California, United States of America
The following excerpt is from Doyle v. State Bar, 126 Cal.Rptr. 801, 15 Cal.3d 973, 544 P.2d 937 (Cal. 1976):
When an attorney's disregard of his clients' interest is 'habitual' (Ridley v. State Bar (1972) 6 Cal.3d 551, 560--561, 99 Cal.Rptr. 873, 493 P.2d 105; Grove v. State Bar (1967) supra, 66 Cal.2d 680, 683--684, 58 Cal.Rptr. 564, 427 P.2d 164), or when failure to render services is combined with failure to communicate with the client and with misrepresentation, severe discipline has been imposed. (Alkow v. State Bar (1971) 3 Cal.3d 924, 936, 92 Cal.Rptr. 278, 479 P.2d 638; Rock v. State Bar (1962) 57 Cal.2d 639, 643--644, 21 Cal.Rptr. 572, 371, P.2d 308.)
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