15 1 of engaging in criminal misconduct, the attorney needs 2 to do a thorough investigation; is that right? 3 A. Yeah, under the circumstances, sure. I 4 should say in light of the circumstances, obviously, you 5 know, different kinds of cases can have different 6 circumstances. 7 Q. Okay. Is one of the considerations that goes 8 into that how much -- whether there's time pressure to 9 get the pleading on file? 10 A. Sure. That would be one of the factors. 11 Q. And how much time the attorney has to 12 investigate the facts? 13 A. Yes. That would be one of the factors as 14 well. 15 Q. Okay. And so before making -- where an 16 attorney's client has no pressing need to get a pleading 17 on file immediately, and the pleading is going to 18 include serious allegations of misconduct by another 19 person, an ethical attorney will take the time needed to 20 do a full investigation; is that fair? 21 A. That's fair, and the converse of your 22 proposition is also fair. For example, if a client has 23 a pending discovery dispute in front of a judge that 24 could be ruled on any day, that would be an exigency 25 that would require pleadings to be filed more quickly ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021838