I dissent. In my view, the record, despite its various shortcomings, amply supports the State Bar’s unanimous recommendation that petitioner be disbarred.
I reject the majority’s conclusion that, in the Spang matter, there is insufficient evidence to establish that petitioner exerted undue influence in the preparation of the two holographic wills and the joint tenancy deed. It is well settled that undue influence may be established by circumstantial evidence. (Estate of Jamison (1953) 41 Cal.2d. 1, 8 [256 P.2d 984].) Indeed, in cases such as this one involving a holographic and unwitnessed will, it is not surprising that there is no direct evidence of undue influence.
In the present case, several of decedent’s relatives testified as follows: decedent was a lonely and impressionable woman who had depended on them a great deal until, suddenly, she began to spurn their attentions, either by hanging up the telephone when they called or by refusing to allow them entry into her house. She expressed her fear of petitioner, and said she was reluctant to speak to her relatives because she was afraid petitioner would discover that they had communicated with each other. Moreover, she tearfully said that petitioner had “control” over her. When asked to explain the comment she replied that she had done “something terrible,” but refused to elaborate further. Moreover, she declined to leave her house because petitioner had refused to return her keys after she had given them to him so that he could feed her dogs while she was in the hospital, and she feared that he would lock her out.
*960Under these circumstances, I conclude the State Bar properly relied on the jury verdict in the civil matter. While we are not bound by findings in a civil action, “if the findings of the trial court and the findings of the [disciplinary] board are supported by substantial evidence they come to us with a strong presumption of validity. The burden is upon the one seeking review of the recommendation of the board to show that its findings are not supported by the evidence, or that its recommendation is erroneous or unlawful.” (In re Wright (1973) 10 Cal.3d 374, 377 [110 Cal.Rptr. 348, 515 P.2d 292], citing Lefner v. State Bar (1966) 64 Cal.2d 189, 192-193 [49 Cal.Rptr. 296, 410 P.2d 832].) Here, in addition to the testimony of decedent’s various relatives, the jury’s findings are consistent with the evidence that the previous, witnessed will had bequeathed Mrs. Spang’s property to her kin and that petitioner, who occupied a position of trust with regard to his client, was not the natural object of her bounty. In rejecting the civil findings, the majority places great reliance on the testimony of petitioner and on that of his boyhood friend, real estate broker Charles Vassallo. I, however, would not disturb the judgments of the civil jury and the hearing panel, which had the opportunity to assess the credibility of the witnesses as they testified. (See Baranowski v. State Bar (1979) 24 Cal.3d 153, 162 [154 Cal.Rptr. 752, 593 P.2d 613].)
In addition to the foregoing serious misconduct, as the majority notes, petitioner in bad faith failed to comply with various court orders related to the Spang action. Moreover, in the Dorham matter, he: (1) deceitfully misdirected a motion to the wrong court department; (2) deliberately presented the court with an inaccurate order; (3) made a sarcastic, and in my opinion a highly offensive, remark about Judge Kay; and (4) failed to pay $250 in sanctions imposed by the court. While individually these acts may merely warrant a period of suspension, I believe in concert they justify the sanction proposed by the State Bar.
The disbarment recommendation, moreover, is consistent with the State Bar’s discipline guidelines which took effect on January 1, 1986. As we recently noted in Greenbaum v. State Bar (1987) 43 Cal.3d 543, 550-551 [237 Cal.Rptr. 168, 736 P.2d 754], even if misconduct predates the guidelines, they nonetheless may properly be considered to determine appropriate discipline. Here, petitioner committed acts which the guidelines indicate shall result in either suspension or disbarment, depending on the gravity of the wrongdoing. (Standards for Atty. Sanctions for Prof. Misconduct, stds. 2.3 & 2.6.)
*961To determine the gravity of the offenses in this case we must look to the aggravating and mitigating circumstances. As the majority concedes, there are no mitigating factors. The list of aggravating circumstances, however, is lengthy. Indeed, five of the six aggravating factors enumerated in subdivision (b) of standard 1.2 are present. Petitioner’s misconduct involved “multiple acts of wrongdoing” (subd. (b)(ii)), as well as “bad faith” and “dishonesty” (subd. (b)(iii)). His undue influence in procuring the holographic wills and the joint tenancy deed “harmed significantly a client,” and the “administration of justice” was likewise harmed by his repeated bad faith disobedience of court orders. (Subd. (b)(iv).) Moreover, inasmuch as petitioner’s actions were either in bad faith or involved deliberate deception of judicial officers, his lack of remorse demonstrates “indifference toward . . . atonement for the consequences of his . . . misconduct.” (Subd. (b)(v).) Finally, he “displayed a lack of candor” during the State Bar proceedings. (Subd. (b)(vi).)
My colleagues, I believe, place undue reliance on the fact that petitioner has no prior record of discipline. Where, in a case such as this, the acts of wrongdoing are numerous and serious, disbarment is justified despite the lack of previous disciplinary proceedings. (See Bambic v. State Bar (1985) 40 Cal.3d 314, 324 [219 Cal.Rptr. 489, 707 P.2d 862].) Accordingly, I would adopt the State Bar’s recommendation that petitioner be disbarred.