Hoffman’s third discipline case involved repeated unauthorized practice of law (UPL) while suspended, including appearances and advocacy in arbitration matters. Despite civil statutes that sometimes permit non-lawyers to represent parties in arbitrations, the Review Department held that a suspended lawyer’s conduct remains the practice of law when it entails advising, advocating, and taking legal positions for a party. Hoffman had previously stipulated (in an earlier discipline) that it was unreasonable to believe he could represent parties in arbitration while suspended, yet he continued doing so—conduct the court deemed intentional acts of moral turpitude. :contentReference[oaicite:8]{index=8}

Examples included emailed legal demands and argument to opposing counsel during the Paradise Film arbitration; post-arbitration filings and communications in a Comerica Bank dispute; and a pre-hearing memorandum and advocacy in the United Care Network arbitration. The court emphasized that prior stipulations and orders matter: Hoffman was on notice his belief was unreasonable, did not move to correct the stipulation, and then repeated the same conduct, evidencing a lack of insight and an unwillingness/inability to conform to professional norms. :contentReference[oaicite:9]{index=9}

Applying the Standards, the court found disbarment warranted: UPL while on disciplinary suspension supports severe discipline; moral turpitude was present; and Hoffman had two prior records of discipline including actual suspension. Deviation from the Standards was not justified given the pattern and aggravation. The decision also clarifies that even where non-lawyers may appear in arbitration, a suspended attorney cannot do so without violating sections 6125/6126 and professional obligations. :contentReference[oaicite:10]{index=10}