The Supreme Court of Georgia on Monday issued the following attorney discipline opinions:

In the Supreme Court of Georgia

Decided: May 7, 2018

S17Y1993. IN THE MATTER OF EDWARD NEAL DAVIS.

PER CURIAM.

This disciplinary matter is before the Court on the report of Special Master Michael E. Sumner, who recommends that the Court accept the petition for voluntary discipline filed by Respondent Edward Neal Davis (State Bar No. 208220), pursuant to Bar Rule 4-227 (c), following the issuance of a Formal Complaint charging him with a variety of violations of the Georgia Rules of Professional Conduct, including, but not limited to, violations of Rules 1.15 (I) (a), 1.15 (II) (b), and 8.4 (a) (4), see Bar Rule 4-102 (d). After discovery and settlement negotiations, Davis, with the approval of the State Bar, agreed that he would submit the underlying petition, admitting only that he violated Rules 1.15 (I) (a) and 1.15 (II) (b), and seeking a Review Panel Reprimand, although the maximum penalty for a violation of Rules 1.15 (I) and (II) is disbarment.

In his petition, Davis admitted conduct which would appear to violate Rules 1.15 (I) and 1.15 (II)1 and recited factors he believed should mitigate the level of discipline to be imposed. He also addressed the conduct underlying the alleged violation of Rule 8.4 (a) (4),2 but refused to admit that he had violated that Rule. The Bar did not oppose Davis's petition for voluntary discipline,
which resulted from negotiations that concluded prior to the issuance of this Court's decisions in In the Matter of West, 300 Ga. 777 (798 SE2d 219) (2017) (rejecting petition for voluntary discipline in part because admitted facts showed what seemed to be a violation of Rule 8.4 (a) (4) but attorney denied any such violation, and the Bar took no position on the matter), and In the Matter of Iwu, 301 Ga. 52 (799 SE2d 155) (2017) (rejecting a petition for voluntary discipline
where attorney admitted facts that supported the conclusion that he violated Rule 8.4 (a) (4), but he declined to admit such a violation). In light of those two opinions, the Bar repeatedly urged Davis to include in his petition an admission that he violated Rule 8.4 (a) (4) by notarizing a signature on a deed which had not been executed in his presence, but Davis refused to do so, claiming instead that he did not violate the Rule because he had no intent to violate the Rule
when he notarized the deed and because no harm flowed from his actions.

But Rule 8.4 (a) (4) plainly states that “[i]t shall be a violation of the Georgia Rules of Professional Conduct for a lawyer to . . . engage in professional conduct involving dishonesty, fraud, deceit[,] or misrepresentation.” It contains no requirement that harm result from an attorney's conduct and, to the extent that Rule 8.4 (a) (4) contains an implicit intent element, that element is not focused on whether the attorney intended to violate the rule. See In the Matter of West, 301 Ga. 901 (804 SE2d 340) (2017) (accepting West's renewed petition for voluntary discipline and recognizing the State Bar's position that Rule 8.4 (a) (4) contains an implicit requirement that
the attorney's conduct be intended or likely to mislead or deceive another).

To be sure, Davis's professed lack of intent to violate Rule 8.4 (a) (4) and the absence of harm resulting from his violation of that Rule may well provide mitigating circumstances with regard to the level of discipline to be imposed, see In the Matter of Swain, 290 Ga. 678, 679 (725 SE2d 244) (2012) (recognizing lack of intent to cause harm as a factor in mitigation of discipline for violation of Rule 8.4 (a) (4)); see also In the Matter of Morse, 266 Ga. 652

(470 SE2d 232) (1996) (this Court looks to the ABA Standards for Imposing Lawyer Sanctions for guidance in determining the appropriate sanction); ABA Standards 4.6, 5.1, 6.1, and 7.0 (addressing factors to be considered in determining the appropriate level of discipline for various types of cases involving an attorney's dishonesty, fraud, deceit, or misrepresentation); and ABA Standard 9.3 (listing factors in mitigation of discipline). Nevertheless, the fact remains that Davis admitted knowingly notarizing a signature on a deed, thereby attesting–falsely as it turns out–that the deed had been signed in his presence by the person whose “signature” appeared thereon. In light of Davis's admissions and the fact that the Bar has taken no position on whether the evidence is sufficient to establish by clear and convincing evidence that Davis's
actions amount to a violation of Rule 8.4 (a) (4), compare In the Matter of West, 301 Ga. at 904 (acknowledging the Bar's admission that, in light of the specific circumstances of West's case, “it is not a foregone conclusion that a violation of Rule 8.4 (a) (4) could be demonstrated by clear and convincing evidence”), the Court rejects Davis's petition for voluntary discipline.

Petition for voluntary discipline rejected. All the Justices concur.

1 The facts supporting the alleged violations of Rules 1.15 (I) and (II) are not discussed herein given the Court's rejection of Davis's petition for voluntary discipline.

2 Specifically, Davis admitted that he notarized the signatures of his clients, a married
couple, on a deed purporting to transfer certain real estate from his clients to a corporate
buyer and states that he did so believing that the wife actually had signed the deed. Although
it was later discovered that the husband had signed his wife's name on the deed, Davis claims
that his notarization caused no harm as the closing proceeds were paid jointly to the couple
and deposited into their joint account and as the wife later ratified the sale of the property,
which ratification is of record in the Taylor County Deed Records.

3 Although this case may seem similar to In the Matter of West, 301 Ga. at 901, the
two cases are distinguishable because that case involved an attorney who admittedly signed
his immigration client's name, without express permission, in several places on an initial
application for asylum, but who represented (1) that he did so knowing that an applicant for
asylum is allowed to amend or supplement his application freely up until the time of the
hearing; (2) that the general practice in this area of the law is to freely allow subsequent
amendments or supplements to asylum applications; and (3) that his intention was always to supplement the application in a timely manner with his client's real signature and other pertinent information. As evidence that his intent was not to deceive, West pointed to the fact that he left several sections of the asylum application unsigned, knowing that the client would sign them before his case proceeded to an appearance, at which time the applicant would be required to sign an affirmation that explicitly addresses whether any prior misstatements in the application were in need of correction. West asserted that Rule 8.4 contains an implicit intent element (i.e., that the attorney engaged in the conduct with the intent to or with knowledge that it could mislead or deceive another) and that his admitted conduct did not establish any intent to deceive anyone. And, in its response to West's renewed petition, the Bar conceded that, despite its investigation into West's conduct, it might not be able to prove by clear and convincing evidence that West acted with the intent to deceive anyone when he signed his client's name to the initial asylum application. Based on that record, this Court agreed to accept West's renewed petition for voluntary discipline without an admission of a Rule 8.4 (a) (4) violation. But none of those factors are present in the record currently available to the Court in this case. Instead, it appears that Davis notarized the wife's signature despite full knowledge that she had not signed the document in his presence and his position apparently is that his bare “belief” that she actually had signed the document relieved him of any responsibilities he undertook in notarizing the deed. The record does not reflect what if any steps Davis took to assure himself that the wife actually signed the deed or that she even agreed to the sale of property referenced therein. Nor does the record currently reflect that Davis notarized the deed due to some pressing circumstance or with the intention of correcting the effects of his omission at some point in the future. Further, Davis does not even appear to acknowledge the wrongful nature of his conduct. In short, this Court finds the two cases distinguishable.

In the Supreme Court of Georgia

Decided: May 7, 2018

S18Y0456, S18Y0457, S18Y0458.

IN THE MATTER OF RONALD JOHN DOEVE (three cases).

PER CURIAM.

These three matters are before the Court on the Report and Recommendation of the Review Panel, recommending the disbarment of Ronald John Doeve (State Bar No. 224735) for financial misconduct and misrepresentations made in the Bar disciplinary proceedings. These matters arose with the State Bar's filing of three formal complaints, which were considered together before the special master, the Honorable Robert J. Castellani.

All three matters are related to Doeve's representation of Vivify Holdings, Inc. and Jason Herring, one of Vivify's corporate officers. The facts, as found by the special master and supported by the record, are as follows: In SDBD No. 6851, Doeve agreed to act as escrow agent for a $100,000 investment that an investor wished to make in Vivify. Doeve agreed not to disburse the funds without the investor's approval. However, Doeve disbursed the funds to Vivify the same day the funds were wired to his trust account. Doeve failed to communicate with the investor to confirm receipt of the funds or disbursement of the funds and failed to respond to the investor's inquiries and to provide an accounting.

In SDBD No. 6853, Doeve agreed to represent a former client in obtaining funds owed by Herring. He also agreed to assist the former client's husband, the husband's company, and the former client's lawyer in obtaining funds owed by Herring. Doeve and Herring falsely represented to these individuals that Herring had $2,000,000 in available funds and that Herring had deposited $460,000 into Doeve's Chase Private Client account, which was not a trust account; Doeve wrote checks totaling $460,000 to the former client and others from the Chase account, but those checks were returned for insufficient funds. Doeve failed to provide an accounting and provided misleading information about the cause of the non-payment and when they could expect to be paid. Doeve also provided misleading information regarding this matter in the Bar disciplinary proceedings.

In SDBD No. 6854, Doeve agreed to assist Herring in paying legal fees to a lawyer who had represented Herring's girlfriend. An intermediary was needed because the lawyer would not accept Herring's check since Herring had previously provided the lawyer with an insufficient funds check. Doeve misled the lawyer about whether he had received funds from Herring, and although Doeve later agreed to pay the lawyer $15,000, he wrote the lawyer an insufficient-funds check from an account that was not a trust account. Doeve continued to mislead the lawyer about the cause for the returned check and when he could expect to be paid.

The special master found that by these actions, Doeve violated Rules 1.15 (I) and (II), 1.15 III (b) (2), and 8.4 (a) (4) of the Georgia Rules of Professional Conduct found in Bar Rule 4-102 (d). The maximum sanction for a violation of each of these Rules is disbarment.

The special master found as aggravating factors that Doeve acted with a selfish or dishonest motive; that he showed indifference to making restitution; that he made false statements in the disciplinary process; that he had substantial experience in the practice of law, having been admitted to the Bar in 1982; and that the facts in the three matters showed a pattern of misconduct. The special master recommended disbarment as the appropriate sanction.

After Doeve filed exceptions to the special master's report and sought review by the Review Panel, he filed a petition for voluntary discipline and an amended petition, in which he admitted violating Rules 1.15 (I), 1.15 (II), and 1.15 (III) (b) (2) and sought to “tender his license.”1 The Review Panel did not address the newly filed petitions for voluntary discipline, but adopted the special master's report and likewise recommended disbarment.

In this Court, Doeve filed exceptions to the Review Panel's report. However, Doeve's exceptions do not challenge the crux of the allegations against him, and, in fact, he has submitted to this Court a petition for voluntary discipline, admitting violations of Rules 1.15 (I) and (II) and Rule 1.15 (III) (b) (2).

Having reviewed the record, and in light of Doeve's admissions of serious violations of the rules governing financial matters and trust accounts, we agree that disbarment is the appropriate sanction. See In the Matter of Axam, 297 Ga. 786 (778 SE2d 222) (2015) (accepting petition for voluntary surrender of license where attorney received $100,000; did not place it in, or administer it from, his trust account; and disbursed the funds according to his client's
instructions rather than the instructions of the owner of the funds); In the Matter of Harris, 301 Ga. 378 (801 SE2d 39) (2017) (disbarring lawyer who issued insufficient-funds checks from trust account and commingled personal funds with trust account funds); In the Matter of Choi, 297 Ga. 793 (778 SE2d 228) (2015) (accepting voluntary surrender of license where attorney failed to
properly manage substantial funds entrusted to him in a fiduciary capacity).

Therefore, it is hereby ordered that the name of Ronald John Doeve be removed from the rolls of persons authorized to practice law in the State of Georgia. Doeve is reminded of his duties pursuant to Bar Rule 4-219 (c).

Disbarred. All the Justices concur.

1 The petition did not cite either Rule 4-110 (f) (petition for voluntary surrender of license is tantamount to disbarment) or Rule 1-208 (c) (petition for leave to resign Bar membership shall contain statement that there are no disciplinary actions pending).

In the Supreme Court of Georgia

Decided: May 7, 2018

S18Y0740. IN THE MATTER OF RICARDO L. POLK.

PER CURIAM.

This matter is before the Court on the petition for voluntary discipline filed by Ricardo L. Polk (State Bar No. 001354) pursuant to Bar Rule 4-227 (b) prior to the issuance of a formal complaint. Polk requests that we accept his petition and impose discipline to run concurrently with the suspension with conditions he is already serving. See In the Matter of Polk, 295 Ga. 215 (758 SE2d 830) (2014) (accepting Polk's fifth petition for voluntary discipline for violations of Rules 1.3, 1.4, and 1.16 of the Georgia Rules of Professional Conduct in connection with the representation of three clients, imposing a 30-month suspension, and requiring restitution of $1,000 to one client and evaluation by the State Bar's Law Practice Management Department) (“Polk I”). See also In the Matter of Polk, 299 Ga. 746 (791 SE2d 771) (2016) (accepting Polk's petition for voluntary discipline for violations of Rules 1.16 and 9.3 and imposing a suspension to run concurrently with the one imposed in Polk I but adding as additional conditions on reinstatement that Polk repay $1,500 to clients he represented in 2012 and $1,500 to another client) (“Polk II”).

In his latest petition, Polk, who has been a member of the Bar since 2004, admits that in May 2013 a client retained him for representation with regard to two separate criminal charges in municipal court; that they agreed on a flat fee of $1,500 for each charge; that Polk appeared on his client's behalf multiple times between June and October of 2013; and that at Polk's last appearance, both cases were transferred to state court because the client wanted a jury trial. Polk asserts that after this Court suspended his license to practice law in May 2014 (in Polk I), he notified all of his clients including this particular client of that suspension. Polk claims that he was honest and straightforward with the client and told the client that he could no longer represent the client; that the client needed to find another attorney right away; that he would assist the client in that regard; and that he would transfer the client's file to the new attorney.
Polk asserts that at the time of these discussions the client had no scheduled hearings in state court or otherwise. Polk claims that the client contacted him a year later demanding a full return of his retainer, but that after discussion, he and the client agreed that Polk would return only $1,000 of the retainer. Polk claims that he told the client that he would be unable to return the $1,000 at that time, however, because he was unemployed. Polk says that his last communication with the client was on December 8, 2015, and that the client has not made any attempts to communicate since then. Polk asserts that it is still his intention to reimburse the $1,000 to the client, but admits that he has not yet done so.

Polk admits that as a result of his interactions with this client, the Bar served him with a Notice of Investigation, advising that it had found probable cause to believe that he violated both Rule 1.16 (d) and Rule 8.4 (a) (4).1 Polk denies that he violated Rule 8.4, and although he contends that he never knowingly or willingly violated Rule 1.16, he admits that he ultimately violated
Rule 1.16 (d) to the extent that he has not refunded the $1,000 to his client.

We agree that the facts, as recited by Polk in his petition for voluntary discipline, do not suggest a Rule 8.4 (a) (4) violation. Compare In the Matter of West, 300 Ga. 777 (798 SE2d 219) (2017) (rejecting an uncontested petition for voluntary discipline where the admitted facts strongly suggested a violation of Rule 8.4 but the petitioner declined to admit such a violation and the Bar failed to address the matter). We also agree that Polk's admitted actions amount to a
violation of Rule 1.16 (d). The maximum sanction for a Rule 1.16 violation is ordinarily a public reprimand. However, Bar Rule 4-103, which says that a finding of a third or subsequent disciplinary infraction shall constitute discretionary grounds for suspension or disbarment, increases Polk's potential sanction; he not only has the prior infractions for which suspensions were imposed in Polk I and Polk II, but also an earlier three-month suspension arising from his admitted violations of Rules 1.3, 1.16, 3.2, and 5.5 as to four other clients, see In the Matter of Polk, 288 Ga. 63 (701 SE2d 161) (2010). Moreover, although Polk acknowledged no factors in aggravation of punishment, we note that in addition to the three suspensions discussed above, Polk's disciplinary history shows two administrative suspensions for failure to pay Bar dues in 2008 and 2015 and another administrative suspension from February 2010 to July 2011 for his failure to pay child support. See Polk II, 299 Ga. at 747; Bar Rule 1-209.

We accept as factors in mitigation in this matter that Polk lacks a dishonest or selfish motive, that he is remorseful, that he acknowledges the wrongful nature of his behavior, and that he has a cooperative attitude toward these disciplinary proceedings. But as we made clear in Polk II, we do not agree with Polk's assertion that his willingness to make restitution should count as a factor in mitigation, because despite that willingness, the fact remains that he has not actually paid restitution. See 299 Ga. at 748. We also reject Polk's assertion that his prior disciplinary violations, all of which occurred in the past decade, are “remote” within the meaning of Standard 9.2 (m) of the ABA Standards for Imposing Lawyer Sanctions, which allows remoteness of prior offenses to be considered in mitigation of discipline. Compare In the Matter of
Winningham, 285 Ga. 175 (674 SE2d 877) (2009) (noting in mitigation that the attorney's prior disciplinary offense occurred more than 35 years earlier); In the Matter of Geary, 281 Ga. 554, 254 (640 SE2d 253) (2007) (recognizing in mitigation that two of the attorney's disciplinary offenses occurred more than ten years earlier). Finally, although Polk urges this Court to consider that his difficulties in this matter arose from “financial struggles” caused in part by his
earlier suspension from the practice of law, the ABA Standards do not separately recognize financial difficulties as a mitigating factor, and we do not believe that the disciplinary consequences of attorney misconduct should be considered in mitigation of additional misconduct.

Although the time portions of the suspensions imposed in Polk I and Polk II expired in November 2016, Polk appears to remain suspended based on his failure to fulfill the restitution conditions on reinstatement that we imposed in those decisions. Polk does not specify what discipline he is seeking for his new violation of Rule 1.16 (d), but he implies that he would accept a suspension to run concurrently with the suspensions he is still serving and he says that he
should be required to refund the full $1,000 to his client prior to seeking reinstatement. The State Bar represents that Polk is seeking a concurrent suspension with a new condition on reinstatement; argues that suspension is the appropriate discipline given the circumstances of this case and Bar Rule 4-103; and urges the Court to accept Polk's petition for voluntary discipline.

We have reviewed the record, and given the facts of this case, particularly Polk's extensive prior disciplinary history that evidences an ongoing and consistent failure to comply with his obligations as a lawyer, we conclude that the discipline requested in this matter is inadequate. Indeed, Polk seems to be seeking as punishment for his latest professional misconduct merely an order directing him to pay his client what he already agreed to pay the client in late 2015 and should repay the client independent of any order by this Court. The “suspension” he offers to accept would add no time at all to the suspensions he is already serving because he has not repaid his other clients. Accordingly, we reject Polk's petition for a voluntary discipline.

Petition for voluntary discipline rejected. All the Justices concur.

1 Rule 1.16 (d) says: “Upon termination of representation, a lawyer shall take steps to the extent reasonably practicable to protect a client's interests, such as giving reasonable notice to the client, allowing time for employment of other counsel, surrendering papers and property to which the client is entitled and refunding any advance payment of fee that has not been earned.” Rule 8.4 (a) (4) says it is a violation of the Rules for a lawyer to “engage in professional conduct involving dishonesty, fraud, deceit or misrepresentation.”

In the Supreme Court of Georgia

Decided: May 7, 2018

S18Y0821. IN THE MATTER OF DAVID E. MORGAN, III.

PER CURIAM.

This disciplinary matter is before the Court on the petition for voluntary discipline filed by Respondent David E. Morgan, III (State Bar No. 522250) prior to the filing of a formal complaint. Morgan, who has been a member of the State Bar since 1978, seeks a two-year suspension with conditions for reinstatement for his admitted violations of Rules 1.15 (I) (b) (1) and (2) (ii), 1.15 (II) (b), and 8.4 (a) (4), the maximum penalty for a violation of each Rule being disbarment. The State Bar has responded, recommending that this Court accept the petition, and this Court agrees to do so.

Morgan unconditionally admits that in 2010, his client left an estate to his heirs that included 366 acres of undivided timber land located in Wilcox County, Georgia. In 2012, he was appointed executor of the client's estate and was responsible for managing the sale of harvested timber, collecting rent from a tenant-farmer, and paying the property taxes. On January 20, 2012, Morgan opened an estate checking account where he deposited monthly rent and proceeds from timber sales and from which he withdrew property tax payments; the annual rent paid by the tenant-farmer was $4,100, the annual property taxes were $2,000, and proceeds from the timber sales fluctuated depending on the amount harvested. Morgan admits that on May 24, 2017, a hearing was convened in the probate court of Wilcox County to settle the estate's accounts; that prior to the hearing, Morgan filed with the probate court bank statements, timber sales information, and a check in the amount of $77,027.21 payable to
the estate from his trust account; that during the hearing, he admitted he had withdrawn funds from the estate checking account and deposited those funds into his trust account for personal use; and that the $77,027.21 check was provided to the probate court as full repayment of the stolen estate funds before anyone was aware of his misconduct. Accordingly, the probate court entered an order finding that Morgan, as the executor, breached his fiduciary duties in transferring estate funds into an account under his control for his personal use. Morgan further states that, in 2010, his wife of 30 years, for whom he provided long-term care due to a terminal illness, passed away; that he suffered from anxiety and depression and often had suicidal thoughts as a result of his loss but never sought treatment; and that in response to his loss he developed an intimate relationship with a family friend, whom he married in 2011, and began spending excessively.

Morgan admits that by his conduct he violated Rule 1.15 (I) (b) (1) and (2) (ii), Rule 1.15 (II) (b), and Rule 8.4 (a) (4) of the Georgia Rules of Professional Conduct found in Bar Rule 4-102 (d). The maximum sanction for a violation of each of these Rules is disbarment.

Morgan admits that, in aggravation, he acted dishonestly and selfishly when he transferred funds from the estate checking account into his trust account and withdrew the funds for his own personal use, see American Bar Association Standards for Imposing Lawyer Sanctions Standard 9.22 (b) (dishonest or selfish motive), and that he has 29 years of experience practicing law, see ABA Standard 9.22 (i) (substantial experience practicing law). See also In the Matter of Morse, 266 Ga. 652 (470 SE2d 232) (1996) (noting that the American Bar Association's standards are instructive in these types of cases). In mitigation, Morgan offers that he has no prior disciplinary record; that with the loss of his wife, he experienced personal and emotional problems during the time of his misconduct; that before the hearing, he made a good faith effort to make restitution by providing the probate court a full repayment of the estate funds; that he was cooperative with the disciplinary process by providing a complete accounting of the estate checking account to the State Bar; and that he has expressed remorse. See ABA Standards 9.32 (b), (c), (d), (e), and (l); In the Matter of Rowe, 287 Ga. 822, 823 (700 SE2d 538) (2010) (mitigating factor included that respondent suffered from personal and emotional problems during the relevant time period); In the Matter of Champion, 275 Ga. 140, 141 (562 SE2d 179) (2002) (mitigation factors included that respondent had shown remorse and repaid funds to her client).

Morgan requests that this Court impose a two-year suspension that includes the following reinstatement conditions: complete a psychological evaluation and follow all recommendations; continue attending weekly Alcoholics Anonymous meetings; attend the State Bar's Law Practice
Management courses; and submit a petition for reinstatement to the Review Panel showing compliance with these conditions for reinstatement. See In the Matter of Reddick-Hood, 296 Ga. 95, 98 (764 SE2d 416) (2014) (respondent seeking reinstatement at the conclusion of a suspension must submit a petition for reinstatement to the Review Panel, who will review it and any objections filed by the State Bar's Office of General Counsel and then make a recommendation to this Court).

The State Bar does not dispute the facts as stated in Morgan's petition and agrees with the aggravating and mitigating factors. The State Bar asserts that the interests of the public and the State Bar would be best served if the Court were to accept Morgan's petition for voluntary discipline and suspend his law license for two years conditioned upon full compliance with the conditions set out in his petition.

Having considered the petition for voluntary discipline and the State Bar's response, we agree that a two-year suspension with conditions on reinstatement is the appropriate sanction in this case for Morgan's admitted violations of Rules 1.15 (I) (b) (1) and (2) (ii), 1.15 (II) (b), and 8.4 (a) (4). See In the Matter of Ballard, 279 Ga. 663 (619 SE2d 625) (2005); In the Matter of Shelfer, 278 Ga. 55 (597 SE2d 365) (2004). Accordingly, David E. Morgan, III is hereby suspended from the practice of law in the State of Georgia for two years. At the conclusion of the two-year suspension, Morgan may seek reinstatement provided that he obtains a certificate from a board-certified and licensed mental health professional that he is fit to return to the practice of law and provides evidence that he has been attending weekly Alcoholics Anonymous meetings
and that he has successfully participated in the State Bar's Law Practice Management Program. When Morgan believes that the conditions for his reinstatement have been met, he shall demonstrate compliance in a petition for reinstatement submitted to the Review Panel, which will then issue a report and recommendation to this Court. Morgan shall not undertake the practice of law until this Court issues an opinion granting or denying his petition for
reinstatement. See In the Matter of Fair, 292 Ga. 308 (736 SE2d 430) (2013). Morgan is reminded of his duties under State Bar Rule 4–219 (c).

Two-year suspension with conditions. All the Justices concur.