10 1 Q. I'm just going to ask you questions about 2 the case and about your knowledge, and all I ask is that 3 you give your best answers based on your knowledge. 4 A. And all I ask is, if you're going to ask any 5 questions touching on those communications and I get a 6 chance to take a look at the subjects addressed in those 7 communications -- 8 Q. If I ask you a question that you need to look 9 at something that you've never seen before to answer, 10 why don't you let us know? 11 A. Okay. Will do. 12 Q. What is your understanding of the ethical 13 responsibility of an attorney in signing a pleading to 14 be filed in Federal Court, and let's say in the Southern 15 District of Florida, if that's any different than 16 elsewhere? 17 A. Sure. 18 Q. Just give me your understanding. 19 A. Sure. The obligation is to make sure that it 20 is a good-faith pleading based on the facts and the law 21 as the attorney understands them, and consistently with 22 the obligation of the attorney to zealously represent 23 the position of his client. 24 Q. Okay. Would you agree with me that it would 25 be unethical to use pleadings for an improper purpose, ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021833