This court disbarred Mr. Hardy's trial and appellate counsel, Shola E. Ayeni, in 2003, based on ethical violations in three client matters. See In re Ayeni, 822 A.2d 420 (D.C. 2003).Hardy v. United States, No. 95-CF-266, 686 A.2d 1061 (D.C. 1996).

Rule 8.4(c) provides that "[i]t is professional misconduct for a lawyer to ... [e]ngage in conduct involving dishonesty, fraud, deceit, or misrepresentation." D.C. Rules of Prof'l Conduct R. 8.4(c) ; seeIn re Ayeni , 822 A.2d 420, 421 (D.C. 2003) (per curiam) (lawyer's plagiarized brief violated Rule 8.4(c) ). "[C]itation to authority is absolutely required when language is borrowed."

We note that other courts considering the issue have reached the same conclusion. See, e.g., In re Ayeni, 822 A.2d 420, 421 (D.C. 2003) (finding attorney committed an ethical violation by copying codefendant's brief); In re Zbiegien, 433 N.W.2d 871, 875 (Minn. 1988) (finding plagiarism in a seminar paper constituted misconduct); Columbus Bar Ass'n v. Farmer, 111 Ohio St.3d 137, 855 N.E.2d 462, 467-68 (2006) (finding ethical violation for copying prior attorney's brief).

See, e.g., In re Ayeni, 822 A.2d 420 (D.C. 2003) (Ayeni transferred client funds to his own account that he used for both personal and operating expenses and used one client's funds to cover a delinquency in another client fund; we disbarred him, agreeing that he had "failed to provide clear and convincing evidence that his impairment [alcoholism] substantially caused his misconduct and that he has been rehabilitated"); Marshall, 762 A.2d 530 (Marshall settled a client's case and then used the proceeds to purchase crack cocaine as well as to pay personal expenses, paying the client only after the client filed a complaint with Bar Counsel, lying to the client and to third-party health care providers about why they had not been paid, and fabricating checks purporting to show payments to third party medical providers; we reasoned that Marshall's addiction "stem[med] from his unlawful possession, use, and abuse of cocaine over a period of several years," id. at 537, and that "[t]o apply a mitigation principle previously used only in con

Furthermore, as a sanction for her misconduct related to Bar Counsel's investigation, the Board recommended a thirty-day suspension. "This court will accept the Board's findings as long as they are supported by substantial evidence in the record." In re Ayeni, 822 A.2d 420, 421 (D.C. 2003) (citing D.C. Bar R. XI, § 9(g)(1)). We accord the Board even more deference when, as here, no exceptions to the Board's recommendations are filed with this court.