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Q. I'm just going to ask you questions about the case and about your knowledge, and all I ask is that you give your best answers based on your knowledge.
A. And all I ask is, if you're going to ask any questions touching on those communications and I get a chance to take a look at the subjects addressed in those communications --
Q. If I ask you a question that you need to look at something that you've never seen before to answer, why don't you let us know?
A. Okay. Will do.
Q. What is your understanding of the ethical responsibility of an attorney in signing a pleading to be filed in Federal Court, and let's say in the Southern District of Florida, if that's any different than
elsewhere?
A. Sure. Q. Just give me your understanding. A. Sure. The obligation is to make sure that it
is a good-faith pleading based on the facts and the law as the attorney understands them, and consistently with the obligation of the attorney to zealously represent the position of his client.
Q. Okay. Would you agree with me that it would
be unethical to use pleadings for an improper purpose,
ROUGH DRAFT ONLY
HOUSE_OVERSIGHT_021833