Ontario, Canada
The following excerpt is from Law Society of Upper Canada v. Ernest Guiste, 2011 ONLSHP 129 (CanLII):
In Law Society of Upper Canada v. Hollyoake, [1991] L.S.D.D No. 114, the lawyer was reprimanded for offensive correspondence that was inconsistent with the proper tone of professional communication. He also was found to have threatened criminal prosecution to secure civil advantage for his client and taping a conversation with a lawyer without her knowledge or consent. The lawyer had no previous discipline record.
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