11 1 for a purpose other than to advance a cause in 2 litigation? 3 A. Sure. 4 Q. And would you agree with me that it would be 5 unethical to make allegation of misconduct by a person 6 in a pleading if that -- if those allegations were not 7 relevant to the case? 8 A. Sure. 9 Q. And would you agree -- 10 A. Actually, not pertinent to the case. 11 Q. Not pertinent to the case? 12 A. Yeah. And when you say not relevant, 13 obviously, reasonable people can have disagreements 14 about what allegations are relevant to the case or not. 15 Q. And my question is that an attorney, it would 16 be unethical, do you agree, for an attorney to sign a 17 pleading where the attorney does not have a good-faith 18 basis that the allegations of misconduct are relevant to 19 the case, are pertinent to the case? 20 A. Pertinent to the case, and as I understand 21 for example under rule 11, the requirement is that the 22 allegations being advanced must not be frivolous. 23 Q. And that there's a good-faith basis for them? 24 A. Well, I mean if you're talking about good 25 faith frivolity, those are I mean, potentially different ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021834