Interpretation ID: nht91-6.6

DATE: September 23, 1991

FROM: Lawrence A. Beyer -- Esq.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 10-16-91 from Paul Jackson Rice to Lawrence A. Beyer (A38; VSA Sec. 112)

TEXT:

This office, as well as my clients, have been advised by an office of NHTSA that attorneys cannot submit documentation and make declarations on behalf of clients unless they submit formal power of attorney documentation which authorizes such representation.

I have been under the assumption that as an attorney I have the right to fully represent my clients before the federal government. Such representation includes the preparation and submission of completed documentation on their behalf.

Please advise me if, in order to represent my clients, it is NHTSA's policy that I have to provide proof to NHTSA that my statement that I represent a party is true.

Thank you for your time.