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standards under the law. My understanding is that frivolity is the standard for, for example, rule 11 sanctions.
Q. Is it unethical to include, in your opinion, to include allegations in a pleading for the purpose of generating publicity?
A. If that's the only purpose, sure, that it would be inappropriate.
Q. And is it unethical to make allegations without having done a reasonable investigation to satisfy -- for the attorney to satisfy himself or
herself that there's a factual basis for the
allegations?
A. Something along those lines, sure.
Q. As a general matter, you agree with that proposition?
A. Yes, sure.
Q. Would you agree that the scope of the investigation, the reasonable investigation an attorney must do, varies depending upon the nature of the
allegations being made?
A. Sure, yes.
Q. Let me finish -- we are both speaking at the same time --
A. Sure.
ROUGH DRAFT ONLY
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