Advocate filing appeal documents amounts to acting for the client, so a power of attorney is required.

An advocate who files a memorandum of appeal, cross-objections, or similar litigation document is treated as "acting" for the client under the procedural rule, because such filing is a step taken on behalf of the client in the conduct of the case. The distinction between merely appearing and pleading, and actually acting, means that these filings are not covered by the exception for a memorandum of appearance. Accordingly, a power of attorney is required for an advocate to file those documents on the client's behalf.

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Issues: Whether an advocate who files a memorandum of appeal, cross-objections, or any other document in a case, other than a memorandum of appearance, is deemed to be "acting" for the client so as to require a power of attorney.

Analysis: The expression "act" in the relevant procedural rule was construed in its ordinary legal sense as taking steps on behalf of a client in the course of litigation, including the filing of documents recognized by the Court as the client's act. The distinction drawn between merely appearing and pleading on the one hand, and acting on the other, showed that filing a memorandum of appeal or cross-objections falls within "acting" and is not covered by the exception for a memorandum of appearance. The inclusive definition of "pleader" also supported the view that an advocate is within the rule.

Conclusion: An advocate files a memorandum of appeal, cross-objections, or other such document as an act for the client, and in such cases a power of attorney is necessary.

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