Siderits worked for a law firm that required employees to exceed a minimum number of billable hours in order to qualify for an annual salary bonus. In order to meet the bonus threshold, Siderits recorded time that he had not actually worked. Siderits tried to compensate by deleting records for billable time worked in the following year. As a result, Siderits received $47,000 in bonuses over two years, while his law firm lost money, because clients were never billed for the time Siderits shifted from later years to earlier years. Siderits’s questionable billing practices led to disciplinary proceedings. In those proceedings, Siderits asserted that he had no knowledge of case law holding that an attorney owes a fiduciary duty to his firm equivalent to the duty owed to a client.