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When misappropriation involves “other ethical violations in addition to the misappropriation, particularly misrepresentations to conceal the misappropriation, mitigating factors usually will not militate against disbarment.” d 263, 272 (Minn. 2006); (stating that an attorney’s “dishonesty after his misappropriation of funds further support[ed] 13 disbarment” where the attorney “made misrepresentations and gave false documents to clients to conceal the misappropriation”).

“[W]e have repeatedly stated that an attorney may be disciplined for acts which are criminal but do not result in a criminal conviction.” (citation omitted) (internal 9 quotation marks omitted); see also In re Samborski , (“We need not await a conviction to disc ipline an attorney fo r criminal acts.”); –46 (Minn. 1991) (discussing the relationship between criminal and professional sanctions); –76 (Minn. 1979) (collecting cases).

In re Samborski , , 408 (Minn. 2002).

(concluding that making false statements to the Director during the course of a disciplinary investigation undermines the public’s trust in the legal profession); (“The maintenance of proper trust account records is vital to the practice of the legal profe

Noneooperation, by itself, supports a sanction of indefinite suspension, and we typically “increasé[ ] the severity of the disciplinary sanction” where noncooperation exists.

See, d at 408-09 (stating attorney’s numerous violations “warrant[ ] severe discipline”); d at 464 (stating that noncooperation with the disciplinary process increases the severity of the disciplinary sanction); (noting that noncooperation with discipline process may warrant indefinite suspension).

See, (disbarring attorney where “[i]n addition to misappropriating client funds, [the attorney] made misrepresentations and gave false documents to clients to conceal the misappropriation”).

See, (stating that by itself, noncooperation with the disciplinary process may warrant indefinite suspension and in connection with other misconduct, noncooperation increases the severity of the disciplinary sanction); (noting that failing to keep proper trust

“In connection with other misconduct, noncooperation increases the severity of the disciplinary sanction.”