In re Christopher D. Libertelli

Summary

The District of Columbia Court of Appeals adopted the Board on Professional Responsibility’s recommendation and disbarred Christopher D. Libertelli for flagrant dishonesty. The court concluded that Libertelli had not established the requirements for mitigation under In re Kersey and had filed no exceptions to the Board’s report.

Holdings

1. Disbarment is the appropriate sanction for an attorney's flagrant dishonesty.
2. Respondent was not entitled to a reduced sanction under the Kersey doctrine because he failed to establish two of the three required factors.
3. When no exceptions are filed to the Board's report and recommendation, the court will impose the recommended discipline after the time for filing exceptions expires, subject to the court's deferential review.

Questions Presented

1. Whether disbarment was the appropriate sanction for respondent's flagrant dishonesty.
2. Whether respondent established the requirements for mitigation under the Kersey doctrine.
3. Whether the court should accept the Board on Professional Responsibility's report and recommendation when respondent filed no exceptions.

Disposition

other