In Law Society of Upper Canada v. Mikitchook, [1998] L.S.D.D. No. 29, October 3, 1997, the discipline committee relied on a definition of misappropriation that says: Misappropriation is ‘any unauthorized use…of clients’ funds entrusted to [a lawyer], including not only stealing, but also unauthorized temporary use for the lawyer’s own purpose, whether or not he derives any personal gain or benefit therefrom…
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