In Re Complaint as to the Conduct of Oh, 252 P.3d 325

Bar charged Oh with numerous RPC violations arising from immigration matters involving 12 clients.
Oh did not answer the formal complaint; Bar sought default under BR 5.8(a).
Trial panel entered default, found 52 RPC violations, and ordered disbarment with restitution to specific clients.
Oh sought review; Bar filed opening brief; Oh submitted Form B resignation which court declined to accept.
Court reactivated appeal; Bar brief argued sanctions were proper; Oh failed to file opening brief.
Court affirmed the trial panel, disbarment to commence 60 days from decision; restitution order affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether default supports disbarment and restitution.	Bar asserts multiple RPC violations warrant disbarment and restitution.	Oh did not file a brief; none stated.	Yes; default supported disciplinary sanctions including disbarment and restitution.
Whether the Form B resignation was properly rejected and review properly conducted.	Bar argues Bar Rule 9.2 Form B requires safekeeping of client files, which not provided.	Oh did not timely comply; court need not accept resignation.	Form B resignation rejected; review continued.
Whether the court should affirm despite lack of briefing by both parties.	Bar contends issues framed by its briefing support affirmance.	Oh did not challenge the order; arguments not raised warrant default affirmation.	Ordinarily affirm where no party challenges the trial panel order.
Whether disbarment and restitution were appropriate sanctions under the record.	Bar contends sanctions appropriate given 52 RPC violations across 12 clients.	Oh did not contest the sanctions in briefing.	Disbarment and restitution affirmed.

In re Hartfield, 349 Or. 108 (2010) (de novo review constrained when no briefing)
In re Murphy, 349 Or. 366 (2010) (illustrates briefing-based review boundaries)
In re Paulson, 346 Or. 676 (2009) (ordinary scope of review when briefing is lacking)