On June 22, 2021 the Appellate Division, First Department suspended an attorney (on an interim basis) for failing to obey their Order which directed her to submit to psychiatric and medical  examinations  to determine her fitness to continue practicing law. The attorney's mental fitness was in question based on her "irrational conduct during and after a medical malpractice trial in which she represented herself as well as her conduct before the Attorney Grievance Committee." Of note were the attorney's attempts to relitigate issues previously resolved, "harassing and profane telephone calls and voice messages to the defendant doctors and their counsel."

The Court emphasized that the suspension was premised on the attorney's failure to cooperate in the investigation by refusing to appear for mental and physical evaluation as ordered and that "if and when respondent does cooperate, she may then seek to vacate the interim suspension. Attorney Grievance Committee v. Patricia M. DeGrace D'Aliasi, 2021 WL 2545674