In 1988, Pan American Flight 103 was subject to an onboard bomb and crashed killing everyone. D was a legal adviser in the State Department. D took part in the investigation of the bombing. As part of his work D was involved with the response to Pan Am’s subpoena claiming that the government had advance warning and did nothing to stop it. D was involved in confidential briefings related to the criminal investigation. D left employment with the State Department and joined a private firm. The Libyan government hired the firm to represent it in connection with the criminal and civil litigation from the bombing. D's terms of agreement with Libya involved 'investigating the facts and legal proceedings, preparing legal analyses, providing legal advice and proposing legal steps to deal with' the 'ongoing civil and criminal disputes and litigation' stemming from the destruction of Pan Am 103. The District of Columbia Board of Professional Responsibility (P) investigated P for violation of PRC 1.11(a). P found D had violated the rule and recommended informal admonishment. D appealed.