not the attorney of record. Instead, the client appears in the action pro se, meaning they represent themselves. The unbundled attorney might in this case inform the court of their assistance drafting the document. In 2007 the ABA relaxed its professional ethical rules to expressly permit unbundled legal services and legal ghostwriting in Rule 1.2(c). In April 2010, the New York County Law Association echoed the ABA opinion by formally giving its blessing to the practice of legal ghostwriting as consistent with the state bar’s ethical rules. The NYCLA Ethics Committee on Professional Ethics in its Opinion 742 stated that “…it is now ethically permissible for an attorney, with the informed consent of his or her client, to play a limited role and prepare pleadings and other submissions for a pro se litigant without disclosing the lawyer’s participation to the tribunal and adverse counsel. Disclosure of the fact that a pleading or submission was prepared by counsel need only be made ‘where necessary.” Certain jurisdictions have called for the implementation of clinics in law schools to teach unbundling legal services to students in a practical setting, and to encourage future lawyers to use the practice. Criticisms Opponents of unbundled legal services often cite ethical concerns about the professional responsibility of a lawyer for his or her client. For one, an attorney owes the court a "duty of candor" in his or her dealings with the court. By working on a lawsuit on behalf of a client but failing to appear, some courts have held this duty is violated. Moreover, full-service attorneys handle all aspects of a case and can be liable for legal malpractice should they be negligent in their representation of clients. Critics claim that, should an attorney limit the scope of his or her representation of a client, they might escape a malpractice claim despite having committed malpractice. Some fear that a lack of communication between lawyer and client can lead to confusion about who is responsible for what, and that important issues of a client's case can fall through the cracks. State bar associations and courts have split on the ethics of unbundling when it comes to legal ghostwriting. Some jurisdictions have ruled that ghostwriting by attorneys is prohibited, claiming that failing to disclose their assistance to a self-represented client would be misleading to the court and their adversary in the lawsuits. Others oppose legal ghostwriting because