Legal ghostwriting is a form of unbundled legal services in the United States in which an attorney drafts a document on behalf of a client without formally appearing before the court. Instead, the client represents his or herself pro se. Purpose The growth of pro se litigants can be attributed to the high cost of litigation, anti-lawyer sentiment, and the advent of do-it-yourself law services. However, self-represented litigants may still need legal representation in order and to navigate the litigation process. Legal ghostwriting is one way in which clients can receive legal counsel while maintaining control of their case and avoiding higher legal costs. Attorneys offering legal ghostwriting services often charge a flat fee rather than billing by the hour as is typical for full-service attorneys. American Bar Association The ABA formally endorsed the delivery of legal ghostwriting services by attorneys to pro se clients in 2007. In a formal opinion, the ABA deemed the practice consistent with Rule 1.2(c) of the American Bar Association Model Rules of Professional Conduct which allows lawyers to unbundle their services to clients. According to the ABA opinion paper, lawyers should generally disclose the fact that papers were prepared by an attorney, but need not disclose their name of firm. New York The New York County Law Association agreed with the ABA approach to legal ghostwriting in a 2010 ethics opinion paper. In that decision, NYCLA found 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.” The Second Circuit court in 2011 ruled that it was not improper for an attorney to ghostwrite legal pleadings on behalf of a self-represented litigant. Criticism Ethical concerns may arise for attorneys offering legal ghostwriting services to clients. A common criticism of legal ghostwriting is that it gives the self-represented litigant an unfair advantage because judges often grant pro se litigants leeway in the courtroom to make up for their lack of experience. Critics argue that when clients employ an attorney ghostwriter, they should not be entitled to that privilege. For this reason, the New York State Bar Association requires attorneys to disclose