If an attorney commingles and converts client property for the attorney's own use, the attorney violates the rule. Disciplinary Action Against Anderson, 491 N.W.2d 703, 703 (N.D. 1992). [ΒΆ 10] Here, clear and convincing evidence shows Robb violated N.D.R. Prof. Conduct 1.15(a) by failing to hold a portion of Leno's settlement proceeds separate from his own property.
Furthermore, we have disbarred attorneys before when we found the conversion of clients' funds coupled with other aggravating factors. See In re Disciplinary Action against Anderson, 491 N.W.2d 703 (N.D. 1992). Thus, under these facts, we conclude that Lashkowitz's conduct requires disbarment.