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Ludescher’s misconduct included making knowingly false statements, which we have stated “demonstrates a lack of honesty and integrity, and warrants severe discipline.” 608 (Minn. 2012) ( (Ulanowski I)).

And finally, we view “other disciplinary rule violations” more severely when paired 11 Our case law supports the referee’s determ ination that the failure to return unearned fees to the clients was misappropriation, see, e.g., In re Lundeen , —a determination that was not challenged here.

We have explained that “making mis representations demonstrates a lack of honesty and integrity, and warrants severe discipline.” see also Montez, d at 68 (finding that attorney’s dishonesty in making false statements to client and successor counsel, among others, was “serious misconduct”); In re Dedefo , (“We take dishonesty by lawyers seriously and have re peatedly held that a lac

the Director sought to suspend him “for conduct wh ich I am sure you will not be able to find a single instance of somebody who engaged in that conduct even provoking a disciplinary investigation.” Tigue does not appear to recognize the gravity of his misconduct—namely, misappropriation of client funds, which we have repeatedly stated is a “particularly serious violation.” In re Lundeen , (explaining that we “generally disbar attorneys who [intentionally] misappropriate client funds unless there

‘repeated failure to comply with court orders’ is itself a ground for disbarment.” (quoting Grzybek, d at 264–65).

Tayari-Garrett , d at 518 ; In re Lundeen , , 606-07 (Minn. 2012).

In re Lundeen , , 608 (Minn. 2012).

" In re Lundeen , , 608 (Minn. 2012) (quoting In re Westby , , 370 (Minn. 2002) ).

Misappropriation of client funds occurs when “‘funds belonging to a client are not deposited in a trust account and are used for any purpose other than that specified by the client.’ ” ().

Such conduct “ ‘demonstrates a lack of honesty and integrity, and warrants severe discipline.’ ” -15 (Minn. 2015) ().

(“[The lawyer] misappropriated funds belonging to [clients] by performing no work on their matters and never returning the funds to the clients.”).

We have held that “misappropriation of client funds [is] a particularly serious violation.” Misappropriation of client funds occurs when “ ‘funds belonging to a client are not deposited in a trust account and are used for any purpose other than that specified by the client.’ ” Id.

Matson’s misappropriation of C.B.’s $550 filing fee, by itself, is “ ‘particularly serious misconduct and usually warrants disbarment absent clear and convincing evidence of substantial mitigating factors.’ ” ( (internal quotation marks omitted); (disbarring an attorney who misappropriated client funds by performing no work on a matter and not returning unearned funds to the client, among other violations).

"The presumptive discipline for misappropriating client funds is disbarment unless there are 'substantial mitigating circumstances.'" -64 (Minn. 2015) ().

“Factors [that] we consider [when] determining the appropriate discipline include[:] the nature of the misconduct, the cumulative weight of the disciplinary violations, the harm to the public, and the harm to the legal profession.”

Four factors guide the imposition of discipline: “the nature of the misconduct, the cumulative weight of the violations, the harm to the public, and the harm to the legal profession.”

Moreover, “making misrepresentations demonstrates a lack of honesty and integrity, and warrants severe discipline.”

innesota Rules of Professional Conduct prohibits a lawyer from “commit[ing] a criminal act that reflects adversely on the lawyer’s honesty, trustworthiness, or fitness as a lawyer in other respects.” A criminal conviction for willfully disobeying a court mandate clearly has a direct relationship to, and “reflects adversely on,” Tayari-Garrett’s “fitness as a lawyer.” See