[Until this opinion appears in the Ohio Official Reports advanc e sheets, it may be cited as Disciplinary Counsel v. Cramer , Slip Opinion No. 2020-Ohio-4195.]

NOTICE This slip opinion is subject to formal revision before it is pu blished in an advance sheet of the Ohio Official Reports. Readers are req uested to promptly notify the Reporter of Decisions, Supreme Court of Ohio, 65 South Front Street, Columbus, Ohio 43215, of any typographic al or other formal errors in the opini on, in order that corrections m ay be made before the opi nion is published.

S LIP O PINION N O
. 2020-O HIO -4195
D ISCIPLINARY C OUNSEL v . C RAMER
. [Until this opinion appears in t he Ohio Official Reports advanc e sheets, it may be cited as Disciplinary Counsel v. Cramer , Slip Opinion No. 2020-Ohio-4195.] Attorneys—Misconduct—Violations of the Rules of Professional Conduct, including engaging in conduct that ad versely reflects on the lawyer’s fitness to practice law—Indefinite suspension. (No. 2019-1739—Submitted April 8, 2020—Decided August 27, 2020. )
O N C ERTIFIED R EPORT by the Board of Professiona l Conduct of the Supreme Court, No. 2018-038.

______________ Per Curiam. {¶ 1} Respondent, Marilyn Abrienne C ramer, of Cleveland, Ohio, Attorney Registration No. 0032947, w as admitted to the practice of law in Ohio in
1977. {¶ 2} In a July 3, 2018 complaint, relator, disciplinary counsel, all eged that Cramer’s conduct with respect to the ancillary administrat ion of her mother’sS UPREME C OURT OF O HIO

2 probate estate in Franklin County violated the Rules of Profess ional Conduct. Specifically, the complaint alleged that Cramer (1) knowingly o r recklessly made false statements concerning the integrity of judicial officers, (2) knowingly made
false statements of fact or la w to a tribunal, (3) engaged in c onduct involving dishonesty, fraud, deceit, or misrepresentation, (4) filed friv olous pleadings, (5) engaged in conduct that was prejudicial to the administration o f justice, and (6) engaged in conduct that adversel y reflects on her fitness to pr actice law. {¶ 3} Following a two-day hearing, a panel of the Board of Profession al Conduct issued a report finding that Cramer committed all the c harged misconduct and recommending that she be indefinitely suspended from the practice of law, with certain conditions on her reinstatement t o the profession. The board adopted the findings of fact, conclusions of law, and recommendation of the hearing panel. Cramer ha s filed 28 objections to the bo ard’s findings of fact, conclusions of law, and recommended sanction and asks thi s court to dismiss relator’s complaint. Based on our review of the record, we ove rrule each of Cramer’s objections and adopt the board’s findings of misconduc t and
recommended sanction. Background {¶ 4} A brief summary of the underlying probate litigation in this ca se is necessary to understand the nature of Cramer’s misconduct. {¶ 5} Cramer’s mother, Selena Cram er, died in Alabama on September 28 , 2007, and was survived by four heirs—Cramer and her siblings, C allie Lipka, Myron Cramer (“Myron”), and Ca rrie Chaplin. In November 2014, Lipka opened an estate in Limestone County, Ala bama, but did not identify Cr amer as one of Selena’s surviving children. Li pka also retained an attorney t o file an application for ancillary administration in Franklin County, Ohio, hired a realtor to dispose of
a house that Selena owned in Col umbus at the time of her death, and placed the house on the market. Three days before the hearing on that app lication, CramerJanuary Term, 2020

3 filed in Franklin County a competing application for authority to administer Selena’s entire estate, along with a sworn declaration making n umerous disparaging comments about Lipka and Myron. Thereafter, Lipka’ s counsel withdrew his application, citing the family’s disagreement rega rding how to proceed. {¶ 6} On September 29, 2014, the probate -court magistrate ordered Cramer to file an amended appli cation to be appointed as the an cillary
administrator and stated that upon filing of the appropriate do cuments and bond, Cramer would receive the appointme nt. The magistrate advised t he parties that the ancillary administrator would have to work for the common b enefit of all
beneficiaries and that the fa ilure to do so would result in the ancillary
administrator’s removal and the appointment of an independent a dministrator. The magistrate stated that she w ould not entertain any argument s regarding the validity of the Alabama administr ation because there was no all egation that
Selena was a resident of Frank lin County at the time of her dea th. Following that hearing, Cramer fired Lipka’s realtor and took the house off of the market. On November 28, 2014, Cramer filed the necessary documents and bon d and was appointed as the ancillary adminis trator to dispose of the Fran klin County real

estate. {¶ 7} Myron and Lipka retained another attorney to represent them in the Franklin County proceedings. In April 2015, they moved for rem oval of Cramer as the ancillary administrator on the grounds that she had fail ed to fulfill her duties, in part by failing to relist the real property for sale . At a June 2015 hearing, the heirs—including Cra mer—agreed to sell the property , pay the expenses of administration, and surrender the remaining proceed s to the Alabama

estate. {¶ 8} On July 17, 2015, the magistrate issued a decision recommending that Cramer be removed as the ancillary administrator based on findings that sheS UPREME C OURT OF O HIO

4 had failed to list the property for sale and that the resulting delay in the administration of the estate and personal issues among the heir s required her
removal. See R.C. 2109.24. On December 23, 2015, the court adopted the magistrate’s decision over Cramer’s objections. {¶ 9} In January 2016, the probate court appointed attorney Thomas Taneff to serve as the successor ancillary administrator. Tane ff filed a civil complaint to sell the real estate in a separate but related pro ceeding. Cramer opposed Taneff’s actions at every turn and unsuccessfully attem pted to remove
him from his role as fidu ciary of the estate. {¶ 10} At some point during Taneff’s administration, the property was vandalized, and Taneff received an insurance settlement of $43, 500 on behalf of the estate. The property was eventually appraised at $30,000, and in July 2017, the court approved the sale of the property for $39,000 over Cr amer’s repeated objections. {¶ 11} In a December 19, 2017 judgment entry, the probate court found that Cramer willfully violated Civ.R. 11 by drafting and signin g numerous documents and pleadings that lacked grounds to support the alle gations made.
The court also found that Crame r willfully violated R.C. 2323.5 1 by conducting herself in a manner intended to harass and intimidate Taneff, w ho was a party to the action, and engaging in conduct that was not warranted unde r existing law and could not be supported by good-faith arguments. The court furt her determined that Cramer’s conduct was imprope r, had caused unnecessary dela y, and had needlessly increased the costs of litigation. On March 22, 201 8, the court ordered Cramer to pay Taneff $22,256.65, representing the attorney fees and costs he had
incurred as the result of her conduct. {¶ 12} With this backdrop, we proceed to the board’s findings of fact and
misconduct.January Term, 2020

5 Misconduct {¶ 13} Relator charged Cramer with seven rule violations arising from her conduct in the ancillary administr ation of her mother’s estate. For ease of discussion, the board divided those charges into three separate counts.
Count One: False Statemen ts Concerning the Integrity of a Judicial Officer {¶ 14} Relator first alleged that Cra mer violated Prof.Cond.R. 8.2(a) (prohibiting a lawyer from knowingly or recklessly making false statements concerning the integrity of a judicial officer) by making numer ous disparaging statements about the integrity o f the probate court, repeatedly alleging that the court had engaged in improper ex parte communications and had a ppointed Taneff for political reasons. {¶ 15} Because lawyers “ ‘possess, and are perceived by the public as possessing, special knowledge of the workings of the judicial b ranch of government,’ ” we have recognized that “[their] statements made during court proceedings are ‘likely to be received as especially authoritat ive.’ ” Disciplinary
Counsel v. Gardner , 99 Ohio St.3d 416, 2003-Ohio-4048, 793 N.E.2d 425, ¶ 22, quoting State ex rel. Oklahoma Bar Assn. v. Porter , 766 P.2d 958, 969 (Okla.1988), and Gentile v. Nevada State Bar , 501 U.S. 1030, 1074, 111 S.Ct. 2720, 115 L.Ed.2d 888 (1991). In Gardner , we adopted an objective standard to determine whether a lawyer’s s tatements about a judicial office r were made with knowledge or reckless disregard of their falsity: We look to t he nature of the statements and the context in which they were made and consider what a reasonable attorney, in light o f all his professional functions , would do in the
same or similar circumstances. Id. at ¶ 26. Applying that standard, we held that “an attorney may be sanctioned fo r making accusations of judici al impropriety that a reasonable attorney would believe are false.” Id. at ¶ 31. {¶ 16} In Cramer’s objections to the magistrate’s 2015 decision recommending that she be removed as the ancillary administrator , CramerS UPREME C OURT OF O HIO

6 referred to the removal hearing as a “pseudo-hearing” and a “ch arade”—largely because the magistrate had refused to consider arguments relate d to the Alabama probate proceedings. Cramer also alleged that the magistrate h ad deprived her of her rights to fundamental fairness and an unbiased hearing, fol lowed the law “only reluctantly,” engaged in “fundamentally unfair procedures ” by distorting the truth and concealing evidence to arrive at “predetermined c onclusions,” and
removed her as the fid uciary to avoid work. {¶ 17} In addition, Cramer accused the magistrate of engaging in impro per ex parte communications with the attorneys representing Lipka a nd Myron. In support, she stated that she had observed the magistrate speak to one of those attorneys before a hearing and she cited the alleged statement of a court employee, but neither allegation identified the substance of th e alleged conversations. In its decision overruling Cramer’s objections and removing her as the fiduciary, however, the cour t addressed Cramer’s attacks on the magistrate and found the magistrate’ s conduct to be proper. {¶ 18} In Cramer’s answer to Taneff’s complaint in the real-estate proceeding, she claimed that Taneff’s appointment as the succes sor ancillary administrator was illegal and appeared to have been “politicall y motivated.” Cramer claimed that she had arranged for the court’s appraiser to enter and inspect the real property after Taneff had failed to do so. Sh e also continued to attack Lipka and Myron and argued that they had acted unlawfull y in the Alabama proceedings. {¶ 19} In her response to Taneff’s motion to strike her answer to the complaint, Cramer alleged that the clerk’s office had engaged i n “particularly suspicious and troubling” handlin g of her answer and had failed to timely file it despite its timely submission. The magistrate subsequently iss ued an order deeming Cramer’s answer to be timely filed but explaining why C ramer’s allegations of misconduct by the clerk were “unfounded and spur ious.”January Term, 2020

7 {¶ 20} In November 2016, Cramer arrived late for a scheduled hearing. During the hearing, Cramer continued to allege that the court h ad engaged in improper ex parte communications with Taneff and other attorney s involved in the case. On cross-examination, Taneff explained that he had c ontacted the court for the purposes of scheduling hearings and locating documents. Taneff expressly
denied that the contacts with t he court were substantive in nat ure. Cramer
declined the court’s invitation to present evidence to support her allegations that the court had engaged in ex part e communications with other att orneys. {¶ 21} After the magistrate issued a decision confirming the sale of t he real property in November 2016, Cramer filed objections and num erous motions. In these filings, she continued to make disparaging comments ab out the court and Taneff. Among other things, she alleged that Taneff’s prior se rvice as the finance chair of the judge’s political campaign, combined with his mone tary contributions to various other (unidentified) political campaigns, “create in surmountable ethical issues, rendering it inadvisable for the Court to entertain his motions attacking the
heirs.” 1 In early 2017, the chief justice assigned a visiting judge to preside over the probate proceedings. {¶ 22} In her answer to the disciplinary charges brought against her, Cramer continued to impugn the in tegrity of the magistrate and the court and commenced an attack on disciplinary counsel. She renewed her a llegations that the magistrate and opposing counsel had engaged in impermissibl e ex parte communications and had “schemed” to remove her as the fiduciary of the ancillary estate, and she repeatedly alleged that the magistrat e and the judge were

1. We note that although Jud.Cond.R. 2.13(A) requires a judge t o exercise the power of appointment impartially and on the basis of merit and to avoid nepotism, favoritism, and unnecessary appointments, it does not expressly prohibit the ap pointment of persons affiliated with a judge’s campaign. Moreover, Loc.R. 8.1 of the Court of Common Pleas of Franklin County, Probate Division, provides that “[p]ersons appointed by the court to serve as * * * fiduciaries * * * shall be selected from lists maintained by th e court” and requires the court to review those lists periodically t o ensure the equitable distrib ution of those appointments.S UPREME C OURT OF O HIO

8 corrupt. She also claimed that assistant disciplinary counsel had “deliberately prepared a dishonest complaint or [was] incompetent to perform his job” and had engaged in misconduct for the pur pose of covering up the probat e court’s actions by “setting up and framing [Cramer].” Moreover, she denied tha t any of her statements were improper, because the magistrate and the probat e judge “ha[d] shown, repeatedly, that they have no integrity,” and she assert ed that the “insults and threats in [the court’s] order [are] far more intemperate a nd offensive than anything she wrote in protes t of th[e] corruption.” {¶ 23} Although Cramer was given multiple opportunities during her disciplinary hearing to submit evidence or otherwise explain th e basis for her accusations, she adamantly maintained her position that she was the victim of a corrupt court. Her primary defense was that but for collusion on the part of the court, she could not have been removed as the ancillary adminis trator and the
court could not have made its s ubsequent orders. Cramer showed no remorse for
her misconduct. The board found that relator had established b y clear and convincing evidence that Cram er violated Prof.Cond.R. 8.2(a). {¶ 24} Cramer raises seven objections reg arding the board’s findings w ith respect to this count. She claims that several of the board’s factual findings are false, and she argues that the board’s determination that she v iolated Prof.Cond.R. 8.2(a) is not supported by the evidence. {¶ 25} After independently reviewing the record and verifying that the record contains clear and convincing evidence to support the bo ard’s factual findings summarized above, we fi nd that Cramer repeatedly made numerous accusations of judicial impropriety that a reasonable attorney would believe are false. For example, we have held that it is not reasonable for an attorney to allege that a judge has engaged in ex parte communications based solel y on the attorney’s observation of a judge entering his or her chambers with counsel for one party, coupled with the attorney’s speculation about the co ntent of theJanuary Term, 2020

9 communication. See Disciplinary Counsel v. Pullins , 127 Ohio St.3d 436, 2010- Ohio-6241, 940 N.E.2d 952, ¶ 53. {¶ 26} We therefore overrule Cramer’s f irst, fourth, fifth, 13th, 18th , 19th, and 20th objections to the board’s findings of fact, and we fin d that Cramer violated Prof.Cond.R. 8.2(a).
Count Two: Dishonest Conduct and Maki ng False Statements to a Tribunal {¶ 27} Next, the board considered relator’s allegations that Cramer (1 ) misrepresented her authority as the ancillary administrator before her appointment, (2) gave false testimony regarding her forcible en try onto the real property after her authority wa s revoked, and (3) gave false te stimony about the existence of a buyer who was purportedly willing to purchase th e real property for $101,000. {¶ 28} Regarding the first allegation, in a September 29, 2014 order, the magistrate specifically cautione d that she would not appoint Cr amer as the ancillary administrator unless and until she filed the appropri ate documents and bond. Cramer filed the required documents and bond and was app ointed as the ancillary administrator on November 28, 2014. But in October 2 014, Cramer contacted the realtor Lipka had hired to sell the Ohio real pro perty. Cramer told
the realtor that she had been a ppointed the ancillary administr ator and that she had removed the realtor’s sign from th e yard. She demanded that th e realtor immediately withdraw the property from the market and provide c opies of the realtor’s correspondence with Lipka and Myron, and she threaten ed the realtor with legal process if she d id not respond to Cramer’s demand. {¶ 29} With respect to relator’s second allegation, at the probate cou rt’s October 27, 2017 hearing on a motion for sanctions against Cram er, Cramer
testified that after Taneff was appointed as the ancillary admi nistrator, off-duty police officer Patrick Lavender helped her forcibly enter the r eal property with a crowbar. In an affidavit submitted to the probate court—and ag ain in hisS UPREME C OURT OF O HIO

10 testimony before the disciplinary panel—however, Lavender adama ntly denied that he assisted Cramer in the forcible entry of the property. He explained that although he had helped Cramer secure the property while she was serving as the ancillary administrator, he knew that something was wrong when he noticed
different locks on the door aft er the court had revoked Cramer’ s authority. He therefore refused to help her forcibly enter the property. At her disciplinary hearing, Cramer reaffirmed that Lavender had aided her forcible entry of the property and further alleged that Taneff had pressured Lavender into giving false testimony. {¶ 30} Finally, throughout the probate proceedings, Cramer repeatedly represented to the court that she had two buyers who were willi ng to purchase the Ohio property for $101,000. In its December 19, 2017 judgment entry finding that Cramer willfully viol ated Civ.R. 11 and R.C. 2323.51, the probate court made the following finding:

Marilyn Cramer never submitted the mystery $101,000.00+ offer to Mr. Taneff, and during the October 27, 2017 hearing, Marilyn Cramer testified that she did not send the mystery offer to Mr. Taneff’s office. For Marilyn Cramer to claim Mr. Taneff is negligent for not acting on an offer to purchase real estate wh ich she repeatedly failed to submit is duplicitous.

{¶ 31} At her disciplinary hearing, Cramer called at least two witness es in an effort to establish that the prospective buyers were willing to pay far more than Taneff obtained for the real property, but the board found that their testimony did not support that proffer. {¶ 32} On these facts, the board found that Cramer violated Prof.Cond. R. 3.3(a)(1) (prohibiting a lawyer from knowingly making a false s tatement of factJanuary Term, 2020

11 or law to a tribunal) and 8.4(c) (prohibiting a lawyer from eng aging in conduct involving dishonesty, fraud, deceit, or misrepresentation). {¶ 33} The board also noted that Cramer had submitted an affidavit fro m one of the alleged prospective buyers in the underlying probate proceeding but found that his testimony at the disciplinary hearing demonstrat ed that he had no personal knowledge of the facts c ontained in that affidavit. H aving weighed the credibility of that witness and of Cramer, the panel determined that Cramer had drafted the affidavit and submitted it to the probate court and the panel, knowing
that it was false. {¶ 34} Cramer raises six objections to the board’s factual findings wi th respect to this count. As three of those objections, she claim s that she did not misrepresent her authority before becoming the ancillary admini strator, that she did not falsely claim to have a buyer willing to pay between do uble and triple the price that Taneff obtained for th e property, and that she did n ot draft a false
affidavit. {¶ 35} Our review of the record shows that the challenged findings of the board in this regard are amply supported by the evidence. The parties submitted as a joint exhibit a copy of an October 22, 2014 letter to the realtor in which Cramer represented that she had been appointed the administrato r of all the estate’s assets in Franklin County—five weeks before she was ac tually appointed to that role. It is true that Cramer presented testimony regar ding two people who had, at various times, expressed interest in purchasing the property for approximately $100,000, but the reco rd shows that neither of th e potential buyers ever made a written offer to purchase the property. And althou gh one of the potential buyers testified that he needed to assess the conditi on of the house in person before making an offer, he admitted that he never contac ted Taneff or the realtor to inquire about viewing t he property. Instead, he rel ied on Cramer’sS UPREME C OURT OF O HIO

12 representations that Taneff woul d not respond to her requests a bout gaining access to the property. {¶ 36} As her three remaining objections to the board’s findings regar ding Count Two, Cramer asserts that L avender gave false testimony re garding his participation in the forcible en try of the property and that in any event, as an heir with an equitable interest in the real property, Cramer’s forci ble entry could not constitute a trespass—though she offers no legal authority to s upport that position. Because the hearing panel has the opportunity to observe the wi tnesses firsthand, we typically defer to its credibility determinations unless the record weighs heavily against those findings. Cincinnati Bar Assn. v. Statzer , 101 Ohio St.3d 14, 2003-Ohio-6649, 800 N.E.2d 1117, ¶ 8, citing Cleveland Bar Assn. v. Cleary , 93 Ohio St.3d 191, 198, 754 N.E.2d 235 (2001). Here, the recor d supports the panel’s determination that Lavender’s testimony was more credib le than
Cramer’s. {¶ 37} For these reasons, we overrule Cramer’s third, seventh, eighth, and ninth objections to the board’s factual findings and her second objection to the board’s conclusions of law, and we adopt the board’s findings t hat Cramer
violated Prof.Cond.R . 3.3(a)(1) and 8.4(c).

Count Three: Conduct that is Unsupported by the Law, that is Prejudicial to the Administration of Justice, and that Adverse ly Reflects on the Attorney’s Fitness to
Practice Law {¶ 38} The last three allegations of mis conduct against Cramer are tha t she engaged in frivolous conduct that prejudiced the administration of justice and adversely reflects on her fitness to practice law by acting out side the scope of her authority, obstructing the successor ancillary administrator’s ability to sell the real property, and threatening parties and witnesses in the ancillar y probate proceedings.January Term, 2020

13 {¶ 39} In support of these allegations, th e board noted that in the 32 -page judgment entry issued on Decemb er 19, 2017, the probate court f ound that Cramer willfully violated Civ.R . 11 and R.C. 2323.51 and later ordered her to pay Taneff $22,256.65 in fees and costs that it found to be directl y attributable to her
frivolous conduct. The court f ound that Cramer had filed numer ous pleadings and other documents containing “scandalous, insulting, and groundle ss allegations” against the court and had filed actions raising issues that eit her were not before the court or had already been decided—all for the purpose of de lay. In addition,
the court found that Cramer had conducted herself in a manner m eant to harass and intimidate Taneff with supposition and innuendo that had no evidentiary support. Moreover, the court noted that “Cramer failed to gras p the reality that when she was removed as the ancillary administrator, she lost t he ability to dictate the terms of sale of the real estate” and that “[her] bad condu ct and frivolous filings turned what should have b een a simple land sale into a circus devoid of any respect to the court and its officers.” On appeal, the Ten th District Court of Appeals affirmed the probate c ourt’s judgment, overruling 11 of Cramer’s assignments of error and dismissing a 12th. Taneff v. Lipka , 2019-Ohio-887, 124 N.E.3d 859 (10th Dist.). {¶ 40} Based on the probate court’s findings, the board found that Cra mer violated Prof.Cond.R. 3.1 (prohibiting a lawyer from bringing o r defending a proceeding, or asserting or contradicting an issue in a proceed ing, unless there is a
nonfrivolous basis in law and fact for doing so), 8.4(d) (prohi biting a lawyer from engaging in conduct that is prejudicial to the administration o f justice), and 8.4(h) (prohibiting a lawyer from engaging in conduct that adversely r eflects on the lawyer’s fitness to practice law). The board found that Cramer violated Prof.Cond.R. 8.4(h) by engaging in conduct not specifically pro hibited by the
Rules of Professional Conduct that adversely reflected on her f itness to practice
law and that her conduct in violation of other professional-conduct ru les wasS UPREME C OURT OF O HIO

14 sufficiently egregious to warrant an additional finding that sh e violated Prof.Cond.R. 8.4(h). See Disciplinary C ounsel v. Bricker , 137 Ohio St.3d 35, 2013-Ohio-3998, 997 N.E.2d 500, ¶ 21. {¶ 41} Cramer objects to the board’s findings of misconduct with respe ct to this count, arguing that the board was required to review th e evidence de novo
and that it failed to do so becau se it adopted the probate and appellate courts’ findings that she violated Civ.R. 11 and R.C. 2323.51. A disci plinary hearing is not a substitute for an appeal, but regardless, we do not find that the board’s adoption of the proba te court’s factual findings demonstrates t hat the board conducted anything but a de novo review. Having reviewed the r ecord, including Cramer’s numerous filings in the probate proceedings, we find t hat relator has established by clear and convincin g evidence that Cramer violat ed Prof.Cond.R. 3.1, 8.4(d), and 8.4(h). We theref ore overrule Cramer’s second objection to the board’s findings of fact and he r first objection to the board’s conclusions of law.
Sanction {¶ 42} When imposing sanctions for atto rney misconduct, we consider al l relevant factors, including the e thical duties that the lawyer violated, the aggravating and mitigating factors listed in Gov.Bar R. V(13), and the sanctions imposed in similar cases. Aggravating and Mitigating Factors {¶ 43} The board found that just one mitigating factor is present—Cram er has no prior disciplinary record. See Gov.Bar R. V(13)(C)(1). As for aggravating factors, the board found that Cramer had (1) acted with a disho nest and selfish motive, (2) committed multiple offenses, (3) showed a lack of c ooperation in the disciplinary process, (4) submitted false evidence or false sta tements or engaged in deceptive practices during the disciplinary process by submi tting a false affidavit, and (5) refused to acknowledge the wrongful nature o f her conduct. See Gov.Bar R. V(13)(B)(2) and (4) through (7).January Term, 2020

15 {¶ 44} The board offered a nine-page explanation detailing Cramer’s extensive and repeated failure t o cooperate in the disciplinary process. Cramer failed to provide answers to relator’s discovery request and ma de a false allegation that relator had not provided discovery, necessitati ng a formal pretrial hearing to discuss discovery issues. Because Cramer refused to divulge the name of one of the prospective buyers that she had purportedly ident ified for the real property, the panel chair had t o order her to provide the name. {¶ 45} Cramer initially denied that relator had furnished her with a c opy of a transcript, and upon being info rmed that the document had bee n provided in PDF format on a flash drive with other discovery materials, she eventually acknowledged that she had receive d it but stated that she did n ot want to open an “executable” file. Cramer later requested that the board issue all its orders by telephone or text message. The p anel chair denied the request and instructed
Cramer to check her e-mail acc ount on a timely and regular basi s. {¶ 46} After relator objected to Cra mer’s proposed submission of numerous grievances that she had filed against judicial officer s and attorneys, on the ground that those grievances a re required to remain confide ntial prior to a determination of probable cause, see Gov.Bar R. V(8)(A)(1)(a), Cramer stated her
intention to call relator’s couns el as witnesses. In a 13-page response to relator’s motion in limine, Cramer once again made spurious allegations—t his time against
Taneff and relator—and demanded that the complaint against her be dismissed. {¶ 47} Cramer’s failure to cooperate culminated in her conduct during the disciplinary hearing. She arrived more than an hour late on bo th days of the hearing—even after the panel chair had agreed to start the hear ings at 10:00 a.m. and 9:00 a.m., respectively, to accommodate Cramer’s purported sleep disorder. On the first day, Cramer explain ed that it had taken her all ni ght to drive from
Cleveland to Columbus and stated that it was the first time tha t she had made the trip without stopping for the night. On the second day, Cramer called the board atS UPREME C OURT OF O HIO

16 9:02 a.m. to state that she woul d be late because she had slept through her alarms. Although her hotel was only three blocks away, she did not arri ve at the hearing until 10:35 a.m. The panel chair vi ewed Cramer’s tardiness as part of her ongoing pattern of failing to comply w ith the panel’s orders and direct ives. {¶ 48} The board described Cramer’s participation at the hearing as rambling and argumentative, and it noted that she was unable to answer questions without turning the focus to how she had allegedly been victimi zed by the probate court and the disciplinary process. The panel chair repeatedly had to admonish her to answer the question that was being asked. And although Cramer repeatedly referred to the “ever-changing” allegations against her, she ac knowledged that
relator had never filed a n amended complaint. {¶ 49} Cramer was fundamentally unprepared to present her own case; sh e introduced no exhibits and wanted to call a witness using her c ellular phone. Although Cramer claimed to have “exercised due diligence,” she acknowledged that many things were not prepared the way she wanted them prep ared. She stated that she could not do more physically given the unpredic table nature of her disability and the fact that she had worked through the night o n five of the prior eight days. Cramer also indicated that she had retired from th e Department of Justice due to her deteriorating health. But when asked whethe r her physical issues had impacted her ability to practice law, Cramer stated that she had been unaware that her mental and phys ical health would be considered at the hearing.
After relator’s counsel stated th at he intended to file a motio n for an examination pursuant to Gov.Bar R. V(15)(C)(1)(b), Cramer stated that she h ad no objection and would cooperate w ith the exam. {¶ 50} Following the hearing, the panel chair issued an order directin g Cramer to file an amended exhibit list and exhibits on or befor e June 7, 2019, and instructed her to include any reports and documents from a qual ified healthcare professional she wished to have the panel consider in mitigatio n. Cramer filed herJanuary Term, 2020

17 initial exhibit list three days late, supplemented it more than two weeks later, and finally tendered hard copies of all her exhibits more than one month late—but she never submitted any medical records. The panel chair excluded 26 of her 110 exhibits on the ground that they were neither offered nor refer red to at the hearing and excluded one exhibit because it has been previously admitte d. And although the panel chair ordered the parties to file posthearing briefs on or before June 28, 2019, Cramer never complie d with that order. {¶ 51} Cramer raises ten objections to the aggravating and mitigating factors found by the board. But as summarized above, the recor d supports the board’s findings. We therefore overrule objections 10 through 12, 14 through 17, and 21 through 23.
Relevant Precedent {¶ 52} In determining the appropriate sanction to recommend for Cramer’s misconduct, the board noted that the sanctions we have imposed on lawyers who had made false state ments concerning the qualificat ions or integrity of a judicial officer range from a six-month suspension to a tw o-year suspension with the second year stayed on conditions. See, e.g. , Disciplinary Counsel v.
Proctor , 131 Ohio St.3d 215, 2012-Ohio-684, 963 N.E.2d 806 (imposing asixmonth suspension on an attorney who had engaged in undignified or discourteous conduct that was degrading to a tribunal and had recklessly mad e false statements concerning the integrity of a j udicial officer in a motion for relief from judgment and an appellate brief); Disciplinary Counsel v. Marshall , 142 Ohio St.3d 1, 2014-Ohio-4815, 27 N.E.3d 481 (imposing a two-year suspension, with the second year conditionally stayed, on an attorney who had knowin gly or recklessly made in an appellate brief false allegations that a judge’s rul ings against her were influenced by racial and gender bias and had engaged in dishone st conduct that was prejudicial to the administration of justice by distributin g settlement funds in
contravention of a court orde r). However, the panel found this case to be mostS UPREME C OURT OF O HIO

18 similar to two cases in which we imposed indefinite suspensions on attorneys who—like Cramer—repeatedly leveled false or unfounded allegatio ns against judges and opposing counsel and refused to acknowledge the wron gful nature of
their misconduct. {¶ 53} In Disciplinary Counsel v. Frost , 122 Ohio St.3d 219, 2009-Ohio2870, 909 N.E.2d 1271, an attorney falsely accused several comm on-pleas-court judges of bias in the execution of their duties, with “nothing beyond conjecture, rumor, and innuendo” to support her charges, id. at ¶ 9. She also repeatedly leveled against a federal judg e unfounded accusations of racial bias and other impropriety and filed a baseless defamation suit against two at torneys who were her opposing counsel in a sexual-harassment case. As aggravati ng factors, we found that Frost had engaged in dishonesty, a pattern of miscon duct, and multiple offenses, that she had failed to acknowledge the wrongfulness o f her conduct, and that her attacks on judges and other public officials had erode d public confidence in the judiciary. Id . at ¶ 37. Just one mitigating factor was present—the absence of a prior disciplinary record. Id . at ¶ 36. {¶ 54} Similarly, in Disciplinary Counsel v. Pullins , 127 Ohio St.3d 436, 2010-Ohio-6241, 940 N.E.2d 952, an attorney recklessly filed af fidavits of disqualification and other cour t documents containing unfounded accusations against two judges regarding the performance of their official duties. He also falsely notarized a document that he had signed on behalf of hi s wife, submitted that document to a court, and caused two subpoenas to be issued in an inactive case to further his own personal agenda. {¶ 55} As aggravating factors, we found that Pullins had acted with a dishonest and selfish motive, engaged in a pattern of misconduc t, committed multiple offenses, given false a nd dishonest explanations of hi s actions, refused to acknowledge the wrongful nature of his misconduct, and caused h arm to innocent third parties and the reputations of the judges whose integrity he had impugned.January Term, 2020

19 We also attributed aggravating effect to psychological issues t hat remained unaddressed due to Pullins’s premature termination of his contr act with the Ohio Lawyers’ Assistance Program (“OLAP”). Id . at ¶ 82-83. The only mitigating factors were the absence of a prior disciplinary record and Pul lins’s full and free disclosure to the board and coope rative attitude toward the dis ciplinary proceedings. Id . at ¶ 74. {¶ 56} In indefinitely suspending Frost and Pullins for their repeated unfounded attacks on the judicial s ystem and other dishonest co nduct, we noted that their misconduct may have b een related to unaddressed ment al-health disorders. Consequently, we cond itioned their reinstatement to the profession on the submission of proof to a r easonable degree of medical certa inty that they were fit to return to the competent , professional, and ethical pract ice of law. Frost , 122 Ohio St.3d 219, 2009-Ohio-2870, 909 N.E.2d 1271, at ¶ 43; Pullins at ¶ 88. {¶ 57} Like Frost and Pullins, Cramer repeatedly and falsely accused a judge and a magistrate of bias and corruption, refused to ackno wledge the wrongful nature of her conduct, and caused considerable harm—no t only to the public officials whom she had atta cked but also to the judiciar y as a whole. The board also found that Cramer’s conduct throughout the disciplin ary proceedings demonstrated a pattern of disresp ect for the disciplinary proce ss and raised serious questions regarding her fitness to provide competent and profes sional legal representation to her clients going forward. Furthermore, the board expressed
concern that Cramer’s misconduct may be related to unaddressed mental- or physical-health conditions. Therefore, the board recommends th at as conditions of her reinstatement, she be required to (1) submit to an OLAP evaluation and comply with any treatment recommendations arising from that eva luation, (2) submit an opinion from a qualified healthcare professional that she is able to resume the competent, ethical, and professional practice of law , and (3) provide proof that she has paid the f ees and costs assessed on her by t he probate court.S UPREME C OURT OF O HIO

20 {¶ 58} As her final three objections, Cr amer contends that she should not be indefinitely suspended from the practice of law simply for f iling a grievance against a judge, for filing a motion to consolidate hearings an d a motion to remove a politically appointed and negligent ancillary administ rator, or for zealously representing a client within the parameters of the la w. Renewing her claim that the charges against her were “ever-changing,” she ur ges this court to completely exonerate her, dismi ss relator’s complaint, and gran t her other forms
of relief not availa ble in disciplinary proceedings. {¶ 59} Cramer’s objections to the recommended sanction grossly
mischaracterize her conduct in the probate proceedings in an at tempt to recast her actions as an appropriate and reasoned response to the alleged but unsubstantiated
misconduct of others. But we have already overruled more than 20 objections directed at the board’s findings and determined—based on clear and convincing evidence—that she committed the rule violations alleged in rela tor’s complaint. {¶ 60} Cramer’s misconduct, the prese nce of numerous aggravating factors—including the submission of false evidence and statemen ts during this disciplinary proceeding—and the single mitigating factor that C ramer has never before been disciplined by this court, are strikingly similar t o the circumstances in
Frost and Pullins. We therefore overrule Cramer’s last three objections and conclude that the appropriate sa nction in this case is an indef inite suspension. Cramer’s pattern of levying baseless attacks against virtually every person involved in the underlying proba te case has now expanded to inc lude allegations that the panel members and the board have distorted the record, withheld critical facts and evidence, and misled this court. And in her hearing testimony, she steadfastly maintained that she herself had done nothing wrong and she described
her own conduct as “bra ve and exemplary.” {¶ 61} Cramer’s profound inability to recognize the wrongfulness of he r own actions, combined with her tardiness and evident lack of pr eparation for herJanuary Term, 2020

21 own disciplinary hearing, support the board’s finding that her misconduct may be the byproduct of unaddressed physical- or mental-health issues. We therefore agree that her reinstatement to the practice of law must be con ditioned on the submission of proof that she has completed an OLAP assessment, complied with any resulting treatment recommendations, and obtained the opini on of a qualified healthcare professional that she is capable of resuming the com petent, ethical, and professional practice of law.
Conclusion {¶ 62} Accordingly, Marilyn Abrienne C ramer is indefinitely suspended from the practice of law in Ohio. In addition to the condition s for reinstatement set forth in Gov.Bar R. V(25), Cr amer shall be required to subm it proof (1) that she has submitted to an evaluation by OLAP and complied with an y recommendations resulting from that evaluation, (2) that she ha s obtained an opinion from a qualified healthcare professional that she is ab le to resume the competent, ethical, and professi onal practice of law, and (3) t hat she has paid the fees and costs assessed against her in the March 22, 2018 judgm ent entry of the Franklin County Court of Comm on Pleas, Probate Division, in cas e No. 567794A.
Costs are taxed to Cramer. Judgment accordingly.
O’C ONNOR , C.J., and K ENNEDY , F RENCH , F ISCHER , D E W INE , D ONNELLY , and S TEWART , JJ., concur.

_________________ Joseph M. Caligiuri, Disciplinary Counsel, and Donald M. Scheet z, Assistant Disciplinary Counsel, for relator. Marilyn A. Cramer, pro se.

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