California, United States of America
The following excerpt is from Smith v. State Bar, 213 Cal.Rptr. 236, 38 Cal.3d 525, 698 P.2d 139 (Cal. 1985):
6 Compare Giddens v. State Bar, supra, 28 Cal.3d 730, 170 Cal.Rptr. 812, 621 P.2d 851, in which this court remanded the cause for a new disciplinary hearing. In that case, the recommended discipline was disbarment, the petitioner had been prevented from attending the hearing because of his incarceration in another state, and he was not represented by counsel.
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