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Rina Tan, a non-lawyer, operates a paid legal-document service that drafts pleadings for clients and signs them as 'Attorney for [Client]' and personally files the documents in the Court of Appeals. The court accepts the filing; weeks later, the misrepresentation is discovered when a reviewing attorney from a licensed firm examines the record and identifies the signer as a non-lawyer. (a) Is Rina Tan engaged in Unauthorized Practice of Law under CPRA (A.M. No. 22-09-01-SC)? Identify the controlling rule and the actors involved. (b) What penalties may be imposed for Rina's conduct under CPRA? Distinguish the types of sanctions that may be imposed. (c) Who may be liable for penalties in this scenario (Rina, the client who hired her, the licensed attorney who engaged Rina), and why? Explain with the CPRA's accountability framework.