Oo O DN OO FF WwW NY =|
NO RO PO PNP NM NO | S| S| HS SF S| S| S| S| S| non BP WO NO -|- ODO OO WDN OO OT BP WO NYO —
11
for a purpose other than to advance a cause in litigation?
A. Sure.
Q. And would you agree with me that it would be unethical to make allegation of misconduct by a person in a pleading if that -- if those allegations were not
relevant to the case?
A. Sure.
Q. And would you agree --
A. Actually, not pertinent to the case. Q. Not pertinent to the case?
A. Yeah. And when you say not relevant,
obviously, reasonable people can have disagreements about what allegations are relevant to the case or not.
Q. And my question is that an attorney, it would be unethical, do you agree, for an attorney to sign a pleading where the attorney does not have a good-faith basis that the allegations of misconduct are relevant to the case, are pertinent to the case?
A. Pertinent to the case, and as I understand for example under rule 11, the requirement is that the allegations being advanced must not be frivolous.
Q. And that there's a good-faith basis for them?
A. Well, I mean if you're talking about good
faith frivolity, those are I mean, potentially different
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