Can a lawyer be reprimanded for calling a colleague a "clueless" or a "foolish" lawyer?

British Columbia, Canada

The following excerpt is from Lanning (Re), 2009 LSBC 2 (CanLII):

In Law Society of Alberta v. Pozniuk, [2002] L.S.D.D. 55, the lawyer wrote to a fellow lawyer and called him “clueless”. That Panel imposed a reprimand as the case involved a single incident without the use of profanity.

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