Plaintiffs’ attorney was sanctioned by a Pennsylvania federal district court for unprofessional behavior and violation of her duty of candor to the court, and was ordered to complete five hours of ethics-based Continuing Legal Education. Order, Ely v. Cabot Oil & Gas Corp., No. 09-cv-02284 (M.D. Penn. July 21, 2014) (ECF No. 546). The sanctions were ordered because, according to the court, the attorney routinely abused and harassed opposing counsel with profanity and interfered with court-ordered site inspections of plaintiffs’ properties; she also failed to timely respond to discovery requests. Further, her admission to practice before the Middle District of Pennsylvania was revoked after it was learned that she was not a member of the Pennsylvania bar. Thereafter, the attorney ghost-wrote many of plaintiffs’ submissions while at the same time misled the court by stating that the plaintiffs were proceeding pro se. As the ethical rules on ghostwriting are currently evolving, the court was “loathe to hang an order of sanctions on the peg of ghostwritten submissions,” but nonetheless sanctioned the attorney for violating her duty of candor.