See, e.g., In re Liu, 282 Fed.Appx. 7, 7-8 (2d Cir. 2008) (although conduct at issue "generally would warrant a significantly greater sanction," public censure was imposed instead, based on mitigating factors and imposition of other, onerous corrective measures); cf. In re Flannery, 186 F.3d 143, 146-49 (2d Cir. 1999) (imposing, on four attorneys, discipline ranging from monetary sanctions and public censure to two-year suspension for causing dismissal of clients' direct criminal appeals by failing to file briefs and ignoring subsequent orders to show cause why discipline should not be imposed).