Failing to hand over a client’s file after the representation ends is not the most serious of ethics infractions, but an Eatontown, N.J., solo’s history of such behavior may up the discipline in his case.

The New Jersey Disciplinary Review Board, in recommending a censure for Eugene LaVergne, said he apparently “has not learned from prior similar mistakes” and “still insists that he can hold client files hostage after the representation has concluded.”

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