12 1 standards under the law. My understanding is that 2 frivolity is the standard for, for example, rule 11 3 sanctions. 4 Q. Is it unethical to include, in your opinion, 5 to include allegations in a pleading for the purpose of 6 generating publicity? 7 A. If that's the only purpose, sure, that it 8 would be inappropriate. 9 Q. And is it unethical to make allegations 10 without having done a reasonable investigation to 11 satisfy -- for the attorney to satisfy himself or 12 herself that there's a factual basis for the 13 allegations? 14 A. Something along those lines, sure. 15 Q. As a general matter, you agree with that 16 proposition? 17 A. Yes, sure. 18 Q. Would you agree that the scope of the 19 investigation, the reasonable investigation an attorney 20 must do, varies depending upon the nature of the 21 allegations being made? 22 A. Sure, yes. 23 Q. Let me finish -- we are both speaking at the 24 same time -- 25 A. Sure. ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021835