"As you know, the Virginia State Bar and D.C. Bar Rules of Professional Conduct Rule 3.3 "Candor Toward the Tribunal" prevents a lawyer from making "a false statement of fact or law to a tribunal." Furthermore, Rule 8.4(c) states that it is professional misconduct for a lawyer to "engage in conduct involving dishonesty, fraud, deceit or misrepresentation which reflects adversely on the lawyer's fitness to practice law.""
Mueller Report

January 1, 1970

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