Deprivation of licenses due to misconduct incompatible with the lawyer's title
Updated on 07/02/2024
Nota Bene
The article provides information about some of the lawyers who are subjected to pressure and repression, namely those prosecuted in criminal cases.
The main article with all types of persecution and a complete list of lawyers subjected to repression can be found here
The main article with all types of persecution and a complete list of lawyers subjected to repression can be found here
Information on other groups of barristers who have been disqualified from the profession can be found at the following addresses:
- Lawyers subjected to criminal prosecution
- Lawyers deprived of the right to a profession based on the results of attestation / re-attestation by the qualification commission
- Lawyers expelled from the Bar by decision of the Disciplinary Commission of the Territorial Bar Association (Council of the Territorial Bar Association)
The material is regularly updated, the date is indicated above. If we missed someone, then please write to us - defendersbelarus@protonmail.com
- Lawyers subjected to criminal prosecution
- Lawyers deprived of the right to a profession based on the results of attestation / re-attestation by the qualification commission
- Lawyers expelled from the Bar by decision of the Disciplinary Commission of the Territorial Bar Association (Council of the Territorial Bar Association)
The material is regularly updated, the date is indicated above. If we missed someone, then please write to us - defendersbelarus@protonmail.com
Who is included in the list
Lawyers deprived of their status by the decision of the Ministry of Justice are those lawyers whose license was terminated directly by the Ministry as a licensing body, who, according to the conclusion of the Qualification Commission under the Ministry of Justice, committed a "misconduct incompatible with the title of lawyer".
The Ministry of Justice itself acts as an actor and initiator in this procedure. The reason is the reports of any other body or the independent discovery of something by the Ministry of Justice, which may serve as a basis for deprivation. The Qualification Commission under the Ministry of Justice issues a conclusion on the need to revoke a license.
This procedure has been used less frequently by the Ministry of Justice recently, presumably due to the submission in July 2021 by the UN Human Rights Committee of considerations on the appeal of lawyer Oleg Ageev, who was deprived of his license in 2011.
This procedure is unlawful because it is incompatible with the principles of the independence of lawyers and the legal profession, according to which the state cannot assess a lawyer's compliance with ethical standards and his qualifications. For this reason, the deprivation of the status of a lawyer as a result of this procedure is unlawful, regardless of other circumstances.
The Ministry of Justice itself acts as an actor and initiator in this procedure. The reason is the reports of any other body or the independent discovery of something by the Ministry of Justice, which may serve as a basis for deprivation. The Qualification Commission under the Ministry of Justice issues a conclusion on the need to revoke a license.
This procedure has been used less frequently by the Ministry of Justice recently, presumably due to the submission in July 2021 by the UN Human Rights Committee of considerations on the appeal of lawyer Oleg Ageev, who was deprived of his license in 2011.
This procedure is unlawful because it is incompatible with the principles of the independence of lawyers and the legal profession, according to which the state cannot assess a lawyer's compliance with ethical standards and his qualifications. For this reason, the deprivation of the status of a lawyer as a result of this procedure is unlawful, regardless of other circumstances.
See the detailed chronicle of the revocation of Alexander Pylchenko's license here.
Pylchenko was an attorney for Viktor Babariko, the 2020 presidential elections ex-candidate, as well as for Babariko's staff coordinator, Maria Kolesnikova, who is also a member of the Presidium of the Coordination Council.
On 15 October 2020, the Qualification Commission on Advocacy of the Ministry of Justice recommended revoking a lawyer's license. By a decision of the collegium of the Ministry of Justice of October 16, the validity of Alexander's lawyer license was suspended.
The essence of the claims against the attorney is connected with the content of his interview with the T*T.BY news portal. In the August 14th, 2020 publication, Alexander Pylchenko expressed his views on the actions to be taken by the Prosecutor General and other officials as to the evidence published in the media about the use of torture against detainees from 9 to 12 August in the police departments and detention facilities, as well as information about election fraud. The lawyer recommended Prosecutor General of Belarus to initiate criminal proceedings into beatings of protesters, torture, cruel and inhuman treatment of detainees. The lawyer also noted that the Prosecutor General's Office should have removed the Minister of Internal Affairs, his deputies, and the head of the detention facilities from office until the inspection of their involvement or non-involvement in the abovementioned incidents had been completed.
According to the Ministry of Justice, Alexander Pylchenko "had made incompetent remarks in the media and actually called for illegal actions, including the "blocking and disarming of military units".
International professional organizations of lawyers have repeatedly sent letters to the Belarusian authorities supporting Aliaksandr Pylchenko and demanding an end to the politically motivated persecution.
Pylchenko was an attorney for Viktor Babariko, the 2020 presidential elections ex-candidate, as well as for Babariko's staff coordinator, Maria Kolesnikova, who is also a member of the Presidium of the Coordination Council.
On 15 October 2020, the Qualification Commission on Advocacy of the Ministry of Justice recommended revoking a lawyer's license. By a decision of the collegium of the Ministry of Justice of October 16, the validity of Alexander's lawyer license was suspended.
The essence of the claims against the attorney is connected with the content of his interview with the T*T.BY news portal. In the August 14th, 2020 publication, Alexander Pylchenko expressed his views on the actions to be taken by the Prosecutor General and other officials as to the evidence published in the media about the use of torture against detainees from 9 to 12 August in the police departments and detention facilities, as well as information about election fraud. The lawyer recommended Prosecutor General of Belarus to initiate criminal proceedings into beatings of protesters, torture, cruel and inhuman treatment of detainees. The lawyer also noted that the Prosecutor General's Office should have removed the Minister of Internal Affairs, his deputies, and the head of the detention facilities from office until the inspection of their involvement or non-involvement in the abovementioned incidents had been completed.
According to the Ministry of Justice, Alexander Pylchenko "had made incompetent remarks in the media and actually called for illegal actions, including the "blocking and disarming of military units".
International professional organizations of lawyers have repeatedly sent letters to the Belarusian authorities supporting Aliaksandr Pylchenko and demanding an end to the politically motivated persecution.
See the detailed chronicle of Liudmila's persecution here.
Liudmila has defended Maria Kolesnikova. On September 24, 2020, she was abducted by unknown individuals in Minsk, and taken to the Central police department of the city. There the individuals seized the documents and items covered by the attorney-client privilege. A protocol indicating a commission of the administrative offense was filed against Liudmila under Art. 23.4 of the Administrative Code (disobedience to a lawful order of the authorities' representatives). Prior to the trial, she was kept at the Okrestina Preliminary Detention Center, despite having three children. She was deprived of access to her lawyers for 20 hours after the arrest. The court imposed on her 30 basic units fine under Art. 23.4 of the Administrative Code. Human rights defenders consider the persecution to be politically motivated, directed against the professional duties of an attorney to protect political opponents of the current government.
On February 19, 2021, the Qualification Commission on Advocacy of the Ministry of Justice decided to deprive Liudmila of the lawyer's license. The license's expiration date has not been determined yet. According to the Ministry of Justice press release, this decision was made based on the fact of committing an administrative offense under Art. 23.4 of the Administrative Code.
The Council of Bars and Law Societies of Europe President communicated to the Belarusian authorities a letter in support of Liudmila and stressed the inadmissibility of obstructing the activities of lawyers.
155 lawyers signed a petition to the Ministry of Justice about the unjustified deprivation of Liudmila's and other lawyers' licenses.
Liudmila has defended Maria Kolesnikova. On September 24, 2020, she was abducted by unknown individuals in Minsk, and taken to the Central police department of the city. There the individuals seized the documents and items covered by the attorney-client privilege. A protocol indicating a commission of the administrative offense was filed against Liudmila under Art. 23.4 of the Administrative Code (disobedience to a lawful order of the authorities' representatives). Prior to the trial, she was kept at the Okrestina Preliminary Detention Center, despite having three children. She was deprived of access to her lawyers for 20 hours after the arrest. The court imposed on her 30 basic units fine under Art. 23.4 of the Administrative Code. Human rights defenders consider the persecution to be politically motivated, directed against the professional duties of an attorney to protect political opponents of the current government.
On February 19, 2021, the Qualification Commission on Advocacy of the Ministry of Justice decided to deprive Liudmila of the lawyer's license. The license's expiration date has not been determined yet. According to the Ministry of Justice press release, this decision was made based on the fact of committing an administrative offense under Art. 23.4 of the Administrative Code.
The Council of Bars and Law Societies of Europe President communicated to the Belarusian authorities a letter in support of Liudmila and stressed the inadmissibility of obstructing the activities of lawyers.
155 lawyers signed a petition to the Ministry of Justice about the unjustified deprivation of Liudmila's and other lawyers' licenses.
Konstantin Mikhel
Konstantin Mikhel is a lawyer and the managing partner at the Vlasova, Mikhel & Partners law firm. He is also a member of the Minsk Regional Bar. He has been practicing law since 1995. He is one of the most prominent business lawyers in Belarus. He is a member of a number of advisory councils on business development at various governmental agencies. In 2009 he received commendations from the Belarusian Minister of Justice for his active work to protect the rights and legal interests of citizens and organizations. He was awarded the Belarusian Republican Lawyer's Union's Highest Legal Award in the Law and Economics category in 2010.
In the autumn of 2020, he was subjected to administrative liability for violating the procedure of organizing mass events (Art. 23.34, para. 1 of the Administrative Code). According to unofficial information, he was detained together with his son at his house.
On February 19, 2021, the Ministry of Justice Qualification Commission on Advocacy decided to deprive Konstantin of a lawyer's license. The license's expiration date has not yet been determined. The Ministry of Justice press release states the following grounds for such a decision: "Attorneys Konstantin Mikhel and Maxim Konon participated in mass events held without the appropriate permission of the local executive committee, thereby committing an administrative offense under Art. 23.34, para. 1 of the Administrative Code." According to the Ministry of Justice, "the above-mentioned actions of the lawyers discredit the title of a lawyer and the Bar, which is a misdemeanor incompatible with the title of a lawyer, entailing the termination of the lawyer's license".
In the autumn of 2020, he was subjected to administrative liability for violating the procedure of organizing mass events (Art. 23.34, para. 1 of the Administrative Code). According to unofficial information, he was detained together with his son at his house.
On February 19, 2021, the Ministry of Justice Qualification Commission on Advocacy decided to deprive Konstantin of a lawyer's license. The license's expiration date has not yet been determined. The Ministry of Justice press release states the following grounds for such a decision: "Attorneys Konstantin Mikhel and Maxim Konon participated in mass events held without the appropriate permission of the local executive committee, thereby committing an administrative offense under Art. 23.34, para. 1 of the Administrative Code." According to the Ministry of Justice, "the above-mentioned actions of the lawyers discredit the title of a lawyer and the Bar, which is a misdemeanor incompatible with the title of a lawyer, entailing the termination of the lawyer's license".
Maxim Konon
In October 2020, the court of the Oktyabrsky district of Minsk found the lawyer guilty of committing an administrative offense under Art. 23.34, para.1 of the Code of Administrative Offenses (violation of the procedure of organizing mass events) and sentenced him to 12 days of arrest for allegedly participating in an unsanctioned protest action near the urban beach in Braslav.
In November 2020, the lawyer was detained by police officers at the entrance to the KGB office, where he had arrived to intervene in the criminal proceedings as a defender of journalist Katsiaryna Barysevich. He was sent to the pre-trial detention center in Baranovichi to serve an administrative arrest.
On February 19, 2021, the Qualification Commission for Advocacy of the Ministry of Justice decided to deprive Maksim Konon of his lawyer's license. As indicated in the Commission's conclusion, having committed an administrative offense, Maxim Konon violated Art. 18, para. 1 of the Law "On Advocacy and Advocate Activity in the Republic of Belarus", paras 3, 7, 8, 9 of the Rules of Professional Activities, thereby discrediting the title of a lawyer and the Bar, which, under para. 73 of the Rules for the Professional Ethics for Attorneys, is a misdemeanor incompatible with the title of a lawyer.
Maxim Konon
In October 2020, the court of the Oktyabrsky district of Minsk found the lawyer guilty of committing an administrative offense under Art. 23.34, para.1 of the Code of Administrative Offenses (violation of the procedure of organizing mass events) and sentenced him to 12 days of arrest for allegedly participating in an unsanctioned protest action near the urban beach in Braslav.
In November 2020, the lawyer was detained by police officers at the entrance to the KGB office, where he had arrived to intervene in the criminal proceedings as a defender of journalist Katsiaryna Barysevich. He was sent to the pre-trial detention center in Baranovichi to serve an administrative arrest.
On February 19, 2021, the Qualification Commission for Advocacy of the Ministry of Justice decided to deprive Maksim Konon of his lawyer's license. As indicated in the Commission's conclusion, having committed an administrative offense, Maxim Konon violated Art. 18, para. 1 of the Law "On Advocacy and Advocate Activity in the Republic of Belarus", paras 3, 7, 8, 9 of the Rules of Professional Activities, thereby discrediting the title of a lawyer and the Bar, which, under para. 73 of the Rules for the Professional Ethics for Attorneys, is a misdemeanor incompatible with the title of a lawyer.
In November 2020, the lawyer was detained by police officers at the entrance to the KGB office, where he had arrived to intervene in the criminal proceedings as a defender of journalist Katsiaryna Barysevich. He was sent to the pre-trial detention center in Baranovichi to serve an administrative arrest.
On February 19, 2021, the Qualification Commission for Advocacy of the Ministry of Justice decided to deprive Maksim Konon of his lawyer's license. As indicated in the Commission's conclusion, having committed an administrative offense, Maxim Konon violated Art. 18, para. 1 of the Law "On Advocacy and Advocate Activity in the Republic of Belarus", paras 3, 7, 8, 9 of the Rules of Professional Activities, thereby discrediting the title of a lawyer and the Bar, which, under para. 73 of the Rules for the Professional Ethics for Attorneys, is a misdemeanor incompatible with the title of a lawyer.
Maxim Konon
In October 2020, the court of the Oktyabrsky district of Minsk found the lawyer guilty of committing an administrative offense under Art. 23.34, para.1 of the Code of Administrative Offenses (violation of the procedure of organizing mass events) and sentenced him to 12 days of arrest for allegedly participating in an unsanctioned protest action near the urban beach in Braslav.
In November 2020, the lawyer was detained by police officers at the entrance to the KGB office, where he had arrived to intervene in the criminal proceedings as a defender of journalist Katsiaryna Barysevich. He was sent to the pre-trial detention center in Baranovichi to serve an administrative arrest.
On February 19, 2021, the Qualification Commission for Advocacy of the Ministry of Justice decided to deprive Maksim Konon of his lawyer's license. As indicated in the Commission's conclusion, having committed an administrative offense, Maxim Konon violated Art. 18, para. 1 of the Law "On Advocacy and Advocate Activity in the Republic of Belarus", paras 3, 7, 8, 9 of the Rules of Professional Activities, thereby discrediting the title of a lawyer and the Bar, which, under para. 73 of the Rules for the Professional Ethics for Attorneys, is a misdemeanor incompatible with the title of a lawyer.
Mikhail Kirilyuk
MRBA lawyer. Member of the expanded board of the Coordination Council. Mikhail is responsible for issues of justice in the National Anti-Crisis Management.
He posted on his Facebook page about the country's topical events (in particular, this post dated September 1, 2020, caught the authorities' attention), and also spoke about the situation in an interview (similarly, this material dated September 6, 2020, has also attracted the attention of the state agencies).
For these statements, the MRBA disciplinary commission reprimanded the lawyer.
On February 8, 2021, the Ministry of Justice sent Mikhail a notice of consideration of the issue of revoking his license in connection with the abovementioned statements (1, 2) signed by the Head of the Advocacy and Licensing Department D. Podlesskaya.
On February 12, 2021, Mikhail sent a request for clarification of the statements that served as the basis for revoking the license, to which no response was received.
On February 19, 2021, the Qualification Commission for Advocacy of the Ministry of Justice decided to deprive Mikhail Kirilyuk of his lawyer's license. The press service of the Ministry of Justice indicated the following rationale for the decision: "Attorney Maxim Kirilyuk has made public statements on the global computer network Internet, containing rude, tactless expressions in relation to representatives of state bodies, which is unacceptable."
He posted on his Facebook page about the country's topical events (in particular, this post dated September 1, 2020, caught the authorities' attention), and also spoke about the situation in an interview (similarly, this material dated September 6, 2020, has also attracted the attention of the state agencies).
For these statements, the MRBA disciplinary commission reprimanded the lawyer.
On February 8, 2021, the Ministry of Justice sent Mikhail a notice of consideration of the issue of revoking his license in connection with the abovementioned statements (1, 2) signed by the Head of the Advocacy and Licensing Department D. Podlesskaya.
On February 12, 2021, Mikhail sent a request for clarification of the statements that served as the basis for revoking the license, to which no response was received.
On February 19, 2021, the Qualification Commission for Advocacy of the Ministry of Justice decided to deprive Mikhail Kirilyuk of his lawyer's license. The press service of the Ministry of Justice indicated the following rationale for the decision: "Attorney Maxim Kirilyuk has made public statements on the global computer network Internet, containing rude, tactless expressions in relation to representatives of state bodies, which is unacceptable."
Yulia Levanchuk
Lawyer of the Brest Regional Bar Association.
On October 15, 2020, the Qualification Commission for Advocacy of the Ministry of Justice decided to deprive Yulia of her lawyer's license. The press service of the Ministry of Justice indicated the following rationale for the decision: "Brest Regional Bar attorney, Yulia Levanchuk, initiated correspondence with an investigator, in which she threatened him and his family members."
There is no further information available to the public.
On October 15, 2020, the Qualification Commission for Advocacy of the Ministry of Justice decided to deprive Yulia of her lawyer's license. The press service of the Ministry of Justice indicated the following rationale for the decision: "Brest Regional Bar attorney, Yulia Levanchuk, initiated correspondence with an investigator, in which she threatened him and his family members."
There is no further information available to the public.
Сергей Пичуха
On March 24, 2021, the Qualification Commission reviewed the materials concerning the case of Sergey Pichukha, MRBA attorney.
The case against the attorney was initiated "in connection with the revealed violation of the legislation on licensing, license requirements and conditions, consisting in an offense incompatible with the lawyer's title (committing actions that discredit the title of a lawyer and the Bar)".
Such actions, in the opinion of the Ministry of Justice, constitute "the fact that Sergey Pichukha committed an administrative offense, meaning the violation of the legal procedure for organizing a mass event". The decision on the administrative case dated December 16, 2020, entered into force on February 8, 2021, after the re-examination of the case by the Minsk Regional Court.
After considering the materials, the Qualification Commission concluded that the above-mentioned actions discredit the title of a lawyer and the Bar, which composes a misdemeanor incompatible with the title of a lawyer, and entails the termination of the license. On March 30, 2021, the Ministry of Justice terminated the license of the attorney.
The case against the attorney was initiated "in connection with the revealed violation of the legislation on licensing, license requirements and conditions, consisting in an offense incompatible with the lawyer's title (committing actions that discredit the title of a lawyer and the Bar)".
Such actions, in the opinion of the Ministry of Justice, constitute "the fact that Sergey Pichukha committed an administrative offense, meaning the violation of the legal procedure for organizing a mass event". The decision on the administrative case dated December 16, 2020, entered into force on February 8, 2021, after the re-examination of the case by the Minsk Regional Court.
After considering the materials, the Qualification Commission concluded that the above-mentioned actions discredit the title of a lawyer and the Bar, which composes a misdemeanor incompatible with the title of a lawyer, and entails the termination of the license. On March 30, 2021, the Ministry of Justice terminated the license of the attorney.
Sergey Ivanov
On November 25, 2021, the Qualification Commission on Advocacy conducted the certification of attorneys of the territorial Bar associations and considered the termination of licenses.
Based on the certification results, the Qualification Commission decided on the termination of Sergey's license for "committing offenses incompatible with the title of lawyer."
The lawyer previously actively posted in his Facebook feed. The "offense" consists in posting statements containing information that undermines public confidence in public authorities, in the activities of judges, and in law enforcement agencies.
Based on the certification results, the Qualification Commission decided on the termination of Sergey's license for "committing offenses incompatible with the title of lawyer."
The lawyer previously actively posted in his Facebook feed. The "offense" consists in posting statements containing information that undermines public confidence in public authorities, in the activities of judges, and in law enforcement agencies.
Fedorovich I.A.
On June 16, 2023, the Qualification Commission for Advocacy in the Republic of Belarus made a decision on the possibility of terminating licenses for advocacy in respect of Fedorovich I.A. – in connection with "committing a misdemeanor incompatible with the title of a lawyer, the list of which is established by the Rules of the professional ethics of a lawyer, approved by the Ministry of Justice (committing actions that discredit the title of a lawyer and the bar)".
Alexander Ulasevich
On May 29, 2023, the Qualification Commission conducted an extraordinary attestation of lawyers, and considered the issues of termination of licenses for advocacy.
Based on the results of the extraordinary attestation, the qualification commission made decisions on the possibility of terminating licenses for advocacy in relation to the lawyer of the Vitebsk Regional Bar Association Ulasevich A.V. in connection with the commission of "misconduct incompatible with the title of a lawyer (commission of actions that discredit the title of a lawyer and the bar)". According to unconfirmed information, the Qualification Commission considered charitable donations to solidarity funds to be an offense.
Based on the results of the extraordinary attestation, the qualification commission made decisions on the possibility of terminating licenses for advocacy in relation to the lawyer of the Vitebsk Regional Bar Association Ulasevich A.V. in connection with the commission of "misconduct incompatible with the title of a lawyer (commission of actions that discredit the title of a lawyer and the bar)". According to unconfirmed information, the Qualification Commission considered charitable donations to solidarity funds to be an offense.
Svetlana Yakusheva
On May 29, 2023, the Qualification Commission conducted an extraordinary attestation of lawyers, and considered the issues of termination of licenses for advocacy.
Based on the results of the extraordinary attestation, the qualification commission made decisions on the possibility of terminating licenses for advocacy in relation to the lawyer of the Vitebsk Regional Bar Association Yakusheva S.O. in connection with the commission of "misconduct incompatible with the title of a lawyer (commission of actions that discredit the title of a lawyer and the bar)". According to unconfirmed information, the Qualification Commission considered charitable donations to solidarity funds to be an offense.
Based on the results of the extraordinary attestation, the qualification commission made decisions on the possibility of terminating licenses for advocacy in relation to the lawyer of the Vitebsk Regional Bar Association Yakusheva S.O. in connection with the commission of "misconduct incompatible with the title of a lawyer (commission of actions that discredit the title of a lawyer and the bar)". According to unconfirmed information, the Qualification Commission considered charitable donations to solidarity funds to be an offense.
Lyudmila Palochkina
In late September 2023, the Qualification Commission for Advocacy in the Republic of Belarus, based on the results of the next certification, made decisions on the possibility of terminating license to practice law in relation to L.I. Palochkina for "committing actions that discredit the title of lawyer and the legal profession."
Yulia Karachun
On November 22, 2023, the Qualification Commission on Advocacy conducted certification of lawyers of territorial bar associations, as a result of which the Qualification Commission decided on the possibility of terminating license in connection with the commission of offenses incompatible with the title of lawyer (committing actions that discredit the title of lawyer and the legal profession) , in relation to the lawyer of the Minsk Regional Bar Association Karachun Y.N.
We draw the attention of readers that after 2021, this particular revocation mechanism was used only once, in 2023, when the Qualification Commission decided to revoke the licenses of several lawyers from Vitebsk. According to unconfirmed information, the lawyers' offense then consisted of making charitable donations to solidarity funds.
We draw the attention of readers that after 2021, this particular revocation mechanism was used only once, in 2023, when the Qualification Commission decided to revoke the licenses of several lawyers from Vitebsk. According to unconfirmed information, the lawyers' offense then consisted of making charitable donations to solidarity funds.
Oksana Puchkovskaya
On November 22, 2023, the Qualification Commission on Advocacy conducted certification of lawyers of territorial bar associations, as a result of which the Qualification Commission decided on the possibility of terminating license in connection with the commission of offenses incompatible with the title of lawyer (committing actions that discredit the title of lawyer and the legal profession) , in relation to the lawyer of the Minsk Regional Bar Association O.Puchkovskaya.
We draw the attention of readers that after 2021, this particular revocation mechanism was used only once, in 2023, when the Qualification Commission decided to revoke the licenses of several lawyers from Vitebsk. According to unconfirmed information, the lawyers' offense then consisted of making charitable donations to solidarity funds.
We draw the attention of readers that after 2021, this particular revocation mechanism was used only once, in 2023, when the Qualification Commission decided to revoke the licenses of several lawyers from Vitebsk. According to unconfirmed information, the lawyers' offense then consisted of making charitable donations to solidarity funds.
Alexey Sokolov
On January 18, 2024, the Ministry of Justice of Belarus held a regular meeting of the Qualification Commission on issues of Advocacy. The Qualification Commission decided on the possibility of terminating the licenses of Alexey Sokolov "in connection with the commission of an offense incompatible with the title of lawyer (committing actions that discredit the title of lawyer and the legal profession)."
