawyer Thomas E. Spahn. They are based on the letter opinions issued by the Virginia State Bar. Any editorial comments reflect Mr. Spahn's current personal views, and not the opinions of the Virginia State Bar, McGuireWoods or its clients.

LEO Num	Topics	Summary
1876	23-Communicating with an Adversary - Miscellaneous 27-Litigation Tactics (Including Misrepresentations, Tape Recordings) 51-Government Attorneys	Prosecutors aware that non-citizen defendants without court-appointed counsel in a court which does not conduct plea colloquies may not offer a plea deal in exchange for a guilty plea without advising the defendant to obtain legal advice or request that the court conduct a colloquy.

Copyright 2000, Thomas E. Spahn