ERICKSTAD, Chief Justice.
This is a disciplinary proceeding brought against Thomas M. Disselhorst, an attorney practicing law in Bismarck. Following formal proceedings, a hearing panel of the Disciplinary Board of the Supreme Court made findings and recommended that Disselhorst be publicly reprimanded for his conduct.
We review disciplinary proceedings against attorneys de novo on the record with the standard of proof being clear and convincing.
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