Attorneys may go inactive and pay a small annual fee and no continuing legal education required. No attorneys elect voluntary surrender over inactive. When one voluntarily surrenders that negates the Bar and would require them to take/pass it again to practice. Nobody chooses that after going to law school and passing the bar.
Attorneys who F up big time ALWAYS take the voluntary surrender option to forestall investigation and disbarment. Moochelle was admitted in 89 & was done in 93. She probably spent 93 being investigated & firewalled. I would guess she “practiced” for a grand total of 3 years.
Could you imagine if Sarah Palin's husband had a similar situation?
Holy crap the MSM would devote dozens of investigators to get the details.