In re: Complaint as to the Conduct of Gregory Mark Abel, Respondent.
OSB 2366; SC S071019
In the Supreme Court of the State of Oregon
September 25, 2025
374 Or 350
No. 41
En Banc
On review of the decision of a trial panel of the Disciplinary Board.*
Argued and submitted February 27, 2025.
Susan R. Cournoyer, Assistant Disciplinary Counsel, Tigard, argued the cause and filed the answering brief on behalf of the Oregon State Bar.
PER CURIAM
Respondent is suspended from the practice of law for 30 days, commencing 60 days from the date of filing of this decision.
PER CURIAM
The Oregon State Bar charged respondent with a single violation of
I. FACTUAL AND PROCEDURAL BACKGROUND
We review the record de novo.
Respondent was admitted to the Oregon State Bar in 2003, after practicing for several years in Washington State. Since 2005, he has been a partner in his current firm, focusing on both civil practice and criminal defense primarily in Jackson County.
In July 2021, respondent began a pro bono representation involving a financial dispute between two brothers, Mark, respondent‘s client, and Jon. The dispute arose from an insurance payout following the destruction of the brothers’ deceased mother‘s home in the Almeda forest fire in September 2020. Before their mother‘s death, Mark already had lived in the home for several years, and his mother at some point had added him to the title. After she died, in 2019, Mark continued living in the home, and he lost all his belongings in the fire. At that time, both Mark and his mother (but not Jon) were the named insureds on the homeowner‘s policy; Jon, however, had been making payments on the policy.
Almost a year later, Mark—who by that time was in a dire financial situation and without permanent housing—sought assistance regarding the homeowner‘s policy from a local legal aid program, which referred the case to respondent pro bono. Mark told respondent that he had tried to file an insurance claim, but the insurance company had told him that—although only he and his mother were the listed named insureds—Jon had already filed a claim. Then, in September 2020, the company had sent two checks to Jon in Washington State, issued collectively to Mark, Jon, and their mother (for $455,224.15 and $19,350.00, respectively). Mark told respondent that Jon then had
Respondent next took steps to verify the information that Mark had provided. He located a small estate probate filing for the mother, filed by Jon, but it had not listed the home and had not been amended to list the insurance checks, which respondent thought would have been required, because the mother had been named as a beneficiary on the checks issued after her death.1 He also called the insurance company and verified that the checks had been issued to Jon, Mark, and their mother, and that they had cleared. He did not, however, independently verify the home ownership status and so did not learn about Jon‘s joint tenancy and right of survivorship.2
On or shortly after the date of his meeting with Mark, respondent dictated a demand letter to Jon, dated Tuesday, July 20, 2021. The letter explained that respondent‘s law firm represented Mark regarding the insurance payout on the policy on which Mark and his mother, but not Jon, were listed as named insureds. The letter then stated:
“[Y]our seizure of the $455,224.15 check and the $19,350.00 check is Grand Larceny. We are preparing a file in cooperation with [Deputy District Attorney] Markiewicz of the Jackson County District Attorney‘s Office. Once we have assembled the file, Mr. Markiewicz will submit it to the Grand Jury for prosecution and be considered A-Felonies.3
“This matter can be resolved by submitting $237,302.00 [(one-half of the insurance proceeds)] to this office by Monday, July 26, 2021. If we do not receive this amount by this deadline, we will proceed accordingly. In review of the checks, it also appears that the check[s] *** have the [mother‘s name] on them. Of course, it is a felony to sign the [mother‘s] name *** after she is deceased. *** It is a forgery to sign the name of a deceased person.
“These are serious legal matters for which you should consult competent legal counsel immediately licensed in the State of Oregon. This amount of money cannot just walk away, and we are in discussion with [the] Jackson County Sheriff‘s Office and the District Attorney‘s Office about proceeding in this case. We have an obvious Civil Lawsuit but if you are Indicted by a Grand Jury first, our case becomes much easier. If you have retained counsel in this matter, please have them contact me immediately.
”THIS LETTER CONTAINS A REQUIREMENT THAT IF NOT MET WILL RESULT IN AN ACTION BEING FILED AGAINST YOU IN THE JACKSON COUNTY CIRCUIT COURT. IF YOU DO NOT MEET THE DEADLINE STATED ABOVE, THE SENDER WILL PROCEED AS INDICATED.
”HEREIN FAIL NOT”
(Boldface type in original; emphases added.)
Respondent “look[ed at]” the draft demand letter within the next two days, but did not review it carefully, as he was talking with his legal assistant at the same time about the
Upon receipt of respondent‘s demand letter, Jon understood it to mean that a case already had been filed against him by the Jackson County District Attorney‘s Office, that he was being accused of several crimes, and that his arrest was imminent. He immediately wrote to the Jackson County District Attorney, Heckert, enclosing a copy of respondent‘s demand letter and asking whether it amounted to “extortion.” When Heckert received Jon‘s inquiry, she asked Markiewicz whether he had communicated with respondent about the subject of the demand letter. Markiewicz then called respondent and confirmed that they had not spoken—at all—about Mark‘s claims against Jon prior to respondent having sent his letter. Markiewicz and respondent also discussed the standard protocol in Markiewicz‘s office, to the effect that citizen complaints are first taken to law enforcement for investigation.5
Markiewicz summarized his call with respondent to Heckert, who then wrote back to Jon. Heckert told Jon that respondent never had approached the district attorney‘s office; that that office was not “working in cooperation” with respondent or Mark; and that the district attorney‘s office responded only to law enforcement inquiries.6 Heckert‘s letter also opined that respondent‘s demand letter had made implications that were “not factually accurate“; that she found the letter to be “very unprofessional and misleading“; and that Jon could complain to the Bar if he thought that respondent‘s conduct had been unprofessional.
Jon then filed a grievance with the Bar, which ultimately resulted in the Bar filing a formal complaint against respondent, in April 2023. The Bar‘s complaint alleged a single violation of
- Jon‘s “seizure” of the checks was “Grand Larceny“;
- “We are preparing a file in cooperation with [Deputy District Attorney] Markiewicz of the Jackson County District Attorney‘s Office.”
- “Once we have assembled the file, Mr. Markiewicz will submit it to the Grand Jury for prosecution and be considered A-Felonies.”
- “This amount of money cannot just walk away, and we are in discussion with [the] Jackson County Sheriff‘s Office and the District Attorney‘s Office about proceeding in this case.”
A trial panel hearing was held in December 2023, at which respondent represented himself and testified extensively. Respondent acknowledged that, at the time when he had dictated and sent the demand letter, he had not yet conferred with Markiewicz about filing charges and had not himself begun to contact law enforcement, but had told Mark to do so before (and after) sending the letter. He described the situation as having been “rushed” and the letter as not “well thought out” and using poor grammar. He explained that he had drafted the letter “how I talk“—as in, he described “this is what‘s happening, but in a prolonged sense, not in *** a presen[t] sense.” Specifically, when he made the statements that the Bar identified in its complaint, he meant to describe what “would happen” in due course—that is, he would work with the district attorney‘s office to assess whether charges should be filed; if so, that office would present to a grand jury; and the resulting charges likely would involve A-level felonies or what he colloquially had
The trial panel concluded that respondent had violated
II. MISCONDUCT ALLEGATION
On review, respondent again acknowledges that the key disputed statements in his demand letter were inaccurate—that is, at the time when he wrote the letter, he (1) had not yet consulted with the Jackson County District Attorney‘s Office or otherwise with Markiewicz; (2) had no information about whether Markiewicz would submit his allegations to a grand jury for consideration of A-felony charges; and (3) had not yet spoken to the Jackson County Sheriff‘s Office. And, importantly, he also acknowledges that he knew at that time that those actions and events—as described by the actual words that he had used in his letter—had not in fact occurred (and might never occur).
But, relying on his own testimony about what he had meant to convey—to describe what would happen in the future—he contends that the Bar did not satisfy its burden of proof as to the “knowledge” requirement of
We begin by noting our agreement with the parties that a knowing misrepresentation under
The key question, therefore, is whether the Bar proved by clear and convincing evidence that respondent had acted with actual knowledge when he made the false statements in his demand letter. Here, the parties’ arguments diverge. Respondent relies primarily on his testimony about what had been in his mind when he dictated and sent the demand letter—that he had meant to communicate what “was going to happen” (if no settlement were reached) in the future and that his primary goal had been for Jon to consult counsel. (Emphasis added.) He emphasizes that no other evidence addressed what actually had been in his own mind at the time; that the trial panel made no adverse credibility finding respecting his testimony; and, ultimately, that the panel gave credence to his testimony when it concluded that a reasonable person nonetheless would have understood his statements to mean something different from what he had meant. For its part, the Bar relies on the actual wording of respondent‘s statements, viewed in the context of the entire demand letter and other parts of the record, to assert that it sufficiently proved that respondent‘s testimony about what he had meant to convey was not believable and, to the contrary, he had meant to falsely convey to Jon that a prosecution effort was well underway when he knew that none of the described steps in fact had been taken.
Our case law provides a framework for assessing whether the Bar sufficiently proved that respondent had acted with actual knowledge, when respondent testified to contrary. First, in the absence of credibility findings from the trial panel, we may assess subjective factors that are observable from the record—for example, whether a lawyer testified in an evasive as opposed to a candid manner. See In re Walker, 293 Or 297, 303, 647 P2d 468 (1982) (so demonstrating). And, if the panel did enter credibility findings, to the extent that the record permits, we also may assess any observable subjective factors. See Fitzhenry, 343 Or at 104
Second, regardless of whether any credibility finding were made,
“[a]s part of our de novo review in disciplinary cases, we can and do assess credibility based on objective factors, such as the inherent probability or improbability of testimony, whether testimony is internally consistent or inconsistent, whether the testimony is corroborated or contradicted, and so on.”
Id. That is, we independently review the record to make credibility determinations when needed, based on a variety of objective factors.8
Fitzhenry provides a useful example. That case involved an allegation that a private company‘s general counsel had made a knowing misrepresentation when he signed a management representation letter that contained false statements about a particular transaction. Id. at 88-89. The lawyer had testified to the trial panel that he had reviewed the letter for only the limited purpose of confirming legal issues and had not had “in mind” details about the particular transaction when he signed; he also denied having known about the company‘s failure to secure a fixed purchase commitment regarding the transaction. Id. at 103-05. We reviewed relevant aspects of the record to assess the lawyer‘s testimony “given the context of the surrounding circumstances,” ultimately relying on several objective considerations to determine that certain aspects of his testimony had not been believable. See id. at 104-06 (evidence showed “flurry of special efforts” that the lawyer and others had made to secure a stronger purchase commitment; management letter had conspicuously listed the disputed transaction, such that the lawyer could not have failed to see it, particularly given that it undeniably had involved a legal issue); id. at 107 (it “defie[d] belief” that the lawyer could have seen the reference to the disputed transaction and not had “in mind” what he knew from his relatively recent involvement and his knowledge about the need to secure a commitment); see also In re Long, 368 Or 452, 472, 491 P3d 783 (2021) (agreeing with trial panel that lawyer‘s testimony was not credible, based on evidence that persuasively countered that testimony); Lawrence, 337 Or at 469 (based on other evidence, lawyer‘s testimony about her intended meaning of a purportedly false statement was “implausible“); In re Dinerman, 314 Or 308, 315-16, 840 P2d 50 (1992) (rejecting lawyer‘s claim that he had been “simply negligent” in not more closely reviewing an agreement that he had signed and concluding, based on other evidence, that lawyer had knowingly made false statements to secure a loan for a client).9
- “We are preparing a file in cooperation with [Deputy District Attorney] Markiewicz of the Jackson County District Attorney‘s Office.”
- “Once we have assembled the file, Mr. Markiewicz will submit it to the Grand Jury for prosecution and be considered A-Felonies.”
- “This amount of money cannot just walk away, and we are in discussion with [the] Jackson County Sheriff‘s Office and the District Attorney‘s Office about proceeding in this case.”10
We begin with respondent‘s testimony. Respondent testified to the trial panel that the use in his demand letter of the present-tense—as in, ”we are preparing a file” and ”we are in discussion with” law enforcement and the district attorney‘s office—had meant to convey actions that would be taken in the future. (Emphases added.) As he put it:
“The word ‘are.’ It‘s how I talk. I‘ve been saying for some time we are having a hearing on this matter. The hearing wasn‘t until today. It was true when I said it, and it‘s still true today.
“If I say to you[,] ‘We are going to the West Coast Conference Tournament,’ your question to me could be when, but it‘s still a correct statement. ‘Are’ can be used a lot of ways.
“And it wasn‘t *** well thought out, but it‘s how I talk. I was speaking *** into the dictation. I was speaking and thinking and trying to say this is what ***—talking to law enforcement, this is what‘s happening, but in a prolonged sense, not in a *** presen[t] sense.”
He further testified:
“[T]he reason for dictating the letter the way I did is in the same mode in my head. That‘s exactly what I was thinking at the time. Here‘s what‘s going to happen. That‘s, in my mind, how I thought I said it. It wasn‘t sworn. It wasn‘t even reviewed very well, and it was sent out.”
He relatedly explained that his use of “will“—as in, that Markiewicz “will” submit the matter to a grand jury for prosecution as A-felonies—was to a similar effect:
“‘Will’ is the same. ‘Will’ is not—if I had said ‘this had happened,’ that would be different. ‘Will’ means it‘s coming next. ‘Will’ is in the future.”11
As respondent put it, the misunderstanding about what he had meant to convey reduced to “poor grammar.”
As a subjective observation, and contrary to our assessment of the lawyer‘s testimony in Fitzhenry, nothing about respondent‘s testimony itself was “evasive” or “guarded.” 343 Or at 104. Instead, his nature in testifying throughout the proceedings generally supported the notion that the less-than-precise wording used in his demand letter is “how [he] talk[s].”12 But, as we will explain, once assessed against the actual wording of the false statements in his demand letter—importantly, viewed in the context of the full letter and also in light of another objective consideration—respondent‘s testimony was not believable.
Respondent‘s demand letter began by reciting some preliminary information about his representation of Mark, the insurance policy, and the checks. It then asserted that Jon‘s “seizure” of the insurance checks was “Grand Larceny“—a crime that does not exist
Next, respondent‘s demand letter required payment of one-half the insurance proceeds, due within six days, or “we will proceed accordingly.” Although the latter phrasing arguably suggests—as respondent testified—that he had meant to describe future events, the letter then immediately stated that it appeared that the checks had the mother‘s name on them and that it was a “forgery” to sign the mother‘s name on the checks after her death.
The demand letter then advised Jon to consult counsel, followed by the final false statement noted in the Bar‘s complaint—that respondent was in discussion with both the sheriff‘s office and the district attorney‘s office about proceeding accordingly. And the following sentence stated that, “if you are Indicted by a Grand Jury” before an “obvious” civil action moves forward, then “our case becomes much easier.” Collectively, those statements built upon the letter‘s earlier false and threatening statements—as the Bar puts it, “ratchet[ing] up the pressure” on Jon to immediately make payment, by misleading him into thinking that the Jackson County criminal justice system was being activated against him. Ultimately, respondent‘s letter closed with this urgent message, in boldface and uppercase type:
”THIS LETTER CONTAINS A REQUIREMENT THAT IF NOT MET WILL RESULT IN AN ACTION BEING FILED AGAINST YOU IN THE JACKSON COUNTY CIRCUIT COURT. IF YOU DO NOT MEET THE DEADLINE STATED ABOVE, THE SENDER WILL PROCEED AS INDICATED.
”HEREIN FAIL NOT”
(Boldface type in original.)
In sum, the full context of respondent‘s demand letter shows that he sought to misrepresent certain material facts about the criminal process to Jon, with the goal of increasing the pressure on Jon to make immediate payment to Mark. The letter did so by conveying a clear sense of urgency in relation to an impending criminal prosecution. And even if, as respondent argues, his goal was to prompt Mark to consult counsel, the letter viewed in full—including its structure in setting out repeatedly false statements and increasingly threatening and urgent wording—strongly supports the Bar‘s contention that respondent‘s testimony about having meant to describe only possible future events was not believable.
Other evidence in the record supports that assessment—namely, the fact that respondent was an experienced litigation attorney in both the civil and criminal arenas. He therefore would have understood the import of including wording that threatened criminal prosecution in a demand letter relating to a potential civil action, particularly when sent to a person whom he knew to be unrepresented. See generally In re Hedrick, 312 Or 442, 446, 822 P2d 1187 (1991) (court did not believe lawyer‘s testimony that probate petition inadvertently had referred to a “last will” when he had learned about a later will between preparation and filing of the petition; lawyer “had to have known” when he filed the petition that it had falsely referred to a superseded will as the current will; lawyer‘s related failure to disclose the
Respondent points to an additional fact that he thinks supports his testimony about what he had meant to convey, relating to the haste with which he had prepared and sent the demand letter. Before the trial panel, he described having dictated the letter quickly and then returning to it a day or two later, when he saw it in a review basket. As he was “looking at” the letter, his legal assistant raised concerns about Mark‘s financial situation, and so their conversation turned to the appropriate means to quickly deliver the letter to Jon. At one point, respondent testified that he did not “actually have an independent memory of reading the letter,” but he did remember signing it. Respondent described that entire situation as having been “rushed.” We do not disbelieve that testimony, and we do not disagree that those circumstances arguably support respondent‘s argument about why he had been less than careful when he drafted the letter. But, at the same time, those circumstances are not dispositive as to what he meant to convey through his statements—that is, that he merely had meant to describe future events, as opposed to sending a knowingly false, threatening message to Jon.
After reviewing the record de novo, we are persuaded that respondent made knowingly false statements about an impending criminal prosecution in his demand letter, in an effort to convey that Jon needed to act immediately. More specifically, the actual words that respondent chose to use, coupled with other statements made throughout the letter, the manner in which he structured the letter, and its immediate and threatening tone—all viewed in light of respondent‘s extensive litigation experience—collectively lead us to conclude that the Bar proved by clear and convincing evidence that respondent had acted with actual knowledge when he made material statements that were false and that reflected adversely on his fitness to practice, in violation of
III. SANCTION
As noted at the outset, respondent seeks a public reprimand, but the Bar requests a 90-day suspension, as the trial panel imposed. In determining the appropriate sanction, we follow our methodology of applying the American Bar Association‘s Standards for Imposing Lawyer Sanctions (1991) (amended 1992) (ABA Standards), first identifying the nature of the duty violated; respondent‘s mental state at the time of the violation; and the extent of any actual or potential injury caused by his misconduct, all to help assess a preliminary sanction. We then apply aggravating and mitigating factors to determine whether the preliminary sanction should be adjusted, followed by analyzing applicable case law. Nisley, 365 Or at 815. As explained below, we suspend respondent from the practice of law for 30 days.
A. Duty Violated
In knowingly making the false and material statements in his demand letter, respondent violated his duty to the legal system, because he falsely communicated that aspects of the local criminal justice system already had been activated against Jon, in an effort to prompt an immediate favorable response. ABA Standard 6.0; see also In re Leonard, 308 Or 560, 571, 784 P2d 95 (1989) (stating, in misrepresentation case, that duty to maintain integrity in professional activities “is one of a lawyer‘s most basic obligations to the public“).
B. Mental State
We already have concluded that respondent acted with actual knowledge when he drafted and sent his demand letter containing false and material statements. See also generally ABA Standards at 17 (defining “knowledge” for purposes of sanction as “the conscious awareness of the nature or attendant circumstances of the conduct but without the conscious objective or purpose to accomplish a particular result“). As our discussion above confirms, respondent was consciously aware when he wrote his demand letter that it contained false, material statements, and he acted with actual knowledge when he nonetheless chose to include those statements
C. Injury
In sending his demand letter containing knowing false and material statements, respondent caused actual injury to Jon. Jon testified that the letter had caused him considerable lack of sleep and that he had worried that his arrest was imminent; upon receipt, he immediately took steps to assess whether the information described was accurate. Respondent‘s misconduct also caused injury to the profession, because his tactics understandably caused Jon to perceive respondent‘s conduct as a member of the legal profession in a negative light. See ABA Standards at 7 (defining “injury“).
D. Preliminary Sanction
The ABA Standards provide that suspension is generally appropriate when a lawyer “knows that false statements *** are being submitted to [a] court” and “causes injury or potential injury to a party to the legal proceeding,” ABA Standard 6.12, but that reprimand is generally appropriate when a lawyer “knowingly engages in any other conduct that involves dishonesty, fraud, deceit, or misrepresentation[,] and that adversely reflects on the lawyer‘s fitness to practice law[,]” ABA Standard 5.13. Because respondent did not make knowing false statements to a court, we conclude that a reprimand is the appropriate preliminary sanction.
E. Aggravating and Mitigating Factors
The parties agree that two aggravating factors apply. First, respondent has substantial experience in the law—in both civil and criminal practice—having been licensed in Oregon since 2003 and in Washington since 1999. ABA Standard 9.22(i). In the context of the conduct at issue, which involved the selected wording for a demand letter in a civil action that encompassed multiple references to local criminal law processes, we give that factor significant weight.
Second, respondent has a prior disciplinary record—a 2018 complaint to which he stipulated to a public reprimand in 2019. ABA Standard 9.22(a). That complaint involved an allegation of current and former client conflicts,
The trial panel also applied the “vulnerability of victim” aggravating factor, ABA Standard 9.22(h), because Jon had been unrepresented. We decline to apply that factor. Although he was unrepresented, Jon was an educated, highly trained professional who, upon receipt of a demand letter, was able to take action in response to the letter. His immediate response in contacting Heckert also shows that he had the knowledge and capacity to immediately reach out to the legal officer in the best position to advise whether the statements in respondent‘s demand letter were accurate. Simply stated, neither Jon‘s personal characteristics, nor any particular circumstances in the context of the case, rendered him a vulnerable victim under ABA Standard 9.22(h), notwithstanding his status as an unrepresented party. See In re Spencer, 355 Or 679, 700, 330 P3d 538 (2014) (rejecting Bar‘s argument that client had been a vulnerable victim because she was an “unsophisticated client in desperate financial circumstances“; client was not an unsophisticated purchaser and had owned property, worked as a comptroller, and regularly handled financial matters); cf. In re Maurer, 364 Or 190, 203, 431 P3d 410 (2018) (court applied factor when lawyer represented husband in acrimonious dispute with self-represented wife, who had a “somewhat fragile
We apply one mitigating factor that the trial panel did not apply: the absence of a dishonest or selfish motive. ABA Standard 9.32(b). Respondent represented Mark on a pro bono basis; he genuinely thought that Mark was legally entitled to one-half of the disputed insurance proceeds; and, in drafting and sending his demand letter, he sought to set in motion a means of securing some financial relief for Mark as quickly as possible. Respondent had no financial or other personal interest at stake, and the record confirms that his intent was to act in what he thought was Mark‘s best interest. See In re Gildea, 325 Or 281, 298-99, 936 P2d 975 (1997) (applying factor when lawyer who violated several rules had acted throughout in good faith and had attempted to further his client‘s best interests at all times).
To summarize: We apply two aggravating circumstances—substantial experience in the practice of law and prior disciplinary record—giving the former significant weight, but the latter little weight. We also apply one mitigating circumstance, absence of a dishonest or selfish motive. On balance, those factors point to either a public reprimand or a short suspension.
F. Case Law
Our case law confirms that a short suspension is appropriate. For example, in Leonard, 308 Or at 571-72, we imposed a 35-day sanction on a lawyer who had violated the predecessor rule to
We have imposed sanctions closer to 60 days in misrepresentation cases involving more serious misconduct, as well as additional violations or aggravating factors. For example, in In re Spencer, 335 Or 71, 80-81, 89, 58 P3d 228 (2002), we suspended for 60 days a lawyer who intentionally had submitted a vehicle registration form containing a misrepresentation to help his clients illegally register a recreational motor vehicle and also had failed to return another client‘s documentation. Multiple aggravating factors—but only two mitigating factors—applied. Id. at 86-87. Similarly, in Dinerman, 314 Or at 314-16, 319, we suspended for 63 days a lawyer who acted with a dishonest motive and knowingly made false statements to help a client secure a bank loan, and who took other actions to help the client engage in fraudulent and illegal conduct. In imposing the 63-day suspension, we noted a 10-year time lapse since the misconduct had occurred with no intervening disciplinary issues (suggesting that a longer sanction otherwise would have been warranted). Id. at 318-19; see also In re Magar, 312 Or 139, 141-42, 817 P2d 289 (1991) (60-day suspension for lawyer who had endorsed insurance proceeds check with co-payee‘s name, despite knowing that the co-payee
Our review of the case law persuades us that a 30-day suspension is appropriate in this case. Respondent‘s misconduct arose from a single incident, as opposed to continuing or compounding misconduct over time, and it arose from respondent‘s sincere desire to act in his client‘s best interests and to immediately secure financial relief that his client undisputably needed (and to which respondent genuinely thought that his client was legally entitled). But, respondent—an experienced civil and criminal practitioner—nonetheless chose to draft and send a demand letter to an unrepresented person that knowingly conveyed a false and urgent message threatening criminal prosecution for serious crimes. That misconduct violated respondent‘s duty to the legal system, harmed the legal profession, and caused actual injury.
IV. CONCLUSION
We conclude that the Bar proved by clear and convincing evidence that respondent acted with actual knowledge when he included false and material statements in his demand letter that reflected adversely on his fitness to practice law, in violation of
Respondent is suspended from the practice of law for 30 days, commencing 60 days from the date of filing of this decision.