Matter of Chilliest — Four-Year Suspension for Estate Fund Misappropriation; Rule 8.4(h) Applies Alongside Rule 1.15 Violations
The First Department imposed a four-year suspension on an attorney who misappropriated estate sale proceeds, commingled client funds, and failed to maintain required bookkeeping records, and clarified that RPC Rule 8.4(h) applies cumulatively alongside Rule 1.15 violations — not merely as a catch-all for conduct not otherwise covered.