The Respondent is the subject of an amended citation alleging four incidents of professional misconduct, all in relation to the same litigation matter. First, failing to deposit settlement funds received in trust on behalf of his client into a pooled trust account. Second, failing to honour an implied undertaking not to release these funds to the client before providing an executed release to opposing counsel. Third, personally retaining fees to which his law firm was entitled. And fourth, failing to account to the client in writing for the application of fees and disbursements to the settlement funds.