Rankings 2019
D&B David and Baias – a successful partnership.
In a partnership, the success belongs to the partnership. The team wins and with it, each one of its members.
Chambers Europe 2019
TAX – BAND 1
The D&B Tax team specialises in contentious and non-contentious tax matters and has proven expertise in proceedings before Romanian and EU courts to challenge adverse tax assessments. D&B lawyers handle cases relating to VAT, corporate income and environmental tax law, offer tax advisory services through its strong connection to PwC as well as assisting companies with merger processes and advise clients from the manufacturing and energy sectors and recently increased activity in the pharmaceutical sector.
The “top tax law” practice stands out for the lawyers’ “really good court presence” and “fast replies.”
D&B represented Yazaki Europe in proceedings relating to the company’s right to interest on a late reimbursement of VAT.
Dan Dascălu represents domestic and international clients in tax disputes, with a focus on VAT annulment and reimbursement as well as environmental tax and corporate income tax.
Clients Testimonials:
- A source notes: “Dan Dascălu is able to see and spot a trend in court practice ahead of time.” Another client values that he has “a blend of theoretical skills and pragmatism.”
- Another source appreciates the group’s ability to “come up with new approaches on specific cases.”
COMPETITION/ANTITRUST – BAND 1
D&B David şi Baias is widely acknowledged as a superb choice to represent blue-chip international corporations in investigations carried out by the Romanian Competition Council, including alleged price fixing, abuse of dominance, and the exchange of information between competitors as well as bid rigging cases. Additionally, D&B maintains a strong offering in compliance matters, including the design of distribution models and acts for a client base of clients in the pharmaceutical, manufacturing and energy sectors.
D&B lawyers represented Energobit in a Competition Council investigation into alleged bid rigging in public tenders for contracts to carry out maintenance and improvement works on the Romanian national grid.
Sorin David, Eminent Practitioner, is widely regarded as a leading competition law expert. He advises domestic clients involved in investigations.
Manuela Guia, band 1 lawyer, advises clients on contentious mandates, including investigations. Sources praise her pragmatic approach, reporting: “She is knowledgeable about our industry, understands our business priorities and is a highly intelligent person.”
Clients Testimonials:
- Clients applaud the firm’s business-oriented approach. One explains: “The lawyers react and give answers on the spot. For our business we require immediate answers, or at least a feeling of how things might evolve from a legal perspective.”
- Another interviewee echoes this sentiment, enthusing: “They understand in detail our business and our needs,” adding: “They provide actionable legal advice.”
- Clients highlight Sorin David’s insight and experience, reporting: “I have a lot of trust and confidence in his advice.”
CORPORATE/M&A – BAND 3
D&B is frequently mandated by entrepreneurs to act on the sell side of M&A transactions. The firm handles mid-cap buy-side deals on behalf of private equity portfolio companies or privately owned corporate clients, often with the support of a strong competition law team, brings together corporate and tax law expertise to advise on mergers between Romanian companies. Regularly acts for clients from the life sciences and energy sectors. D&B also assists retail sector clients with real estate-driven corporate transactions.
Anda Rojanschi is a key figure in the M&A team and leads diverse real estate, healthcare and food and drink transactions.
Sorin David, Eminent Practitioner, is a well-respected figure in the market with considerable experience in corporate law topics. Clients highlight his “business acumen and understanding” and say that “he provides immediate and valuable feedback.”
Clients Testimonials:
- Clients appreciate that “the lawyers give good business advice and point out things we may have overlooked.”
- Interviewees further highlight the team’s availability, saying: “It is always possible to discuss matters with the lawyers, whether about small or large issues.”
- Clients describe Anda Rojanschi as “open-minded, intelligent and able to quickly understand all of the possible outcomes.” She also earns praise for her negotiation skills and her ability to establish a “good relationship with the counterparty.”
DISPUTE RESOLUTION – DAN DASCĂLU, BAND 5 LAWYER
Dan Dascălu of D&B David si Baias is particularly well known for his expertise in fiscal litigation, with sources noting that he is “a proficient lawyer, particularly in aspects pertaining to tax procedures”.”He also assists clients with broader commercial disputes”.
Chambers Global 2019
CORPORATE/M&A – BAND 4
Clients describe Anda Rojanschi, band 3 lawyer, as “open-minded, intelligent and able to quickly understand all of the possible outcomes.” She also earns praise for her negotiation skills and her ability to establish a “good relationship with the counterparty.” She is a key figure in the M&A team and leads diverse real estate, healthcare and food and drink transactions.
Sorin David, Eminent Practitioner, is a well-respected figure in the market with considerable experience in corporate law topics. Clients highlight his “business acumen and understanding” and say that “he provides immediate and valuable feedback.”
Clients Testimonials:
- Clients describe Anda Rojanschi as “open-minded, intelligent and able to quickly understand all of the possible outcomes.” She also earns praise for her negotiation skills and her ability to establish a “good relationship with the counterparty.”
Legal 500
TAX – TIER 1
D&B David si Baias represented Grup Servicii Petroliere in the Supreme Court of Justice, successfully obtaining the suspension of a tax assessment decision totalling €30m. The team also assisted Yazaki Europe with the annulment of several tax decisions that rejected the client’s right to interest under late reimbursements of VAT. Dan Dascălu and Anda Rojanschi head the practice and specialise in tax-related litigation and M&A work, respectively. Areas of expertise include VAT, profit tax, transfer pricing, social contributions, excise duty and environmental tax issues. Ana-Maria Iordache is also singled out – she is recommended as Next Generation Lawyer.
EU AND COMPETITION – TIER 1
D&B David si Baias assisted clients in several high-profile investigations by the Romanian Competition Council. Examples include representing EnergoBit in relation to allegations of bid rigging for public tenders and acting for Toneli in an investigation into anti-competitive egg pricing. Manuela Guia serves as practice head, working closely with Sorin David.
TMT (TELECOMS, MEDIA, TECHNOLOGY) – TIER 2
At D&B David si Baias, the client roster includes major telecoms operators, media companies and technology entities. Manuela Guia acts for Orange, advising on day-to-day issues including contract negotiations and franchise agreements. She also assisted Castel Film and Media Pro in drafting a proposal for a piece of law concerning a state aid scheme applying to the film industry. Manuela heads the team.
COMMERCIAL, CORPORATE AND M&A – TIER 4
D&B`s M&A team is headed by Anda Rojanschi and Sorin David and handles a wide range of commercial and M&A mandates. The team is well regarded by Romanian entrepreneurs for its advice on business sales to strategic and financial investors and recently acted for Farmexim’s shareholders in the sale of their shares to Phoenix Pharmahandel. On the acquisition front, Anda Rojanschi assisted Voici La Mode with acquiring three Marks & Spencer stores, which saw the client becoming the new holder of the Romanian M&S franchise.
DISPUTE RESOLUTION – TIER 4
D&B David si Baias`s team “provides perfect guidance” and “handles its part perfectly”, particularly excelling in administrative and tax law litigation. Acting for Grup Servicii Petroliere, practice head Dan Dascălu successfully obtained the suspension of a €30m tax assessment decision in the Supreme Court of Justice.
IFLR 1000
BANKING & FINANCE – TIER 3
D&B is a tier 3 law firm in Banking and Finance. Ovidiu Bold is Rising Star in Capital Markets.
M&A – TIER 4
D&B is a tier 4 law firm in M&A.
Sorin David and Anda Rojanschi are mentioned as Highly regarded lawyers in M&A.
Legal 500
EU AND COMPETITION – TIER 1
The depth of the team D&B David si Baias SCA is a major plus, not just in terms of associates such as Lucian Bozian, who attracts huge client praise, but also in the presence of managing partner Sorin David who remains a leading figure in the market. The versatile practice covers the full range of issues, including antitrust and unfair competition claims on the contentious side, and merger clearance and compliance training on the advisory front.
Sorin David – Leading individuals
Lucian Bozian – Rising stars
Clients Testimonials:
- “We were extremely pleased with their expertise and know-how in EU Funds/ State aid and Competition and built a strong relationship from then onward.”
- “Very professional attitude, good understanding of client’s objectives, hands-on approach, clear and structured legal opinions, first-class defence of client’s interests.”
- “Puts its clients first and focuses on providing extraordinary service to those clients.”
- “They provided seamless advice on our daily business and performed several compliance tasks on competition issues.”
- “Sorin David is one of the best known lawyers in the market.”
- “Lucian Bozian, was always available for our needs and we received valuable help and advice every time it was necessary. His commitment and great knowledge on complex matters was always treasured by us. Lucian Bozian has a past experience as a competition inspector, which enables him to provide practical insight into the authority’s way of handling investigations. He also has a strong hold of our business and understands the intricacies of the market.”
TAX – TIER 1
D&B David si Baias SCA has a top-notch reputation for contentious and non-contentious tax advice, and related administrative and white collar crime proceedings. The firm regularly represents clients before the regulatory authorities, and provides strong corporate support on M&As, financings, real estate deals and restructurings. Other areas of strength include VAT, transfer pricing, social contributions, excise duty and environmental tax. The firm’s membership of the PwC network makes it popular with clients seeking a one-stop-shop.
Tax litigation head Dan Dascălu, Ana-Maria Iordache and Mihail Boian are highly recommended for disputes. Sorin David and Anda Rojanschi are active on the advisory side.
Dan Dascălu – Leading individuals
Ana-Maria Iordache – Next Generation Partners
Clients Testimonials:
- “D&B David si Baias SCA are a great team and we trusted them with our tax litigation.”
- “In our opinion, Dan Dascalu is the best Romanian lawyer specialised in tax litigation, with extensive knowledge and experience in tax matters.”
- “The tax team is definitely at the top of the list when it comes to choosing the best possible lawyers in this domain. They can handle even the most difficult and complex cases, due to their exceptional technical skills doubled by the most practical approach.”
- “They are always available, even in short notice, and when you work in a fast changing industry you learn to appreciate this. I usually need answers yesterday, because this is how things work, so I know that I’ll get it when I ask D&B. We’ve worked together for so long they understand the business, so I don’t need to prepare pages of business understanding for them; I just ask the question.”
- “Puts its clients first and focuses on providing extraordinary service to those clients. Stability of representation team.”
- “Responsive lawyers who ask great questions and actively listen to answers.”
- “They have that connection to the reality that is given by years of practice, I guess – they provide a straightforward answer, not an open one. As a practitioner in the industry I do not need an array of possibilities to choose from, but a yes/no answer. Dan Dascalu and Ana Maria Iordache are remarkable to me.”
- “Dan Dascalu, being both a very persuasive practitioner and also an exceptional theorist, is definitely one of the best advocates to which anyone can entrust in full confidence even the most sensitive cases. He is a proficient lawyer, coordinating a team of genuinely professional individuals, of which I would mention Mihail Boian as a young lawyer on the rise.”
COMMERCIAL, CORPORATE AND M&A – TIER 3
D&B David si Baias SCA offers an all-embracing corporate practice that is as comfortable on the transactional side as it is on day-to-day matters. The one-stop-shop nature of its offering is cemented by its membership of the PwC network, and clients appreciate having the ability to access the full range of services.
Highly rated partner Anda Rojanschi leads the team alongside managing partner Sorin David. Clients include major multinationals, entrepreneurs and investors, and the firm is especially active in the healthcare sector.
Clients Testimonials:
- “A highly dedicated team with many years of M&A experience proven by several completed deals. The legal team benefits from the association with PwC (easy to assemble cross-disciplinary teams with financial, tax, corporate finance experts).”
- “Anda Rojanschi is a seasoned lawyer with strong M&A experience gained in several successfully closed transactions. She has the ability to smoothly convey her knowledge to the client achieving effective results in time-pressured situations.”
DISPUTE RESOLUTION TIER 3
D&B David si Baias SCA fields a strong team of litigation experts with experience across a range of disciplines. Tax disputes feature high on the agenda, but the firm also handles claims linked to heavily-regulated industries such as telecoms, as well as broader commercial, real estate, employment, banking and insolvency related disputes.
The versatile Dan Dascălu leads the team, which includes tax and administrative litigation expert Ana-Maria Iordache and Mihail Boian. Managing partner Sorin David is also highly experienced in this area.
Clients Testimonials:
- “We have been collaborating with D&B for many years within a sensitive and complex case; have a relationship based on trust, given the quality of legal opinions, the promptness of their submission, and considering our needs as clients.”
- “The capability of the team to handle difficult and complex litigations puts them to the top of practitioners in the dispute resolution area. They hold impressive skills in managing tax, competition, and administrative proceedings.”
- “I totally recommend Sorin David and Ovidiu Bold as very professional, rigorous, innovative lawyers.”
- “Sorin David is a really prestigious professional who can be trusted with the most sensitive competition cases, as he holds great experience and extensive knowledge in competition matters. Dan Dascalu is widely known for managing tax and administrative disputes on the highest possible standard, combining a very strong know how with the eloquence of a brilliant barrister.”
EMPLOYMENT TIER 3
D&B David si Baias SCA has a solid team led by partner Dan Dascălu, who divides his time between tax and employment law. The practice also contains several specialised associates who come highly recommended by clients, including Ioana Cercel. The practice is especially strong on the employment aspects of complex restructuring projects and business transfers. More recently it has been active on the litigation front and advised clients on COVID-19 related issues.
Clients Testimonials:
- “Very professional team, responsive and supportive. Pro active approach from their side, flexible and customer oriented.”
- “D&B David & Baias communicates very effectively with the client’s internal teams, even if they are not people from the legal department. D&B team members are talking in the same language, more precisely if they are working with teams outside from the legal area, for example the HR department, they can explain the request or they can give advice that can be understood by non-legal teams. Moreover, D&B deliver their works in due time to be reviewed / approved from the point of view of the client’s commercial policy and they maintain a professional working environment.”
- “Ioana Cercel – Managing Associate – I appreciate that Ioana is very pragmatic and also informs me about the estimation of the chances of losing the litigation, in case the case is not solid. Unlike other competitors, she gives us a clear and balanced picture of the strengths we have but also of the weaknesses in labor disputes. She is very organized, has well-structured works and respects the deadline.”
ENERGY AND NATURAL RESOURCES TIER 3
D&B David si Baias SCA made strong inroads into the market through its absorption of the energy boutique Pachiu & Associates, including partner Laurentiu Pachiu and well-regarded consultants Marius Nita and Delia Pachiu. The new arrivals add depth to an energy practice, where managing partner Sorin David and corporate partner Anda Rojanschi also have strong experience. The group now provides a full service offering, encompassing transactional, infrastructure, regulatory and tax issues.
Clients Testimonials:
- “The team has an extensive and in-depth knowledge and experience in the energy sector in Romania. It provides thorough information at once and full support. The team is very responsive. The cost estimates and billings are correct.”
- “Key strengths and capabilities are: Extremely knowledgeable of the Energy Market in Romania, including applicable law and regulations. In-house expertise on various specialist topics. Very well connected with official organizations in the energy industry in Romania, as well as the private sector, including investors.”
- “The firm seems to have a strong focus on innovations in people and technology. It has an easy and user friendly system of organising online meetings, even with large groups, and connecting to our team of attorneys by electronic means is very simple and a straightforward process.”
- “Professional, creative, pro-active and solution oriented: a true partner in all business dealings. Reliable, flexible, pleasant and professional co-operation, quick response times and excellent availability.”
- “We have been working with Marius Nita and Delia Pachiu for many years and have been accompanied through many regulatory changes. They respond within a short term, answer questions completely and handle all topics to our full satisfaction.”
REAL ESTATE AND CONSTRUCTION TIER 4
D&B David si Baias SCA has a strong transactional offering, regularly advising on the real estate aspects of major corporate acquisitions, as well as the corporate structuring of property investments and joint ventures. The firm’s membership of the PwC network also gives it a significant edge on the tax side, as well as related financings and regulatory issues.
Managing associate Georgiana Balan leads the practice, which has strong involvement from managing partner Sorin David and corporate head Anda Rojanschi.
Clients Testimonials:
- “The team is composed by lawyers with awareness of the legal and business environment. We have been working mainly with Georgiana Balan. Georgiana has been very motivated and responsive and has offered solutions whenever necessary.”
- “A very competitive team, with very good communication from the team members with the client and a strong understanding of the client’s needs.”
Legal 500
EU AND COMPETITION – TIER 1
The depth of the team D&B David si Baias SCA is a major plus, not just in terms of associates such as Lucian Bozian, who attracts huge client praise, but also in the presence of managing partner Sorin David who remains a leading figure in the market. The versatile practice covers the full range of issues, including antitrust and unfair competition claims on the contentious side, and merger clearance and compliance training on the advisory front.
Sorin David – Leading individuals
Lucian Bozian – Rising stars
Clients Testimonials:
- “We were extremely pleased with their expertise and know-how in EU Funds/ State aid and Competition and built a strong relationship from then onward.”
- “Very professional attitude, good understanding of client’s objectives, hands-on approach, clear and structured legal opinions, first-class defence of client’s interests.”
- “Puts its clients first and focuses on providing extraordinary service to those clients.”
- “They provided seamless advice on our daily business and performed several compliance tasks on competition issues.”
- “Sorin David is one of the best known lawyers in the market.”
- “Lucian Bozian, was always available for our needs and we received valuable help and advice every time it was necessary. His commitment and great knowledge on complex matters was always treasured by us. Lucian Bozian has a past experience as a competition inspector, which enables him to provide practical insight into the authority’s way of handling investigations. He also has a strong hold of our business and understands the intricacies of the market.”
TAX – TIER 1
D&B David si Baias SCA has a top-notch reputation for contentious and non-contentious tax advice, and related administrative and white collar crime proceedings. The firm regularly represents clients before the regulatory authorities, and provides strong corporate support on M&As, financings, real estate deals and restructurings. Other areas of strength include VAT, transfer pricing, social contributions, excise duty and environmental tax. The firm’s membership of the PwC network makes it popular with clients seeking a one-stop-shop.
Tax litigation head Dan Dascălu, Ana-Maria Iordache and Mihail Boian are highly recommended for disputes. Sorin David and Anda Rojanschi are active on the advisory side.
Dan Dascălu – Leading individuals
Ana-Maria Iordache – Next Generation Partners
Clients Testimonials:
- “D&B David si Baias SCA are a great team and we trusted them with our tax litigation.”
- “In our opinion, Dan Dascalu is the best Romanian lawyer specialised in tax litigation, with extensive knowledge and experience in tax matters.”
- “The tax team is definitely at the top of the list when it comes to choosing the best possible lawyers in this domain. They can handle even the most difficult and complex cases, due to their exceptional technical skills doubled by the most practical approach.”
- “They are always available, even in short notice, and when you work in a fast changing industry you learn to appreciate this. I usually need answers yesterday, because this is how things work, so I know that I’ll get it when I ask D&B. We’ve worked together for so long they understand the business, so I don’t need to prepare pages of business understanding for them; I just ask the question.”
- “Puts its clients first and focuses on providing extraordinary service to those clients. Stability of representation team.”
- “Responsive lawyers who ask great questions and actively listen to answers.”
- “They have that connection to the reality that is given by years of practice, I guess – they provide a straightforward answer, not an open one. As a practitioner in the industry I do not need an array of possibilities to choose from, but a yes/no answer. Dan Dascalu and Ana Maria Iordache are remarkable to me.”
- “Dan Dascalu, being both a very persuasive practitioner and also an exceptional theorist, is definitely one of the best advocates to which anyone can entrust in full confidence even the most sensitive cases. He is a proficient lawyer, coordinating a team of genuinely professional individuals, of which I would mention Mihail Boian as a young lawyer on the rise.”
COMMERCIAL, CORPORATE AND M&A – TIER 3
D&B David si Baias SCA offers an all-embracing corporate practice that is as comfortable on the transactional side as it is on day-to-day matters. The one-stop-shop nature of its offering is cemented by its membership of the PwC network, and clients appreciate having the ability to access the full range of services.
Highly rated partner Anda Rojanschi leads the team alongside managing partner Sorin David. Clients include major multinationals, entrepreneurs and investors, and the firm is especially active in the healthcare sector.
Clients Testimonials:
- “A highly dedicated team with many years of M&A experience proven by several completed deals. The legal team benefits from the association with PwC (easy to assemble cross-disciplinary teams with financial, tax, corporate finance experts).”
- “Anda Rojanschi is a seasoned lawyer with strong M&A experience gained in several successfully closed transactions. She has the ability to smoothly convey her knowledge to the client achieving effective results in time-pressured situations.”
DISPUTE RESOLUTION TIER 3
D&B David si Baias SCA fields a strong team of litigation experts with experience across a range of disciplines. Tax disputes feature high on the agenda, but the firm also handles claims linked to heavily-regulated industries such as telecoms, as well as broader commercial, real estate, employment, banking and insolvency related disputes.
The versatile Dan Dascălu leads the team, which includes tax and administrative litigation expert Ana-Maria Iordache and Mihail Boian. Managing partner Sorin David is also highly experienced in this area.
Clients Testimonials:
- “We have been collaborating with D&B for many years within a sensitive and complex case; have a relationship based on trust, given the quality of legal opinions, the promptness of their submission, and considering our needs as clients.”
- “The capability of the team to handle difficult and complex litigations puts them to the top of practitioners in the dispute resolution area. They hold impressive skills in managing tax, competition, and administrative proceedings.”
- “I totally recommend Sorin David and Ovidiu Bold as very professional, rigorous, innovative lawyers.”
- “Sorin David is a really prestigious professional who can be trusted with the most sensitive competition cases, as he holds great experience and extensive knowledge in competition matters. Dan Dascalu is widely known for managing tax and administrative disputes on the highest possible standard, combining a very strong know how with the eloquence of a brilliant barrister.”
EMPLOYMENT TIER 3
D&B David si Baias SCA has a solid team led by partner Dan Dascălu, who divides his time between tax and employment law. The practice also contains several specialised associates who come highly recommended by clients, including Ioana Cercel. The practice is especially strong on the employment aspects of complex restructuring projects and business transfers. More recently it has been active on the litigation front and advised clients on COVID-19 related issues.
Clients Testimonials:
- “Very professional team, responsive and supportive. Pro active approach from their side, flexible and customer oriented.”
- “D&B David & Baias communicates very effectively with the client’s internal teams, even if they are not people from the legal department. D&B team members are talking in the same language, more precisely if they are working with teams outside from the legal area, for example the HR department, they can explain the request or they can give advice that can be understood by non-legal teams. Moreover, D&B deliver their works in due time to be reviewed / approved from the point of view of the client’s commercial policy and they maintain a professional working environment.”
- “Ioana Cercel – Managing Associate – I appreciate that Ioana is very pragmatic and also informs me about the estimation of the chances of losing the litigation, in case the case is not solid. Unlike other competitors, she gives us a clear and balanced picture of the strengths we have but also of the weaknesses in labor disputes. She is very organized, has well-structured works and respects the deadline.”
ENERGY AND NATURAL RESOURCES TIER 3
D&B David si Baias SCA made strong inroads into the market through its absorption of the energy boutique Pachiu & Associates, including partner Laurentiu Pachiu and well-regarded consultants Marius Nita and Delia Pachiu. The new arrivals add depth to an energy practice, where managing partner Sorin David and corporate partner Anda Rojanschi also have strong experience. The group now provides a full service offering, encompassing transactional, infrastructure, regulatory and tax issues.
Clients Testimonials:
- “The team has an extensive and in-depth knowledge and experience in the energy sector in Romania. It provides thorough information at once and full support. The team is very responsive. The cost estimates and billings are correct.”
- “Key strengths and capabilities are: Extremely knowledgeable of the Energy Market in Romania, including applicable law and regulations. In-house expertise on various specialist topics. Very well connected with official organizations in the energy industry in Romania, as well as the private sector, including investors.”
- “The firm seems to have a strong focus on innovations in people and technology. It has an easy and user friendly system of organising online meetings, even with large groups, and connecting to our team of attorneys by electronic means is very simple and a straightforward process.”
- “Professional, creative, pro-active and solution oriented: a true partner in all business dealings. Reliable, flexible, pleasant and professional co-operation, quick response times and excellent availability.”
- “We have been working with Marius Nita and Delia Pachiu for many years and have been accompanied through many regulatory changes. They respond within a short term, answer questions completely and handle all topics to our full satisfaction.”
REAL ESTATE AND CONSTRUCTION TIER 4
D&B David si Baias SCA has a strong transactional offering, regularly advising on the real estate aspects of major corporate acquisitions, as well as the corporate structuring of property investments and joint ventures. The firm’s membership of the PwC network also gives it a significant edge on the tax side, as well as related financings and regulatory issues.
Managing associate Georgiana Balan leads the practice, which has strong involvement from managing partner Sorin David and corporate head Anda Rojanschi.
Clients Testimonials:
- “The team is composed by lawyers with awareness of the legal and business environment. We have been working mainly with Georgiana Balan. Georgiana has been very motivated and responsive and has offered solutions whenever necessary.”
- “A very competitive team, with very good communication from the team members with the client and a strong understanding of the client’s needs.”