Attorney Grievance Commission of Maryland v. Deidra Nicole Proctor ,

Misc. Docket AG No. 1, September Term, 2020. Opinion by Gould, J.

ATTORNEY DISCIPLINE – SANCTIONS – DISBARMENT Court of Appeals disbarred lawyer who made intentio nal misrepresentations to multiple clients, failed to adequately communicate with a cl ient, represented a client while she was not permitted to practice law, overcharged clients for fees and expenses, and also made misrepresentations to the court and Bar Counsel. S uch conduct violated Maryland Attorneys’ Rules of Professional Conduct 19-301.1 ( Competence), 19-301.2 (Scope of Representation and Allocation of Authority Between Client and Attorney), 19-301.3 (Diligence), 19-301.4 (Communication), 19-301.5 (Fe es), 19-301.16 (Declining or Terminating Representation), 19-303.3 (Candor Towar d the Tribunal), 19-305.5 (Unauthorized Practice of Law), 19-308.1 (Bar Admis sion and Disciplinary Matters), and 19-308.4 (Misconduct).Circuit Court for Prince George’s County

Case No.: CAE20-12285 Argued: March 8, 2022 IN THE COURT OF APPEALS
OF MARYLAND Misc. Docket AG No. 1 September Term, 2020

______________________________________ A TTORNEY G RIEVANCE C OMMISSION

O F M ARYLAND

v. D EIDRA N ICOLE P ROCTOR

__________________________________ *Getty, C.J., Watts Hotten Booth Biran Gould McDonald, Robert N. (Senior Judge, Specially Assigned)

JJ.

______________________________________

Opinion by Gould, J.

______________________________________ Filed: July 25, 2022 *Getty, C.J., now a Senior Judge, participated in the hearing and conference of this case while an active member of this Court. After being recalled pursuant to Md. Const., Art. IV, § 3A, he also participated in the decision and adoption of this opinion.On March 11, 2020, the Attorney Grievance Commissi on of Maryland (“AGC”),

acting through Bar Counsel, filed a Petition for Di sciplinary or Remedial Action (the “Petition”) against Deidra Nicole Proctor, pursuant to Maryland Rule 19-721. The Petition alleged that Ms. Proctor violated numerous provisio ns of the Maryland Attorneys’ Rules of Professional Conduct (“MARPC”). 1 In accordance with Maryland Rules 19-722(a) and 19-727, we assigned the Petition to the Honorable C rystal D. Mittelstaedt (“hearing judge”) to hold an evidentiary hearing and render findings of fact and conclusions of law. The hearing was held on September 20, 2021. Bar Co unsel presented its case with no witnesses and 58 exhibits, including the request s for admissions that were deemed admitted. Ms. Proctor appeared pro se . In lieu of closing arguments, the hearing judge asked the parties to submit post-hearing proposed f indings of fact and conclusions of law. Only Bar Counsel chose to do so. On November 4, 2021, the hearing judge issued Findi ngs of Fact and Conclusions of Law (the “findings”), finding by clear and convi ncing evidence that Ms. Proctor violated MARPC 1.1 (Competence), 1.2(a) (Scope of Representa tion and Allocation of Authority Between Client and Attorney), 1.3 (Diligence), 1.4( a) and (b) (Communication), 1.5(a) (Fees), 1.16(d) (Declining or Terminating Represent ation), 3.3 (Candor Towards the

1 Effective July 1, 2016, the Maryland Lawyers’ Rule s of Professional Conduct (“MLRPC”) were renamed the MARPC and recodified wit hout substantive modification in Title 19, Chapter 300 of the Maryland Rules. Gi ven that there are no material differences between the two versions and Ms. Proctor committed violations of said rules prior to and after their renaming, we will refer to all violatio ns herein under their shorter designations as permitted by Rule 19-300.1(22)— e . g ., “Rule 1.1” as opposed to “Rule 19-301.1.”2

Tribunal), 5.5(a) and (b) (Unauthorized Practice of Law), 8.1(a) and (b) (Bar Admission and Disciplinary Matters), and 8.4 (a), (c), and (d ) (Misconduct). 2 Pursuant to Maryland Rule 19-728(b), Ms. Proctor fi led exceptions to the findings. Oral arguments were held before this Court on March 8, 2022. By Per Curiam Order issued March 9, 2022, this Court disbarred Ms. Proc tor. Attorney Grievance Comm’n v

. Proctor , 477 Md. 631 (2022). We now explain why.
BACKGROUND
A. Procedural Context . On November 11, 2020, Ms. Proctor was personally se rved with the Petition, interrogatories, a request for production of docume nts, and a request for admission of fact and genuineness of documents. Pursuant to Maryland Rules 2-421(b), 2-422(c), and 2- 424(b), she had 45 days to respond to Bar Counsel’s discovery requests. 3 Ms. Proctor failed to respond to either the Petition or the dis covery requests, prompting Bar Counsel to move for an order of default on January 26, 2021. Ms. Proctor filed an untimely opposition to the motion, claiming she was never served with t he Petition. On March 1, 2021, Ms. Proctor filed her answer to the Petition. On March 23, 2021, Bar Counsel withdrew its motion for default and re-served its discovery requests on Ms. Proctor by email and regu lar mail, along with a notice of service.

2 The hearing judge’s findings explain Ms. Proctor’s violation of MARPC 8.4(d), but the final order states MARPC 8.4(b). We believ e that was a typographical error.

3 Pursuant to these Rules, she had an extra 15 days beyond the typical 30-day response time to submit the discovery responses bec ause the discovery was served with the Petition.3

Once again, she did not respond. As a result, Bar Counsel filed a motion seeking sanctions and that its requests for admissions of fact and ge nuineness of documents be admitted in accordance with Maryland Rule 2-424(b), or alternat ively, an order compelling Ms. Proctor to answer the requested discovery. On July 16, 202 1, the hearing judge granted Bar Counsel’s motion and ordered Ms. Proctor to respond to the discovery requests by July 26,
2021. Ms. Proctor failed to comply with the discovery ord er, prompting Bar Counsel to again move for sanctions, pursuant to Maryland Rule s 2-432(a) and 2-433, seeking to (1) have the court deem admitted the requests for a dmissions of fact and genuineness of documents; (2) strike Ms. Proctor’s answer; (3) adm it the averments in the Petition; and (4) preclude Ms. Proctor from presenting witnesses or discovery at the hearing and preclude her testimony related to any facts not rel ated to mitigation. On September 16, 2021, the hearing judge granted Bar Counsel’s motio n and prohibited Ms. Proctor from presenting any documents at trial that were not pro duced in discovery.
B. Factual Findings . Ms. Proctor has been a member of the Maryland Bar s ince December 13, 2000. She was temporarily suspended for failing to pay her an nual assessment to the Client Protection Fund for: April 8 - 17, 2003; April 7 - July 4, 200 4; April 10, 2007 - February 28, 2008; March 15 - April 5, 2012; and March 20 - April 3, 2 014. Ms. Proctor continued to practice law during her periods of suspension.4

Between September 10, 2009 and March 8, 2010, Ms. P roctor was decertified from the practice of law due to her failure to submit he r pro bono reporting forms. Despite her decertification, Ms. Proctor continued to practice law.
1. Representation of Robin R . Belfast . Around January 18, 2006, Robin R. Belfast retained Ms. Proctor to represent her in connection with her claim of age and race discrimin ation against her former employer, Verizon Communications (“Verizon”). Verizon dismis sed Ms. Belfast after 27 years, due to a reduction in work force. Prior to retaining M s. Proctor, Ms. Belfast had filed a claim with the Equal Employment Opportunity Commission, w hich issued a right to sue letter on December 29, 2005, giving Ms. Belfast 90 days to fi le a civil complaint against Verizon. Ms. Proctor failed to file the complaint. Over the next six years, Ms. Proctor not only failed to disclose that fact to Ms. Belfast, b ut she affirmatively misrepresented the status of the matter, that the litigation was under way and ongoing. Based on such misrepresentations, Ms. Belfast believed that Ms. P roctor was actively litigating her case and engaging in settlement discussions. For example, on March 12, 2010, Ms. Belfast wrote M s. Proctor to inquire about the status of her case. Three days later, Ms. Proc tor responded with intentionally misleading statements, indicating that she was work ing to resolve the matter and “looking into additional details” of a potential witness. Between August 20, 2010 and December 2011, Ms. Proc tor continued to mislead Ms. Belfast by stating that settlement discussions were ongoing, that she was having discussions with Verizon, and that a trial was sche duled for March 29, 2012.5

After several additional communications indicating that the case was pending, on March 21, 2012, Ms. Proctor finally admitted to Ms. Belfast that there was no lawsuit pending against Verizon. Ms. Proctor feigned uncer tainty whether the blame rested with her for failing to file the complaint, or with the court for failing to properly docket it. In April 2012, Ms. Proctor stated that she would compe nsate Ms. Belfast for the case “should that be necessary,” and then falsely indicated that more could be done on the case and informed Ms. Belfast that she was going to “focus[] on the courts.” On August 13, 2012, Ms. Proctor offered Ms. Belfast $250,000. to settle a potential malpractice claim arising from her neglect of Ms. B elfast’s case. Ms. Proctor did not advise Ms. Belfast that she had a conflict of interest and that Ms. Belfast should seek the advice of other counsel in connection with the proposed se ttlement. Without the benefit of counsel, Ms. Belfast accepted the offer. On Octobe r 9, 2012, Ms. Proctor prepared and provided to Ms. Belfast a written settlement agreem ent which inexplicably reduced her payment obligation to $200,000. Again without the benefit of counsel, Ms. Belfast agreed to the twenty percent reduction in the settlement a mount. Ms. Belfast repeatedly asked for a copy of her file, but Ms. Proctor never provided it to her. Between January and September 2013, Ms. Proctor mad e empty promises, stating that she was waiting for a personal injury settleme nt and trying to obtain a loan in order to pay the settlement. When neither source of funds c ame through, in October 2013, Ms. Proctor offered to pay Ms. Belfast $1,000 a month t owards the settlement. Ms. Proctor made her first payment in November 2013, which was returned for insufficient funds. In6

January 2014, Ms. Proctor made her first $1,000 pay ment and thereafter made only minimal, sporadic payments. In July 2017 and January 2018, fed up with Ms. Pro ctor’s sporadic and unreliable payments, Ms. Belfast told Ms. Proctor that she was going to file a complaint with the AGC and the Maryland State Bar Association if Ms. Proct or did not pay her debt in full immediately. Ms. Proctor attempted to dissuade Ms. Belfast from contacting the AGC by knowingly misrepresenting to Ms. Belfast that the s ettlement amount would likely be relitigated and would “result in a lower amount due, which may ultimately resolve this matter sooner.” When Ms. Belfast filed her complaint with the AGC in January 2018, Ms. Proctor still owed her approximately $224,000, inclusive of late fees stipulated in the settlement agreement. 2. Representation of Antonia G . Colvin . On or about October 13, 2017, Antonia G. Colvin ret ained Ms. Proctor to represent her in her capacity as personal representative for her husband’s estate (the “Estate”). Ms. Proctor agreed to defend a $55,942 disallowed claim made against the Estate by King T. Leatherbury Associates, Inc. (“Leatherbury”). When Ms. Proctor was retained, Ms. Colvin had already been served with the complaint as well as discovery requests. The deadline for completion of discovery was March 18, 2018. On November 13, 2017, Ms. Proctor entered her appea rance and filed an answer to the complaint. Ms. Proctor did not, however, respo nd to the discovery requests or discuss them with Ms. Colvin. Shortly thereafter, Leatherb ury’s counsel served a second request7

for production of documents and a notice of deposit ion. Ms. Proctor stated that she was unavailable on the deposition date. On February 19, 2018, Leatherbury’s counsel wrote M s. Proctor a letter to resolve its unanswered discovery requests and schedule a ne w deposition date. Ms. Proctor replied on February 22, 2018 and indicated that she intende d to file a motion to dismiss and would request an extension for Ms. Colvin’s discovery res ponses until after the motion to dismiss was resolved. The next day, Leatherbury moved for sanctions due to Ms. Colvin’s discovery failure. Ms. Proctor failed to respond t o the motion. On March 27, 2018, the court granted the motion for sanctions, ordered Ms. Colvin to respond to the discovery request within ten days , and ordered Ms. Colvin to pay the fees incurred by Leatherbury’s counsel in connection wit h the motion. Ms. Proctor never disclosed any of this to Ms. Colvin. The parties participated in a settlement conference , which did not resolve the claim. Trial was scheduled for December 13, 2018. Leatherbury filed a second motion for sanctions as a result of Ms. Colvin’s failure to comply with the March 27 order. In opposition t o this motion, Ms. Proctor falsely stated Ms. Colvin’s responses to discovery had been mailed on April 20, 2018. In fact, Ms. Proctor did not mail the responses until November 2 6, 2018. Ms. Proctor filed a pretrial statement and proposed jury instructions and voir dire, which were returned by the court as being deficient

. On December 11, 2018, the court held a hearing on t he second motion for sanctions. Neither Ms. Colvin, who was unaware of the hearing, nor Ms. Proctor appeared. Ms.8

Proctor later claimed she thought the hearing would be conducted by telephone. In their absence, the court granted the second motion for sa nctions, entered default judgment against Ms. Colvin and the Estate, finding a willfu l failure to comply with the March 27th order, and converted the December 13, 2018 trial to a hearing on damages. Prior to the damages hearing, the parties reached a n agreement under which Ms. Colvin would pay Leatherbury $20,000 in full satisf action of its claims. Ms. Colvin had 45 days from December 13, 2018 to make payment in f ull. As a result, the damages hearing was rescheduled for February 14, 2019, in the event that the parties did not fulfill their obligations under the settlement agreement. Ms. Co lvin asked Ms. Proctor for information regarding the settlement, but Ms. Proctor failed to respond. As she had no knowledge of the settlement details, Ms. Colvin did not make the settlement payment within the 45-day period. In January 2019, the court granted Leather bury’s motion for attorneys’ fees in the amount of $2,600. On February 12, 2019, Leatherbury’s counsel informe d Ms. Proctor that the $20,000 settlement was off the table, and that the price of settlement had gone up to $35,000. Ms. Proctor counseled Ms. Colvin to reject the settleme nt because, she predicted, she could get a more favorable result at the February 14 hearing. Unaware that the merits of Leatherbury’s claim had already been determined and that the purpose of the February 14, 2019 hearing was merely to determine damages, Ms. C olvin rejected the $35,000 offer. On February 14, 2019, Leatherbury was awarded the f ull amount of its claim totaling $55,942.9

Ms. Colvin terminated Ms. Proctor’s representation on March 8, 2019. She requested a copy of her file, but Ms. Proctor never responded or provided her with a copy.
3. Representation of Steven W . Barrow . Steven W. Barrow retained Ms. Proctor on February 2 1, 2018 to represent him in connection with his divorce from Alcinda Cirwithian . Under their fee agreement, Ms. Proctor agreed to charge $300 per hour. Mr. Barrow paid an initial retainer of $5,000. On or about February 22, 2018, Mr. Barrow was serve d with process. Ms. Proctor failed to file an answer or enter her appearance or file a motion to transfer venue, as she had stated she would do. Mr. Barrow was served with discovery, which he prov ided to Ms. Proctor. Ms. Proctor failed to respond. Ms. Cirwithian filed a motion for a default judgment, and the court entered an order of default against Mr. Barro w on April 11, 2018. Ms. Proctor reacted to the order of default by entering her appearance, promising opposing counsel that discovery responses would be forthcoming within day s, and filing an untimely motion to transfer venue. The discovery responses were not forthcoming. Oppo sing counsel filed a motion for sanctions and served Ms. Proctor with requests for admissions. On May 7, 2018, Ms. Proctor filed responses to the discovery requests a nd an opposition to the motion for sanctions, assuring the court that the responses ha d been provided. As a result, the motion for sanctions was denied as moot. Ms. Proctor also filed a motion to vacate the default judgment, which the court granted.10

The motion to transfer venue was denied. The court issued a scheduling order requiring all discovery be completed by August 23, 2018. Ms. Proctor never provided Mr. Barrow with a copy of the scheduling order, nor did she inform him of the dates and deadlines set forth therein. On July 25, 2018, Ms. Proctor served untimely disco very requests on Ms. Cirwithian. On August 22, opposing counsel filed a second motio n to compel and for sanctions due to Mr. Barrow’s deficient discovery responses. Mr. Barrow had provided supplemental responses to Ms. Proctor, but Ms. Proctor failed to pass them along to opposing counsel. That same day, Ms. Proctor moved for an extension o f the discovery deadline, which the court denied. The scheduling order had imposed a deadline for fil ing exhibit lists in advance of the pendente lite hearing. Ms. Proctor failed to f ile the exhibit list, resulting in a court order precluding Mr. Barrow from introducing any ex hibits at the hearing. On September 6, Ms. Proctor filed an opposition to the second motion for sanctions, claiming that she had filed extensive discovery res ponses, and was continuing to supplement them. On September 10, the court denied Ms. Proctor’s req uest for an extension of the discovery deadline and scheduled a hearing on the s econd motion for sanctions. On October 19, the court granted opposing counsel’s second motion to compel and for sanctions. The court gave Mr. Barrow ten days to supplement his deficient responses. Ms. Proctor failed to inform Mr. Barrow of this dea dline; instead, she falsely stated that11

the court made no finding and requested further arg ument. The court ordered Mr. Barrow to pay attorneys’ fees in connection with the motio n. After having paid Ms. Proctor $15,230 in fees and another $1,200 for transcripts, 4 Mr. Barrow terminated Ms. Proctor’s representation. On December 4, Mr. Barrow contacted Ms. Proctor to return the monies he had paid for her services. Ms. Proctor never responded to M r. Barrow’s request.
4. Representation of Norman Ireland . On January 1, 2019, Ms. Proctor was retained by Nor man Ireland in connection with his divorce from Althea Jacques-Ireland. Ms. Proct or entered her appearance and filed an answer to the complaint. Ms. Proctor, however, did not serve a copy of the answer on Ms. Jacques-Ireland and declined to respond to her requ ests for a copy.
5. Bar Counsel’s Investigation .

a. Ms . Belfast’s Complaint . On January 20, 2018, Ms. Belfast filed a complaint against Ms. Proctor with the AGC. Bar Counsel sent a letter to Ms. Proctor requ esting her response to the complaint by February 21, 2018. Ms. Proctor failed to respond u ntil February 27, 2018, and then asked Bar Counsel for an extension until March 12, 2018. On March 12, 2018, Ms. Proctor responded, stating t hat, due to “considerable passage of time,” she had “no independent memory of specific dates, witness names or many other facts related to” Ms. Belfast’s case. H owever, she did admit that she did not

4 The transcripts cost only $243.12

file or follow-up regarding the docketing of Ms. Be lfast’s complaint and that she ultimately resolved a potential malpractice claim against her. Ms. Proctor’s response omitted key details, including the numerous misrepresentations that she made to Ms. Belfast and the paltry amount she paid towards the settlement. Bar Counsel was not satisfied with this response and requested additional details on August 13, 2018. On November 5, 2018, Ms. Proctor responded to Bar C ounsel’s August request. She falsely stated that she disclosed her misrepres entation in 2008 and immediately thereafter took responsibility for this omission. She further stated that it took until 2012 to reach a settlement with Ms. Belfast due to extended negotiations concerning Ms. Belfast’s inflated expectations of the value of her claim.
b. Ms . Colvin’s Complaint . On March 11, 2019, Ms. Colvin filed a complaint aga inst Ms. Proctor with the AGC. Bar Counsel requested a response by April 12, 2019. In response to Ms. Proctor’s request for more time, Bar Counsel extended the deadline to May 12, 2019. On June 28, 2019, after having not received a response, Bar Counsel w rote to Ms. Proctor requesting a response by July 12, but again received no response . On August 21, one of Bar Counsel’s investigators traveled to Ms. Proctor’s house and w as advised to leave Bar Counsel’s letters at her front door. Again, Ms. Proctor failed to pr ovide any response.

c. Mr . Barrow’s Complaint . On March 27, 2019, Mr. Barrow filed a complaint aga inst Ms. Proctor with the AGC. On April 16, 2019, Bar Counsel requested that Ms. Proctor respond to Mr. Barrow’s complaint. Having received no response, Bar Counse l again requested a response to the13

complaint in May and June. Ms. Proctor failed to r espond, even after one of Bar Counsel’s investigators left Bar Counsel’s letters at her fro nt door on August 21.
d. Ms . Jacques-Ireland’s Complaint . On April 25, 2019, Ms. Jacques-Ireland filed a comp laint against Ms. Proctor with the AGC. On May 8, 2019, Bar Counsel requested Ms. Proctor’s response to the complaint by May 24, 2019. Having received no response, Bar Counsel reiterated the same request in June and July. Each time, Ms. Proctor did not r espond. Ms. Proctor also did not respond after Bar Counsel’s investigator left Bar Counsel’s letters at her front door on August 21.
STANDARD OF REVIEW This Court has original jurisdiction over attorney discipline proceedings and conducts an independent review of the hearing judge ’s findings of fact and conclusions of law. Attorney Grievance Comm’n v

. Hamilton , 444 Md. 163, 178 (2015). We review the hearing judge’s conclusions of law without deferenc e. Md. Rule 19-740(b)(1). We may treat any facts not challenged by exceptions as est ablished. Rule 19-740(b)(2)(A). Otherwise, we review the record to determine whethe r the hearing judge’s factual findings “have been proved by the requisite standar d of proof set out in Rule 19-727(c).” Rule 19-740(b)(2)(B). Bar Counsel must prove its a llegations of misconduct by clear and convincing evidence. Rule 19-727(c). The attorney must prove any affirmative defenses and any mitigating or extenuating circumstances by a preponderance of the evidence. Id

.14 DISCUSSION
A. Exceptions to the Hearing Judge’s Findings of Fact

. Either party may file exceptions to the hearing jud ge’s conclusions of law or findings of fact. Rule 19-728(b). Here, Bar Couns el has not filed any exceptions. Ms. Proctor, however, has filed five broadly-worded exc eptions to the hearing judge’s findings, as follows: (1) all findings related to Ms. Belfast and the unauthorized practice of law due to the limitations period for bringing this Petitio n; (2) all the findings based on admissions established pursuant to what she contends were erro neous discovery sanctions; (3) the court’s conduct in the May 6, 2021 hearing; (4) all findings related to the unauthorized practice of law, which were erroneous; and (5) all findings relating to Mr. Barrow, Ms. Colvin, and Ms. Jacques-Ireland, because she “had e vidence relating both to the truthfulness of the allegations and to mitigating f actors.” It is unclear whether the latter two exceptions are to factual findings, conclusions of law, or both.
1. Statute of Limitations/Laches Exception . In connection with the Belfast matter and the claim s that she is liable for the unauthorized practice of law, Ms. Proctor argues th at her due process rights were violated by the AGC’s lengthy 14-year delay in filing its Pe tition. She contends she was prejudiced by this delay by virtue of a failing memory with th e passage of time and that she no longer has her notes from the case. We are not persuaded. Ms. Proctor bases her statut e of limitations argument on Section 5-101 of the Courts and Judicial Proceeding s Article of the Maryland Code (2006, 2020 Repl. Vol.), which provides that “[a] civil ac tion at law shall be filed within three15

years from the date it accrues unless another provi sion of the Code provides a different period of time within which an action shall be comm enced.” Ms. Proctor provides no support for her proposition that a disciplinary act ion of this kind is subject to the statute of limitations. In fact, it isn’t. See Anne Arundel Cnty. Bar Ass’n, Inc. v

. Collins , 272 Md. 578, 582 (1974); Attorney Grievance Comm’n v

. Penn , 431 Md. 320, 335 (2013). Thus, we overrule Ms. Proctor’s statute of limitations ex ception. To the extent Ms. Proctor is relying on the doctrin e of laches, that too is unavailing to her. In Attorney Grievance Comm’n v

. Cassilly , 476 Md. 309, 348 (2021), we held that, “with the possible exception of cases involving bot h extraordinary circumstances of delay and actual prejudice resulting in a clear due proce ss violation, applying the doctrine of laches to attorney discipline proceedings would not be consistent with the goal of such proceedings, which is to protect the public.” Thus , a respondent has a steep hill to climb to succeed with a laches defense. Here, Ms. Proctor does not come within striking dis tance of meeting this exacting standard. The delays in the Belfast matter were of her own making and directly resulted from her intentional and continuous misrepresentati ons and her other professional misconduct. Ms. Belfast did not become aware that Ms. Proctor never filed her complaint against Verizon until 2012, six years after Ms. Pro ctor was retained and six years after Ms. Proctor failed to file. Ms. Proctor’s malfeasance continued with the drafting of an agreement to settle Ms. Belfast’s claims against he r because she neither informed Ms. Belfast of the conflict of interest between them no r advised her to seek advice from independent counsel. Between 2012 and 2013, Ms. Pr octor continued to make empty16

promises of payment and made minimal periodic payme nts for the next four years. In late 2017, after Ms. Belfast indicated she intended to c ontact the AGC regarding Ms. Proctor’s conduct and her failure to make payments, Ms. Proct or made a last-ditch effort to prevent intervention from the AGC by making knowingly false statements to Ms. Belfast regarding the actions the AGC would take. Ms. Belfast filed her claim with the AGC in January 2018. The AGC began investigating Ms. Proctor’s conduct and more compla ints began rolling in. Specifically, Ms. Colvin filed her complaint on March 11, 2019, M r. Barrow filed his complaint on March 27, 2019, and Ms. Jacques-Ireland filed her c omplaint on April 25, 2019. Due to the influx of complaints, the AGC had more to inves tigate and, for efficiency purposes, reasonably brought a consolidated proceeding to add ress all of the complaints. Moreover, Ms. Proctor refused to cooperate with the investiga tion. Her misconduct unquestionably caused delays in the investigation and contributed significantly to the Petition not being filed until 2020. As such, Ms. Proctor has failed to meet the steep requirements of a viable laches defense. We therefore overrule Ms. Proctor’s exceptions base d on laches. 5
2. General Exception to all Findings of Fact . Ms. Proctor excepts to all the hearing judge’s find ings of fact because they resulted from facts established as a result of allegedly imp roper discovery sanctions. She contends

5 Ms. Proctor’s only general exception to the hearin g judge’s findings pertaining to Ms. Belfast was based on a violation of due process . Given that we overruled this exception, and she did not except to the hearing ju dge’s finding on any other basis, we see no basis to address her unsupported claim.17

that she was never properly served with the discove ry requests, and therefore she was not required to respond. She complains that the hearin g judge declined her request for a continuance to give her time to supplement her disc overy responses, and sanctioned her without finding that the delay prejudiced Bar Couns el. Ms. Proctor’s exceptions are without merit. After agreeing to withdraw the motion for default, Bar Counsel re-served Ms. Proctor with the discovery requests both by regular mail and email, as confirmed in the notice of servi ce provided therewith. Ms. Proctor acknowledged receipt of that email. Ms. Proctor cl aims she never received the hard copies of the discovery requests, and that the requests fo r admissions had over 1,400 pages of documents attached thereto. But Ms. Proctor never moved to strike the service as improper or deficient. Nor did she move for a protective or der because the discovery was too burdensome. See Attorney Grievance Comm’n v

. McCarthy , 473 Md. 462, 484 n.8 (2021). Bar Counsel patiently gave Ms. Proctor several oppo rtunities to comply with the discovery requests before moving for sanctions. As to the first motion for sanctions, the hearing judge chose not to sanction Ms. Proctor in favor of giving her an opportunity to come into compliance with her discovery obligations . The hearing judge gave Ms. Proctor 10 days to fully respond in an order that was both emailed and mailed to her. Nonetheless, Ms. Proctor failed to comply, claiming she didn’t g et the order because she moved out of her home, and the U.S. Postal Service failed to for ward her mail. And she contends that she didn’t check her email because she was “separat ed from her computer on an ongoing basis.” The hearing judge justifiably faulted Ms. Proctor for her failure to keep informed about the case.18

We will now address Ms. Proctor’s failure to timel y respond to the requests for admissions. Maryland Rule 2-424(b) provides: Each matter of which an admission is requested shal l be deemed admitted unless, within 30 days after service of the request or within 15 days after the date on which that party’s initial pleading or moti on is required, whichever is later, the party to whom the request is directed serves a response signed by the party or the party’s attorney. As to each matt er of which an admission is requested, the response shall set forth each reques t for admission and shall specify an objection, or shall admit or deny the ma tter, or shall set forth in detail the reason why the respondent cannot truthfu lly admit or deny it. The reasons for any objection shall be stated. A denia l shall fairly meet the substance of the requested admission, and when good faith requires that a party qualify an answer or deny only a part of the matter of which an admission is requested, the party shall specify so much of it as is true and deny or qualify the remainder. A respondent may no t give lack of information or knowledge as a reason for failure to admit or deny unless the respondent states that after reasonable inquiry the information known or readily obtainable by the respondent is insufficien t to enable the respondent to admit or deny. A party who considers that a mat ter of which an admission is requested presents a genuine issue for trial may not, on that ground alone, object to the request but the party may, subject to the provisions of section (e) of this Rule, deny the matter or set forth reas ons for not being able to admit or deny it. Under this Rule, the requests were automatically d eemed admitted due to Ms. Proctor’s failure to timely respond. Subsection (d ) of this Rule provides that a party in Ms. Proctor’s shoes may move to withdraw the admissions to the requests, which the court may grant if it “finds that it would assist the present ation of the merits of the action and the party who obtained the admission fails to satisfy the cou rt that withdrawal or amendment will prejudice the party in maintaining the action or de fense on the merits.” Here, Ms. Proctor filed no such motion. The requests were, therefore , properly deemed admitted. Turning now to the sanctions against Ms. Proctor, Maryland Rule 2-432(a) provides:19

A discovering party may move for sanctions under Ru le 2-433 (a), without first obtaining an order compelling discovery under section (b) of this Rule, if a party or any officer, director, or managing ag ent of a party or a person designated under Rule 2-412 (d) to testify on behal f of a party, fails to appear before the officer who is to take that person’s dep osition, after proper notice, or if a party fails to serve a response to interrog atories under Rule 2-421 or to a request for production or inspection under Rul e 2-422, after proper service. Any such failure may not be excused on th e ground that the discovery sought is objectionable unless a protecti ve order has been obtained under Rule 2-403. A hearing judge is “vested with broad discretion in imposing sanctions when a party fails to comply with [discovery] rules.” Attorney Grievance Comm’n v

. Kreamer , 404 Md. 282, 342 (2008). Our role is to review the record to determine whether the court considered the relevant factors identified in Taliaferro v

. State , 295 Md. 376 (1983). See Butler v

. S & S Partnership , 435 Md. 635, 650 (2013). The Taliaferro factors are: whether the disclosure violation was technical or s ubstantial, the timing of the ultimate disclosure, the reason, if any, for th e violation, the degree of prejudice to the parties respectively offering and opposing the evidence, whether any resulting prejudice might be cured by a postponement and, if so, the overall desirability of a continuance. Id

. (quoting Taliaferro , 295 Md. at 390-91). At the hearing on the second sanctions motion, Ms. Proctor went through these factors and argued that they weighed against sancti oning her and in favor of another extension of the 120-day deadline for commencing th e hearing. 6 The transcript from the

6 Rule 19-727(d) provides that “[u]nless extended by the Court of Appeals, the [attorney disciplinary] hearing shall be completed within 120 days after service on the attorney of the order entered under Rule 19-722.” As later discussed, earlier in the case, the parties filed a Consent Motion for Extension of Time to Complete Hearing of Charges (the “consent motion”), which this Court granted, d ue to the service issue raised by Ms. Proctor.20

hearing shows that the hearing judge did, in fact, consider Ms. Proctor’s arguments. Indeed, the hearing judge took the matter under adv isement and issued a written order later that day. We are satisfied from our review of the record that the hearing judge understood the facts and circumstances surrounding Ms. Proctor’s d iscovery failures and acted well within her considerable discretion in entering the sanctio ns order. 7 Accordingly, we overrule Ms. Proctor’s exceptions based on the discovery rulings made by the hearing judge.
3. General Exceptions to the May 6, 2021 Hearing. We turn now to Ms. Proctor’s exceptions to the find ings based on the hearing judge’s conduct at the May 6, 2021 hearing. Ms. Pr octor asserts that the hearing judge informed her that before a hearing would be schedul ed in this case, Bar Counsel would need to file a motion with the Court of Appeals and wait for that motion to be granted. This, she contends, gave Ms. Proctor “no choice” ex cept to consent to an extension. Ms. Proctor further contends that she was unfamiliar wi th the process at that time, and was therefore strong-armed into consenting to this moti on. She argues that the hearing judge’s instruction was incorrect, erroneous, and resulted in unspecified prejudice to her. We overrule this exception. The May 6 hearing was a scheduling conference where all parties agreed that (1) all discovery would be completed by July 30, 2021; (2) all

7 In any event, the hearing judge’s sanction prohibi ting her from introducing documents was hardly a draconian measure, given Ms. Proctor’s contention that she had no documents to produce.21

dispositive motions and motions in limine would be filed by August 13, 2021; and (3) that a two-day, non-jury trial would be held on Septembe r 20 and 21, 2021. Pursuant to Maryland Rule 19-272(e), Ms. Proctor’s attorney grievance matter was required to be heard within 120 days from the date on which she was served. The parties agreed to use February 19, 2021 as the date of serv ice. Based on this date, the 120-day deadline would be June 19, 2021. Pursuant to Rule 19-722(d), Bar Counsel was required to file the consent motion to obtain this Court’s a pproval for an extension of time. Ms. Proctor’s exception fails for three simple reas ons. First , she consented to the motion; that she did so lacking a familiarity with the process was of her own choosing. Second , the extension of the 120-day period was necessita ted because of the issue of service that Ms. Proctor raised. Third , Ms. Proctor failed to articulate any prejudice to her from the extension, and no such prejudice is discernible in this record.
B. Conclusions of Law . From the foregoing factual findings, the hearing ju dge found by clear and convincing evidence that Ms. Proctor violated MARPC 1.1, 1.2(a), 1.3, 1.4(a) and (b), 1.5(a), 1.16(d), 3.3(a), 5.5(a) and (b), 8.1(a) and (b), and 8.4(a), (c), and (d). We will now address each of the hearing judge’s con clusions of law. In sum, we agree with the hearing judge’s findings and overrul e Ms. Proctor’s remaining exceptions.
1. MARPC 1 . 1 (Competence) . MARPC 1.1 requires attorneys to give competent repr esentation to all clients. In order to provide competent representation to a clie nt, an attorney must apply “appropriate knowledge, skill, thoroughness, and preparation to the client’s issues.” Attorney Grievance22

Comm’n v

. Brooks , 476 Md. 97, 131 (2021) (quoting Attorney Grievance Comm’n v

. Rheinstein , 466 Md. 648, 709 (2020), reconsideration denied (Feb. 28, 2020), c ert

. denied sub nom

. Rheinstein v

. Attorney Grievance Comm’n , ___ U.S. ___, 141 S. Ct. 370 (2020)). An attorney demonstrates incompetence by failing to act in a timely fashion that may result in harm to the client. Attorney Grievance Comm’n v

. Brown , 426 Md. 298, 319 (2012). Similarly, an attorney demonstrates incomp etence by failing to file necessary motions or failing to appear at a hearing. Attorney Grievance Comm’n v

. Walker-Turner , 428 Md. 214, 226-28 (2012). The hearing judge found that Ms. Proctor provided i ncompetent representation to Ms. Belfast when she failed to timely file the laws uit against Verizon. The hearing judge found that Ms. Proctor provided incompetent represe ntation to Ms. Colvin due to her insufficient responses to discovery and the motion for sanctions, failing to correct these responses, ignoring a court order, and failing to a ppear at a hearing on Ms. Colvin’s behalf. And the hearing judge found that Ms. Proctor provid ed incompetent representation to Mr. Barrow by failing to inform him of relevant deadlin es, failing to timely respond or propound discovery, and failing to timely file a mo tion to transfer venue. These findings are supported by clear and convincing evidence. Although Ms. Proctor does not expressly except to t he hearing judge’s conclusion that she violated MARPC 1.1, she implicitly does so by excepting to all findings related to Ms. Colvin and Mr. Barrow. Ms. Proctor avers that she has evidence that could refute the allegations against her, and that she reduced her c ase load when she became aware that the AGC would be pursuing a disciplinary action against her. The short answer is this: if Ms.23

Proctor had such evidence, then she should have pro duced it in discovery, and she should have timely responded to the requests for admission s. Having overruled her exceptions regarding the discovery sanctions, we likewise over rule her exceptions to the hearing judge’s findings here.
2. MARPC 1 . 2 (Scope of Representation) . MARPC 1.2(a) provides: Subject to sections (c) and (d) of this Rule, an at torney shall abide by a client’s decisions concerning the objectives of the representation and, when appropriate, shall consult with the client as to th e means by which they are to be pursued. An attorney may take such action on behalf of the client as is impliedly authorized to carry out the representatio n. An attorney shall abide by a client’s decision whether to settle a matter. In a criminal case, the attorney shall abide by the client’s decision, afte r consultation with the attorney, as to a plea to be entered, whether to wa ive jury trial and whether the client will testify. A client is entitled “to make informed decisions as to the objectives of the representation[].” Attorney Grievance Comm’n v

. Shapiro , 441 Md. 367, 380 (2015). An attorney who deprives a client of this power by fai ling to give sufficient updates concerning his case violates MARPC 1.2(a). Id . Likewise, this Rule is also violated when an att orney does not follow a client’s instructions or adequate ly pursue a client’s claim. See Attorney
Grievance Comm’n v

. Moore , 451 Md. 55, 80 (2017) (finding a violation of MAR PC 1.2(a) when an attorney did not attempt to settle a client ’s case despite the client’s instructions);
Brown , 426 Md. at 320 (finding a violation of MARPC 1.2( a) when an attorney failed to pursue a client’s claim and did not inform the clie nt of discovery sanctions due to the attorney’s idleness); Attorney Grievance Comm’n v. Reinhardt , 391 Md. 209, 218 (2006)24

(ignoring a client’s repeated request for updates c oncerning her case and failing to take the requisite action to resolve her case amounted to a violation of MARPC 1.2(a)). The hearing judge concluded that Ms. Proctor violat ed MARPC 1.2 for the same reasons that she violated MARPC 1.1 and 1.4, as dis cussed below. Ms. Proctor repeatedly failed to pursue her clients’ claims when she did n ot file Ms. Belfast’s lawsuit and failed to file and respond to motions during her represent ation of Ms. Colvin and Mr. Barrow. She further failed to inform her clients of the sta tus of their respective cases, which deprived them of the ability to make informed decis ions about their matters. The hearing judge’s conclusion is supported by clear and convin cing evidence.
3. MARPC 1 . 3 (Diligence) . MARPC 1.3 requires an attorney to “act with reasona ble diligence and promptness in representing a client.” This Rule can be violat ed when an attorney fails to communicate with the client or fails to “advance the client’s c ause or endeavor[.]” Attorney Grievance
Comm’n v

. Bah , 468 Md. 179, 208 (2020) (quoting Attorney Grievance Comm’n v

. Edwards , 462 Md. 642, 699 (2019)); see also Attorney Grievance Comm’n v

. Smith-Scott , 469 Md. 281, 340 (2020) (noting that a violation of MARPC 1.1 and/or 1.4 can constitute a violation of 1.3). The hearing judge found that this Rule was violated when Ms. Proctor declined to serve a copy of Mr. Ireland’s answer on Ms. Jacques -Ireland and ignored her requests for said copy. The hearing judge further found that Ms . Proctor violated this Rule during her representation of Ms. Belfast, Ms. Colvin, and Mr. Barrow for the same reasons she was25

in violation of MARPC 1.1 and 1.4. The hearing jud ge’s conclusion that Ms. Proctor violated this Rule is supported by clear and convin cing evidence. Here again, Ms. Proctor does not specifically excep t to the hearing judge’s conclusion that she violated MARPC 1.3, but excepts generally to all findings related to Ms. Jacques-Ireland for the same reasons she except ed to all findings relating to the Colvin and Barrow matters. As with her prior objection, i f Ms. Proctor had evidence that was helpful to her, then she should have produced it in discovery, and she should have timely responded to the requests for admissions. As she d id not, we overrule her exception.
4. MARPC 1 . 4 (Communication) . MARPC 1.4 provides: (a) An attorney shall: (1) promptly inform the client of any decision or c ircumstance with respect to which the client’s informed consent, as defined in Rule 19-301.0 (f) (1.0), is required by these Rules; (2) keep the client reasonably informed about the s tatus of the matter; (3) promptly comply with reasonable requests for in formation; and (4) consult with the client about any relevant limi tation on the attorney’s conduct when the attorney knows that the client exp ects assistance not permitted by the Maryland Attorneys’ Rules of Profe ssional Conduct or other law. (b) An attorney shall explain a matter to the exten t reasonably necessary to permit the client to make informed decisions regard ing the representation. MARPC 1.4 can be violated if a client has made seve ral “reasonable requests for information, which may include a general status upd ate or for documents pertaining to the case[,]” to no avail. Attorney Grievance Comm’n v

. Planta , 467 Md. 319, 349 (2020); Attorney Grievance Comm’n v

. Dailey , 474 Md. 679, 705 (2021). A violation may also occur if an attorney makes misrepresentations to he r client concerning the status of their26

case. Attorney Grievance Comm’n v

. Fox , 417 Md. 504, 517 (2010). In both instances, a client would be unable to make an informed decision regarding the representation. Id

. The hearing judge concluded that MARPC 1.4(a) was v iolated when Ms. Proctor failed to communicate with Ms. Belfast, Ms. Colvin, and Mr. Barrow about the status of their respective cases. Similarly, she failed to i nform her clients of the adverse developments in their cases due to her errors and o missions. The hearing judge’s conclusion that Ms. Proctor violated this Rule is s upported by clear and convincing evidence.
5. MARPC 1 . 5 (Fees) . MARPC 1.5(a) provides: An attorney shall not make an agreement for, charge , or collect an unreasonable fee or an unreasonable amount for expe nses. The factors to be considered in determining the reasonableness of a f ee include the following: (1) the time and labor required, the novelty and di fficulty of the questions involved, and the skill requisite to perform the le gal service properly; (2) the likelihood, if apparent to the client, that the acceptance of the particular employment will preclude other employmen t of the attorney; (3) the fee customarily charged in the locality for similar legal services; (4) the amount involved and the results obtained; (5) the time limitations imposed by the client or b y the circumstances; (6) the nature and length of the professional relat ionship with the client; (7) the experience, reputation, and ability of the attorney or attorneys performing the services; and (8) whether the fee is fixed or contingent. In determining whether a fee is unreasonable, this Court does not limit its analysis to the fee at the inception of the representation. Attorney Grievance Comm’n v

. Garrett , 427 Md. 209, 224 (2012). Rather, we also examine t he fee at the conclusion of the representation in relation to the services provided

. See Planta , 467 Md. at 350-51; Attorney27

Grievance Comm’n v

. Patterson , 421 Md. 708, 732 (2011) (holding that an attorney ’s lack of diligence and competence may cause a fee to be u nreasonable at the conclusion of representation). The hearing judge determined that this rule was vio lated when Ms. Proctor collected an unreasonable amount of fees from Mr. Barrow. Al though no issue was found on the face of their fee agreement, those fees later becam e unreasonable because of the lack of competent or diligent representation that Ms. Proct or provided. Additionally, this Rule was violated when Ms. Proctor charged Mr. Barrow $1 ,200. for transcripts that only cost $243—a markup of nearly 500%—without any explanatio n or justification. The hearing judge’s conclusion of law that Ms. Proctor violated MARPC 1.5(a) is supported by clear and convincing evidence.
6. MARPC 1 . 16 (Declining or Terminating Representation) . MARPC 1.16(d) provides: Upon termination of representation, an attorney sha ll take steps to the extent reasonably practicable to protect a client’s intere sts, such as giving reasonable notice to the client, allowing time for employment of another attorney, surrendering papers and property to which the client is entitled and refunding any advance payment of fee or expense tha t has not been earned or incurred. The attorney may retain papers relati ng to the client to the extent permitted by other law. The hearing judge determined that Ms. Proctor viola ted MARPC 1.16(d) when she failed to provide Ms. Belfast and Ms. Colvin with a copy of their files and failed to respond to their requests for those files in any manner. R egarding Mr. Barrow, this Rule was violated when Ms. Proctor declined to return any of the unreasonable fees collected in connection with her representation. We agree and f ind that the hearing judge’s conclusion28

is supported by clear and convincing evidence. See Hamilton , 444 Md. at 191 (failing to return unreasonable fees is a violation of MARPC 1. 16(d)); Brown , 426 Md. at 322 (holding that an attorney is required to give a cli ent a copy of their file at the conclusion of representation when requested, and the failure to d o so is a violation of MARPC 1.16(d)).
7. MARPC 3 . 3 (Candor Toward the Tribunal) . MARPC 3.3(a)(1) prohibits an attorney from knowingl y making or failing to correct “false statement[s] of fact or law to a tribunal . . . .” An attorney also must always be truthful to the inquiry board. Attorney Grievance Comm’n v

. Butler , 456 Md. 227, 238 (2017). The hearing judge concluded that Ms. Proctor violat ed this Rule in connection with her representation of Ms. Colvin on November 27, 20 18, when she falsely stated that she mailed Ms. Colvin’s discovery responses to opposing counsel on April 20, 2018, and that she was never made aware that the responses were no t received. This conclusion is supported by clear and convincing evidence.
8. MARPC 5 . 5 (Unauthorized Practice of Law; Multi-Jurisdiction al Practice of Law). MARPC 5.5 provides, in part: (a) An attorney shall not practice law in a jurisdi ction in violation of the regulation of the legal profession in that jurisdic tion, or assist another in doing so. (b) An attorney who is not admitted to practice in this jurisdiction shall not: (1) except as authorized by these Rules or other la w, establish an office or other systematic and continuous presence in this ju risdiction for the practice of law; or (2) hold out to the public or otherwise represent t hat the attorney is admitted to practice law in this jurisdiction.29

An attorney who engages in the practice of law whil e decertified or suspended from the Maryland Bar is in violation of MARPC 5.5. Attorney Grievance Comm’n v

. Agiliga , 422 Md. 613, 624 (2011). There is no bright line t est we employ to establish if an individual engaged in the unauthorized practice of law. Rather, when determining whether an attorney violated MARPC 5.5(a), we focus our ana lysis “on whether the activity in question required legal knowledge and skill in orde r to apply legal principles and precedent.” Attorney Grievance Comm’n v

. Tanko , 427 Md. 15, 45 (2012) (quoting Attorney Grievance Comm’n v

. Hallmon , 343 Md. 390, 397 (1996)) (citation omitted). Examples of activities that we have held to constit ute the practice of law are preparing or interpreting legal documents, “the giving of legal advice, or the application of legal principles to problems of any complexity[.]” Attorney Grievance Comm’n v

. Lang , 461 Md. 1, 33 (2018) (quoting Hallmon , 343 Md. at 397). In determining whether MARPC 5.5(b) has been violat ed, we also consider whether the attorney maintained a “continuous presence in t his jurisdiction for the practice of law.” Attorney Grievance Comm’n v

. Thompson , 462 Md. 112, 128 (2018) (citing Md. Rule MARPC 5.5(b)(1)), reinstatement granted sub nom

. Matter of Thompson , 463 Md. 614 (2019). This presence could be in the form of hold ing oneself out as an attorney or maintaining an office for the practice of law. Attorney Grievance Comm’n v

. Jackson , 477 Md. 174. 198-200 (2022). Moreover, an attorney’s f ailure to inform her client that she is suspended or decertified from the practice of law a lso violates this Rule. See Attorney
Grievance Comm’n v

. Maignan , 423 Md. 191, 203 (2011).30

The hearing judge found that Ms. Proctor violated t his Rule on two occasions. The first was during the time periods when she was temp orarily suspended from the practice of law due to her failure to pay her annual assessment to the Client Protection Fund. The second was when she was temporarily decertified fro m the practice of law due to her failure to submit pro bono reporting forms. Ms. Proctor excepts to this finding. She claims th at she should not have been forced to defend herself against allegations that occurred seven to 18 years prior to the filing of the Petition. She additionally contends that when the Petition was filed, she had no records or recollection relevant to her payment of the annu al dues. Finally, she avers that the hearing judge’s conclusion is unsupported since the re were no specific examples given of when she practiced law during the periods when she was temporarily suspended or decertified. 8 We overrule Ms. Proctor’s exception. One period wh en Ms. Proctor was suspended from the practice of law was between March 15 and A pril 5, 2012. On March 21, however, Ms. Proctor improperly provided legal advice to Ms. Belfast when she stated that there was no case pending against Verizon and that she was un sure of whether she failed to file the lawsuit or whether it was improperly docketed. Thu s, the hearing judge’s conclusion of law that Ms. Proctor violated MARPC 5.5(a) is suppo rted by clear and convincing evidence.

8 Since we have already disposed of Ms. Proctor’s ar gument regarding the unauthorized practice of law allegations not being barred by the statute of limitations, we will only focus on the portion of Ms. Proctor’s arg ument relating to the hearing judge’s lack of evidence to support this finding.31

In addition, Ms. Proctor did not inform Ms. Belfast of her temporary suspension or her decertification from the practice of law. Rath er, she continued in her representation of Ms. Belfast. Therefore, we find that the hearing j udge’s finding that Ms. Proctor violated MARPC 5.5(b) is supported by clear and convincing e vidence.
9. MARPC 8 . 1 (Bar Admission and Disciplinary Matters) . MARPC 8.1, in part, provides: An applicant for admission or reinstatement to the bar, or an attorney in connection with a bar admission application or in c onnection with a disciplinary matter, shall not: (a) knowingly make a false statement of material fa ct; or (b) fail to disclose a fact necessary to correct a misapprehension known by the person to have arisen in the matter, or knowing ly fail to respond to a lawful demand for information from an admissions or disciplinary authority, except that this Rule does not require disclosure o f information otherwise protected by Rule 19-301.6. The hearing judge concluded Ms. Proctor violated MA RPC 8.1(a) when on November 5, 2018, she told Bar Counsel that in 2008 , she had informed Ms. Belfast that she failed to file a lawsuit against Verizon and to ok responsibility for her failure. Additionally, she violated this Rule when she state d that between 2008 and 2012, she had extensive negotiations with Ms. Belfast regarding t he unrealistic value of her case. These statements were knowingly false, in violation of MA RPC 8.1(a). See Thompson , 462 Md.
at 129 (making knowingly false statements to the AGC in an effort to paint oneself in a better light was a violation of MARPC 8.1(a)); see also Attorney Grievance Comm’n v. O’Leary , 433 Md. 2, 26 (2013) (misleading the AGC during t heir investigation was a violation of MARPC 8.1(a)).32

The hearing judge concluded that Ms. Proctor viola ted MARPC 8.1(b) between March 2019 and July 2019 when she failed to respond to Bar Counsel’s many attempts to contact her regarding the complaints that were file d against her. The hearing judge’s conclusion of law that Ms. Proc tor violated MARPC 8.1 is supported by clear and convincing evidence. See Attorney Grievance Comm’n v

. Harmon , 433 Md. 612, 626-27 (2013) (finding a violation of MARPC 8.1(b) when an attorney repeatedly failed to respond to the AGC’s investiga tive inquiries).
10. MARPC 8 . 4 (Misconduct) . MARPC 8.4, in relevant part, states: It is professional misconduct for an attorney to: (a) violate or attempt to violate the Maryland Atto rneys’ Rules of Professional Conduct, knowingly assist or induce an other to do so, or do so through the acts of another;
*** (c) engage in conduct involving dishonesty, fraud, deceit or misrepresentation; [or] (d) engage in conduct that is prejudicial to the ad ministration of justice[.] The hearing judge found that Ms. Proctor violated M ARPC 8.4(a) due to her other rule violations. Because Ms. Proctor violated seve ral MARPC Rules, we find that this conclusion of law is supported by clear and convinc ing evidence. See Attorney Grievance
Comm’n v

. Sanderson , 465 Md. 1, 64 (2019) (noting how committing viola tions of other MARPC also violates MARPC 8.4(a)). The hearing judge found that Ms. Proctor violated M ARPC 8.4(c) during her representation of Ms. Belfast, Ms. Colvin, and Mr. Barrow. Regarding Ms. Belfast and33

Mr. Barrow, Ms. Proctor made several misrepresentat ions to conceal her wrongdoing and attempted to dissuade Ms. Belfast from filing a com plaint with the AGC. She further violated this Rule in connection with Ms. Colvin fo r the same reasons that she violated MARPC 3.3, falsely stating that she mailed Ms. Colv in’s discovery responses to opposing counsel on April 20, 2018 and that she was never ma de aware that the responses were not received. We affirm the hearing judge’s finding as to this vi olation. See Attorney Grievance
Comm’n v

. Mixter , 441 Md. 416, 523-24 (2015) (holding that an attor ney’s “dishonest and misrepresentative actions” violated MARPC 8.4(c)); Rheinstein , 466 Md. at 716-17 (explaining how an attorney who commits a violation of MARPC 3.3(a) usually also violates MARPC 8.4(c) due to the commonalities betw een those rules). When an attorney’s actions “bring the legal profess ion into disrepute[,]” she has committed a violation of MARPC 8.4(d). Attorney Grievance Comm’n v

. Plank , 453 Md. 446, 465 (2017) (citation omitted). This includes “acts of dishonesty and incompetence, [and even] intentional representations to Bar Couns el[.]” Dailey , 474 Md. at 710. In all four matters and during the AGC’s investigation, Ms . Proctor repeatedly engaged in egregious conduct that would adversely affect the p ublic’s opinion of the legal profession. Rheinstein , 466 Md. at 719 (recurring misconduct constitutes a violation of MARPC 8.4(d)). Therefore, we find the hearing judge’s co nclusion of law that Ms. Proctor violated MARPC 8.4 is supported by clear and convincing evid ence. SANCTION34

This Court has determined the appropriate sanction for Ms. Proctor’s conduct. Bar Counsel urged that we disbar Ms. Proctor; Ms. Proct or contended that a definite one-year suspension would be more appropriate. We agreed wi th Bar Counsel. We sanction attorney misconduct with the purpose of safeguarding the public from those unfit to practice law, not to punish the atto rney. Attorney Grievance Comm’n v

. Karambelas , 473 Md. 134, 176-77 (2021). We will assess the i ndividual circumstances, inclusive of any mitigating or aggravating factors, of each case in order to determine a sanction commensurate to the violations committed. Id . at 177.
A. Mitigating Factors . We recognize the following mitigating factors in co nsidering the appropriate sanction: (1) the absence of prior attorney discipline; (2) t he absence of a dishonest or selfish motive; (3) personal or emotional problems; (4) timely good faith efforts to make restitution or to rectify the misco nduct’s consequences; (5) full and free disclosure to [Bar Counsel] or a coop erative attitude toward the attorney discipline proceeding; (6) inexperience in the practice of law; (7) character or reputation; (8) a physical disability; (9) a mental disability or chemical dependency, including alcoholism or drug a buse, where: (a) there is medical evidence that the lawyer is affected by a chemical dependency or mental disability; (b) the chemical dependency or m ental disability caused the misconduct; (c) the lawyer’s recovery from the chemical dependency or mental disability is demonstrated by a meaningful a nd sustained period of successful rehabilitation; and (d) the recovery arr ested the misconduct, and the misconduct’s recurrence is unlikely; (10) delay in the attorney discipline proceeding; (11) the imposition of other penalties or sanctions; (12) remorse; (13) remoteness of prior violations of the MLRPC; a nd (14) unlikelihood of repetition of the misconduct.35

Attorney Grievance Comm’n v

. Allenbaugh , 450 Md. 250, 277-78 (2016) (citing Attorney
Grievance Comm’n v

. Shuler , 443 Md. 494, 506-07 (2015)). Ms. Proctor did not offer any mitigating factors and none were found.
B. Aggravating Factors . The Court also considers the following aggravating factors: (1) prior attorney discipline; (2) a dishonest or s elfish motive; (3) a pattern of misconduct; (4) multiple violations of the [MARP C]; (5) bad faith obstruction of the attorney discipline proceeding b y intentionally failing to comply with the Maryland Rules or orders of this Co urt or the hearing judge; (6) submission of false evidence, false statements, or other deceptive practices during the attorney discipline proceeding ; (7) a refusal to acknowledge the misconduct's wrongful nature; (8) t he victim’s vulnerability; (9) substantial experience in the pr actice of law; (10) indifference to making restitution or rectifyi ng the misconduct’s consequences; (11) illegal conduct, including that involving the use of controlled substances; and (12) likelihood of repet ition of the misconduct. Attorney Grievance Comm’n v

. Sperling , 459 Md. 194, 275 (2018). The hearing judge found that Bar Counsel proved eight aggravating fac tors by clear and convincing evidence. We agree.
First , the hearing judge found that Ms. Proctor had a di shonest or selfish motive. Ms. Proctor made several misrepresentations to conc eal the true status of Ms. Belfast’s case and made false statements surrounding their se ttlement agreement to deter Ms. Belfast from filing a complaint with the AGC. Ms. Proctor also had a dishonest and selfish motive in connection with her representation of Ms. Colvin by falsely stating that Ms. Colvin’s discovery responses were mailed to opposing counsel and that she was unaware they were never received. She had a dishonest and selfish mo tive in connection with her representation of Mr. Barrow when she knowingly mis represented the outcome of the36

hearing and failed to advise him that he had 10 day s to supplement his discovery responses. She also displayed a dishonest or selfish motive wh en she overcharged Mr. Barrow for the transcripts. Second , the hearing judge found that Ms. Proctor exhibite d a pattern of misconduct, evidenced by her repeated failings to file pleading s, motions, and discovery, and to inform her clients of these shortcomings. Third , as evidenced by our above analysis on MARPC viola tions, Ms. Proctor committed numerous violations while representing he r clients and during Bar Counsel’s investigation. Fourth , Ms. Proctor engaged in bad faith obstruction of t he disciplinary process by intentionally making false statements to Bar Counse l and refusing to comply with the lawful requests for information regarding the compl aints filed against her. Fifth , during her disciplinary hearing, Ms. Proctor made knowingly false statements and submitted false evidence. Ms. Proctor falsely stated that she never received Bar Counsel’s discovery requests, falsely stated that s he was never served by the process server and that the affidavit submitted by the process ser ver was untrue, and falsely claimed that she mailed discovery responses to Bar Counsel. Sixth , Ms. Proctor has not acknowledged the wrongful nat ure of her conduct. She still avers that she was never served with the requ ests for admissions and that the hearing judge “erroneously” ordered discovery sanctions. M s. Proctor also does not appear to accept responsibility for the allegations from Ms. Colvin, Ms. Jacques-Ireland, and Mr. Barrow. For each of those matters, she claims that she has evidence pertaining “both to37

the truthfulness of the allegations and to mitigati ng factors.” Ms. Proctor has clearly not fully appreciated the extent of her misconduct. Seventh , Ms. Proctor has been admitted to the Maryland Bar for approximately 22 years, which is a substantial amount of experience. Thus, she was or should have been aware of her professional obligations and the serio usness of her actions.
Last , Ms. Proctor has repeatedly failed to make payment s to Ms. Belfast pursuant to their settlement agreement. She similarly faile d to reimburse Ms. Colvin and Mr. Barrow for the sanctions they were assessed because of her failings in their cases or to refund Mr. Barrow for any part of the unreasonable fee she collected. These actions evidence Ms. Proctor’s unwillingness to make her cl ients whole for the damage she has caused.
C. Analysis . Ms. Proctor’s transgressions involve intentional di shonesty and the unauthorized practice of law. In Attorney Grievance Commission v

. Vanderlinde , 364 Md. 376, 418 (2001), this Court found that disbarment is often t he appropriate sanction when the attorney’s wrongful actions involve dishonesty. We cautioned that [o]nly if the circumstances are that compelling, wi ll we even consider imposing less than the most severe sanction of disb arment in cases of stealing, dishonesty, fraudulent conduct, the inten tional misappropriation of funds or other serious criminal conduct, whether oc curring in the practice of law, or otherwise. Id . at 414. On the other hand, when there has been n o misappropriation of money, intentional dishonesty has not always resulted in d isbarment. See, e

. g ., Attorney Grievance
Comm’n v

. Keating , 471 Md. 614, 656 (2020); Attorney Grievance Comm’n v

. Lane , 36738

Md. 633, 646-47 (2002) (“We have not, however, alwa ys found disbarment to be the appropriate sanction where there is misrepresentati on involved, especially where misappropriation of money was not involved.”). It all depends, of course, on the specific facts and circumstances of each case. Attorney Grievance Comm’n v

. Bonner , 477 Md. 576, 622 (2022) (citing Attorney Grievance Comm’n v

. Palmer , 417 Md. 185, 211 (2010)). In our recent decision in Attorney Grievance Commission v

. Collins , 477 Md. 482, 529-530 (2022), we reexamined when intentional dish onest conduct would warrant disbarment under the standard set forth in Vanderlinde , 364 Md. at 367. 9 There, we analyzed AGC cases post- Vanderlinde and observed that disbarment has generally been warranted in cases where intentional dishonest cond uct has also been accompanied by “theft, fraud, harm to a client or third party, or the intentional misappropriation of funds.” Id . at 530.

9 Under Vanderlinde , intentional dishonest conduct, absent compelling circumstances, justified disbarment. 364 Md. at 41 8-19. We created a standard that provided: in cases of intentional dishonesty, misappropriatio n cases, fraud, stealing, serious criminal conduct and the like, we will not accept, as “compelling extenuating circumstances,” anything less than the most serious and utterly debilitating mental or physical health conditions, arising from any source that is the “root cause” of the misconduct and that also result in an attorney’s utter inability to conform his or her conduct in accordan ce with the law and with the M[A]RPC. Only if the circumstances are that co mpelling, will we even consider imposing less than the most severe sanctio n of disbarment in cases of stealing, dishonesty, fraudulent conduct, the in tentional misappropriation of funds or other serious criminal conduct, whether occurring in the practice of law, or otherwise. Vanderlinde , 364 Md. at 413-14.39

With this in mind, we turn to the specific facts an d circumstances of Ms. Proctor’s case. As previously stated, she engaged in conduct involving intentional dishonesty, including lying to her clients, Bar Counsel, and th e tribunal. Due to this behavior alone, disbarment is generally warranted. See Hamilton , 444 Md. at 200; Lane , 367 Md. at 647; Vanderlinde , 364 Md. at 418. Ms. Proctor’s misconduct directly harmed her client s. Her clients lost claims and defenses due to her serial neglect, paid unreasonab le fees, and were deprived of important information necessary to make informed decisions ab out their cases. Our review of prior attorney misconduct cases informs us that Ms. Proct or’s actions align with the cases in which we have imposed the sanction of disbarment. See, e

. g ., Attorney Grievance Comm’n

v . McCarthy , 473 Md. 462, 507 (2021) (disbarring an attorney w ho engaged in self-serving, dishonest behavior that resulted in harm to his cli ent); Attorney Grievance Comm’n v

. Armstrong , 471 Md. 537, 608-09, 612 (2020) (disbarring an at torney who got his client’s case dismissed with prejudice due to the attorney’s failure to respond to discovery, and causing a different client to be deported by missin g a filing deadline for asylum); Attorney
Grievance Comm’n v

. Miller , 467 Md. 176, 237-38 (2020) (disbarring an attorne y who made misrepresentations that resulted in harm to he r client); Attorney Grievance Comm’n

v . Bleecker , 414 Md. 147, 180 (2010) (disbarring an attorney w ho harmed his client by concealing that he missed the statute of limitation s to file a client’s case). Ms. Proctor further failed to demonstrate any “comp elling extenuating circumstances” to justify a sanction less than disb arment. Collins , 477 Md. at 530; Vanderlinde , 364 Md. at 413-14. Her allegations that she was having emotional difficulties40

as a result of the complaint filed by Ms. Belfast a nd that the filing affected her representation in her other client matters did not satisfy the standard. Ms. Proctor neither produced any evidence at trial to support this asse rtion nor did she offer any mitigating factors. See Bonner , 477 Md. at 617. Accordingly, we determine that d isbarment is the appropriate sanction.