PUBLIC RESPONSE / RIGHT OF REPLY – The Paris Bar’s account is not the whole story: my response, and the documentary record behind it

Annabelle Gauberti Paris Bar right of reply press release for Crefovi

After four disciplinary proceedings, repeated regulatory interventions and two provisional suspensions, I am publishing my side of the story — supported by my consolidated defence statement and a 226-annex evidential bundle.

Paris–London, 14 September 2026 — I am publishing this response because an institution should not be permitted to define a person’s professional history through its own accusations and decisions while the evidence explaining that person’s conduct remains unseen.

For several years, the ‟Ordre des avocats à la cour de Paris” — the Paris Bar, or “OACP” — has portrayed a series of disagreements, complaints, professional communications and procedural disputes as evidence of repeated professional misconduct on my part.

That is not my account of what happened.

Except where expressly attributed to a judgment, decision, authority or identified document, the characterisations, allegations and conclusions in this statement set out my account and analysis. They are not presented as findings already made by a court, regulator or other competent authority.

My account is supported by a detailed documentary record: correspondence, requests for guidance, formal complaints, regulatory exchanges, judicial decisions, medical and procedural evidence, appeals and contemporaneous records showing what I actually did, what I asked the Paris Bar to do, what answers I received and, in many instances, what answers I did not receive.

On 9 September 2026, I submitted a detailed defence statement in the fourth disciplinary proceeding brought against me. Following a full reconciliation of that statement against its underlying evidence, I have prepared a consolidated and corrected version dated 14 September 2026, supported by a master bundle preserving the original architecture of 226 annex entries.

A public, redacted edition of those documents is being made available alongside this statement.

This is my answer.


This was not a story of refusing rules

The central proposition advanced against me over the years has too often been that I was uncooperative, unwilling to comply with professional rules or resistant to regulation.

The documents show something materially different.

Again and again, I did what a regulated professional is supposed to do.

I asked the regulator for guidance.

I used procedures prescribed by the Paris Bar.

I asked for visas before making sensitive communications.

I sought to place disputed client monies into a protective escrow mechanism rather than appropriate them.

I used the fee-assessment procedure.

I requested access to my own personal data.

I complained internally when I believed the institution itself was acting improperly.

I asked its harassment and discrimination commission to intervene.

I appealed disciplinary decisions.

I escalated unresolved concerns to external authorities.

And when I believed that the cumulative exercise of regulatory and disciplinary powers had begun to interfere with competition and market access, I referred those concerns to the French Competition Authority and the European Commission.

My experience was that compliance did not produce regulatory certainty.

Instead, requests for guidance, challenges made through formal channels and attempts to use the Paris Bar’s own procedures were repeatedly followed by further demands, investigations or disciplinary escalation.

That distinction is fundamental.


When following the rules is still not enough

I sought a visa before complaining about a judge

One of the allegations ultimately incorporated into the first disciplinary proceeding concerned my criticism of the circumstances in which a judicial order had been made by a judge.

I did not simply send a complaint impulsively.

Before doing so, I used the Paris Bar’s own ‟Bureau des visas” procedure.

On 21 February 2020, I transmitted the proposed communication through the ordinal route. The visa request was subsequently registered under number 330247 on 3 March 2020.

The registration document does not establish that a final substantive visa was granted, and I do not suggest otherwise.

What it establishes is that I attempted to use the compliance mechanism made available by my professional regulator before taking the step I was contemplating.

Yet that did not protect me from disciplinary proceedings.

The episode itself became part of the first disciplinary case.

For me, that is one of the clearest illustrations of the problem: even seeking prior regulatory oversight was not enough to prevent subsequent disciplinary escalation.


I tried for months to use the bâtonnier-séquestre procedure

The other major component of the first disciplinary proceeding concerned disputed monies held through CARPA while a fee dispute was unresolved.

The simplified version of that history is that I improperly retained money belonging to former clients.

The documentary chronology is considerably more complicated.

Beginning in February 2020, I sought guidance from the relevant Paris Bar services concerning how the disputed amount could be handled while my entitlement to outstanding fees was being determined.

I contacted the fee-assessment service (‟Fixation des honoraires”), ‟Déontologie” and the services concerned with CARPA and sequestration.

I repeatedly asked practical questions.

Could I file the sequestration request myself?

Why did the model documentation appear to require another lawyer?

What was the legal basis for that requirement?

How precisely was I supposed to transfer the disputed amount into the hands of the ‟bâtonnier-séquestre” while protecting everyone’s rights pending determination of the fee dispute?

Those questions were repeated through March, April and May 2020.

On 13 May 2020, while those practical questions remained unresolved, the Commission de déontologie instructed me to regularise the situation rapidly and warned that disciplinary authorities could otherwise be seized.

I continued trying to resolve the matter through the formal mechanisms.

On 10 September 2020, the Paris judicial court issued an order provisionally assessing the relevant fees and authorising the amount specified in that order to be placed into sequestration with the “bâtonnier” pending final determination of the dispute.

The cheque was then delivered for sequestration.

The ‟bâtonnier-séquestre” ultimately confirmed receipt of the amount on 2 December 2020.

In other words, the documentary record shows months of efforts to use the very protective mechanism provided by the Paris Bar.

Yet the same underlying situation became one of the foundations of the first disciplinary proceeding.

My criticism is therefore not that the Paris Bar had no right to regulate the handling of client monies.

My criticism is that I repeatedly sought to comply through its own services and procedures, yet the inability of those mechanisms to provide timely operational guidance was subsequently detached from the disciplinary narrative used against me.


The data-access dispute came first

This history did not begin with disciplinary litigation.

It began years earlier with a dispute concerning professional insurance and the accuracy of information held about me.

On 28 November 2017, I exercised my right of access to personal data held by the Paris Bar.

In 2018, I complained to the French data-protection authority, the CNIL, about difficulties obtaining the requested information.

On 29 May 2018, the CNIL expressly confirmed that it had intervened with the Paris Bar to remind it of its obligations concerning the right of access and to request a response.

The Bar told the CNIL that it had disclosed all of my personal data.

I disputed the completeness of that disclosure and continued requesting clarification and rectification.

The problems did not end there.

A later subject-access request dated 21 September 2021 led to a prolonged sequence of identification demands, links that could not properly be used, renewed links, file-format issues and further requests for supplementation.

It was not until January 2023 that I expressly confirmed that I had finally been able to read the disclosed material — approximately sixteen months after the original request — after which further updated material was supplied and important completeness issues remained.

This matters because the public history of my relationship with the Paris Bar cannot be reduced to “an increasingly difficult lawyer subjected to discipline”.

There was a pre-existing and serious dispute about the institution’s own handling of my personal data.


The Paris Bar intervened repeatedly in Crefovi’s website and business communications

The Paris Bar subsequently began extensive reviews of Crefovi’s website and professional communications.

Those interventions concerned matters including the use of the plural “lawyers”, references to teams and sector groups, terms such as “specialist”, “specialised” and “expert”, descriptions of Crefovi’s international network, legal notices and external hyperlinks.

I challenged aspects of those demands.

But I also responded in detail and supplied evidence.

In February 2023, after further exchanges, I confirmed numerous changes implemented by Crefovi’s webmaster, including changes to professional terminology and website wording.

That distinction matters.

Disagreeing with the legal basis, proportionality or competitive effect of regulatory demands is not the same thing as refusing to engage with them.

My concern ultimately became broader: whether these repeated interventions in how a small, international and independent practice could describe itself, structure its communications and reach clients were genuinely proportionate regulatory measures or were operating as barriers to competition and market access.

That question is now one of the matters I have asked independent competition authorities to examine.


I tried the Paris Bar’s internal harassment mechanism

By early 2021, I considered that the combination of disciplinary, deontological and administrative actions had crossed a line.

On 4 February 2021, I formally alerted the Paris Bar’s ‟Commission Harcèlement et Discrimination(‟COMHADIS”).

I asked for an independent investigation into conduct which I characterised as institutional harassment and discrimination.

I also invoked whistleblower protections and asked for the ongoing disciplinary, deontological and accounting-control processes to be suspended while my alert was investigated.

The essential point is not that COMHADIS was obliged to accept every legal characterisation I advanced.

It is that I attempted to use the Paris Bar’s own internal protection mechanism before escalating outside the institution.

The disciplinary machinery did not stop.


I then escalated outside the Paris Bar

When internal mechanisms failed to bring the relief or independent scrutiny I had requested, I escalated my concerns.

On 7 April 2021, I brought the matter to the attention of the French Ministry of Justice, the ‟Agence française anticorruption” and the First President of the Paris Court of Appeal.

The First President’s office later indicated that the Paris public prosecutor appeared to be the appropriate judicial authority for the matters raised.

I then pursued that route too.

This sequence matters.

My response was not to bypass institutions.

It was to move progressively through them.

Internal complaint. External administrative escalation. Judicial escalation. Appeals. Regulatory complaints.

That is the opposite of refusing institutional processes.


Four disciplinary proceedings were brought over time

Over the following years, the Paris Bar opened successive disciplinary proceedings against me.

The fourth proceeding, still current in September 2026, followed three earlier disciplinary cases and was accompanied by two consecutive provisional suspension measures.

My consolidated defence statement does not ask readers to pretend that adverse decisions were never made.

They were.

I appealed them, challenged their legal and factual foundations and, where possible, sought review by higher courts and the European Court of Human Rights.

The public issue is different.

It is whether the cumulative chronology should be reduced to a succession of justified sanctions against one recalcitrant professional — or whether the record instead raises serious questions about proportionality, procedural fairness, repeated escalation and institutional power.

My position is the latter.


Being medically incapacitated did not stop the proceedings

The fourth disciplinary period overlapped with a serious and medically documented period of incapacity.

That medical incapacity was repeatedly notified to the Paris Bar and supported by medical evidence.

Nevertheless, disciplinary investigation and provisional-suspension procedures continued.

In one appeal relating to a provisional suspension, I sought an adjournment on medical grounds. The matter proceeded in my absence and the appeal was treated as unsupported.

In another matter, I attended despite my medical condition because I believed that failing to appear risked a decision being made without my defence.

My presence was then relied upon as evidence that my medical condition had not prevented me from defending myself.

That produced an impossible position:

if I did not attend, proceedings could continue without me; if I forced myself to attend, my attendance could be used to undermine the medical incapacity I had invoked.

That procedural experience forms part of the factual basis on which I describe my experience as involving institutional violence. I use that expression as my characterisation of the cumulative effects of the documented conduct, not as a legal finding already made by a court.


The fourth disciplinary hearing itself raised further procedural concerns

The hearing was scheduled for 9 September 2026.

Only on 2 September, seven days beforehand, was I provided with what was presented as a consolidated disciplinary file of approximately 1,025 pages.

The file continued changing.

On 8 September — roughly twenty-four hours before the hearing — I was told that additional material had been incorporated.

I asked for the file to be frozen, for a complete and accurate inventory, for clarity as to the version being put before the disciplinary formation, for the identity of the formation and for advance notice of the sanctions being sought.

The response stated that the inventory was provided only on an “indicative” basis and that the sanctions sought would be communicated at the hearing.

I do not regard that as a trivial procedural complaint.

It goes to whether an individual can effectively defend herself against an institution possessing far greater administrative resources and control over the dossier.


I do not accept that confidentiality should become an institutional shield

Professional secrecy and confidentiality serve legitimate and important purposes.

They protect clients.

They protect genuinely confidential professional communications.

They can protect the integrity of proceedings.

I respect those principles.

The public documents accompanying this statement are therefore being redacted to protect private medical information, personal and financial data, client information, professional secrecy and other legally protected material.

But confidentiality should not become a one-way institutional shield.

It should not mean that an institution can exercise disciplinary, administrative and regulatory power, while the person affected is effectively prevented from showing the public the correspondence and chronology necessary to explain what happened.

The public bundle therefore preserves the full architecture of the evidence.

All 226 annex references remain accounted for.

Where information requires protection, it is redacted.

Those redactions should not be interpreted as an admission concerning the merits of any allegation or dispute; they are made solely to reduce unnecessary disclosure of legally protected or private information in the public edition.

The existence of the evidence is not erased.


Insurance: obligations imposed on lawyers must be matched by functioning protection

A further strand concerns the collective insurance arrangements associated with practice at the Paris Bar.

I challenged claims for professional-insurance contributions during periods in which I was suspended from practice and disputed the handling of requests to restore workable monthly-payment arrangements.

Separately, I sought to activate insurance protection after serious events affecting me personally.

Following an incident on 2 March 2019 in Paris, during a professional trip linked to Paris Fashion Week and meetings connected with my practice, I declared a claim under the collective ‟défense pénale” arrangements.

I reported events which I characterised as police violence.

The insurer, MMA, ultimately refused the guarantee on the basis that it considered the events insufficiently connected to my professional activity.

I contested that assessment.

Following the medically documented incapacity referred to above, I also sought activation of the collective “prévoyance” arrangements.

Despite repeated exchanges, I continued to face unresolved questions concerning the administration of the claim, the applicable waiting period, the commencement and calculation of any benefits and the timetable for payment.

For me, these insurance disputes form part of the same broader question:

an institution that imposes compulsory regulatory and financial obligations on its members must also ensure that the protections attached to those obligations operate transparently and effectively.


I escalated the competition-law issues to independent authorities

By March 2026, I no longer regarded what had happened as solely a disciplinary or professional-conduct dispute.

On 27 March 2026, Crefovi and I submitted formal competition-law complaints to:

Those complaints ask independent competition authorities to examine whether the cumulative use of disciplinary, administrative, communications-related and other regulatory powers has had restrictive or exclusionary effects on an independent practice operating in the market for legal services.

The complaints ask the competent authorities to examine, among other matters, whether the circumstances disclosed potential restrictive collective practices and/or abuse of a dominant position.

I do not claim that either authority has already made a final finding that competition law was infringed.

That determination belongs to the competent authorities.

The point is that these concerns were sufficiently serious, documented and persistent for me to refer them formally to both French and European competition regulators.


What the documentary record objectively shows

Whatever legal conclusions may ultimately be drawn from these events, the documentary chronology establishes a number of objective facts.

The CNIL confirmed in May 2018 that it had intervened with the Paris Bar concerning my exercise of data-access rights.

Before making one of the communications later relied upon in disciplinary proceedings, I used the Paris Bar’s Bureau des visas procedure and the request was formally registered.

The documentary record concerning the disputed client monies shows repeated requests over several months for operational guidance about the bâtonnier-séquestre mechanism before the relevant amount was ultimately placed in sequestration.

Four disciplinary proceedings were brought against me over time, together with two successive provisional-suspension measures.

In the fourth disciplinary proceeding, what was presented as a consolidated file of approximately 1,025 pages was communicated seven days before the hearing, and further material was incorporated approximately twenty-four hours before the hearing.

In March 2026, formal competition-law complaints concerning the cumulative use and effects of regulatory powers were submitted to the French Competition Authority and to the European Commission’s Directorate-General for Competition.

Those facts do not, by themselves, determine the legal characterisation of the Paris Bar’s conduct. They do, however, explain why I reject any account which treats the disciplinary history in isolation from the institutional chronology that preceded and accompanied it.

Regulation must itself be governed by law

My criticism has never been that lawyers should be free from regulation.

They should not.

Professional regulation serves legitimate purposes.

My criticism is that regulatory power must itself remain subject to law, proportionality, transparency, procedural fairness and accountability.

The regulated person cannot be required to obey every deadline, every procedure and every formal obligation while the regulator’s own responsiveness, evidential standards and procedural responsibilities are treated as secondary.

That is the central contradiction I experienced.

I sought guidance and was later criticised in relation to the very situation for which I had asked guidance.

I sought prior regulatory oversight and the underlying conduct nevertheless became disciplinary material.

I sought internal protection and disciplinary action continued.

I sought access to my data and eventually had to involve the CNIL.

I modified website content while reserving my position, yet the regulatory intervention continued.

I appealed.

I complained.

I escalated.

I used the available institutions.

And still the disciplinary machinery intensified.


My response is now public

I have therefore decided that my defence must be accessible.

The public documentation accompanying this statement consists of:

1. A public, redacted version of my consolidated and corrected statement of defence dated 14 September 2026, and

2. A public, redacted master annex bundle retaining the original 226-piece evidential architecture.

The original procedural documents remain preserved unchanged. The documents made available to the public are separate redacted editions prepared solely for public disclosure.

The public versions redact information that should not responsibly be placed into the public domain, including private medical, personal and financial material, client information, material protected by professional secrecy and other legally protected content.

Earlier adverse publicity issued about me is not being reproduced.

The purpose of this publication is not to recreate it.

The purpose is to answer it.

This publication constitutes my public response. It does not waive, replace or exhaust any statutory right of reply, right of correction, appeal, complaint, claim or other remedy available to me or to Crefovi in relation to earlier or future publications, decisions or proceedings.


Read the documents and judge the record

I do not ask anyone to accept my account merely because I say it is true.

That is precisely why I am publishing evidence.

Readers can examine what I requested.

They can examine the Paris Bar’s responses.

They can see the chronology.

They can distinguish allegations from findings.

They can see where I complied.

They can see where I challenged.

They can see where I sought external review.

And they can form their own conclusions about whether the cumulative chronology of four disciplinary proceedings, repeated regulatory interventions and successive provisional-suspension measures represents ordinary and proportionate professional regulation — or raises materially more serious questions about proportionality, procedural fairness and institutional power.

I am not asking for immunity from scrutiny.

I am asking for scrutiny that runs in both directions.

Accountability cannot be one-sided.


Annabelle Gauberti
Founder and principal, Crefovi
Solicitor of England and Wales

Public redacted consolidated defence statement dated 14 September 2026: [LINK]

Public redacted 226-annex evidential bundle: [LINK]

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