non BP WO NO -|- ODO OO WDN OO OT BP WO NYO —

Oo O DN OO FF WwW NY =| NO RO PO PNP NM NO | S| S| HS SF S| S| S| S| S| non BP WO NO -|- ODO OO WDN OO OT BP WO NYO — 15 of engaging in criminal misconduct, the attorney needs to do a thorough investigation; is that right? A. Yeah, under the circumstances, sure. I should say in light of the circumstances, obviously, you know, different kinds of cases can have different circumstances. Q. Okay. Is one of the considerations that goes into that how much -- whether there's time pressure to get the pleading on file? A. Sure. That would be one of the factors. Q. And how much time the attorney has to investigate the facts? A. Yes. That would be one of the factors as well. Q. Okay. And so before making -- where an attorney's client has no pressing need to get a pleading on file immediately, and the pleading is going to include serious allegations of misconduct by another person, an ethical attorney will take the time needed to do a full investigation; is that fair? A. That's fair, and the converse of your proposition is also fair. For example, if a client has a pending discovery dispute in front of a judge that could be ruled on any day, that would be an exigency that would require pleadings to be filed more quickly ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021838