Id. at 408 n. 6. Thus, specified demands accompanied the threat in that case. See also In re Mekler, 406 A.2d 20, 22-23 (Del. 1979) (per curiam) (Court publicly censured attorney who threatened a piano company with criminal action if it did not return down payment on repossessed piano and thereafter drafted the specifications included in the criminal complaint; after the arrest, the respondent suggested the charge would be dismissed if the threatened party returned the $1,600); People ex rel. Gallagher v. Hertz, 198 Colo. 522, 608 P.2d 335 (1979) (attorney acting as receiver for partnership threatened criminal prosecution unless party repaid $4,200 attorney claimed was due to the partnership and then followed through on threat, his sole motive being promotion of his interest in the civil matter); Libarian v. State Bar, 38 Cal.2d 328, 239 P.2d 865 (1952). The direct, unequivocal "requests for action" in these cases contrast markedly with the majority's observation that it "can perceive of no purpose for the letter other than to influence the B.L.M.'s handling of a non-Native application . . . the rejection of which