Matter of Zankowski

Summary

The Appellate Division, Third Department imposed reciprocal discipline on Doreen Marie Zankowski after Massachusetts suspended her from practicing law for two years for misconduct including intentionally billing clients for services not rendered. The court granted the Attorney Grievance Committee’s motion and suspended respondent from practicing law in New York for two years, effective immediately, rejecting her request for retroactive application.

Holdings

1. Reciprocal discipline should be imposed because respondent raised no substantive defense to the Attorney Grievance Committee's motion under 22 NYCRR 1240.13(b).
2. A two-year suspension from the practice of law in New York, effective immediately and continuing until further order of the court, is an appropriate sanction.
3. The suspension should not be imposed retroactively; it is effective immediately.

Questions Presented

1. Whether reciprocal discipline should be imposed in New York based on respondent's Massachusetts suspension when respondent raised no substantive defense under 22 NYCRR 1240.13(b).
2. What sanction should be imposed in New York for respondent's misconduct and Massachusetts discipline.
3. Whether the New York suspension should be imposed retroactively, nunc pro tunc, to coincide with the expiration of respondent's Massachusetts suspension.

Disposition

other