THE preamble of the Code of Professional Responsibility and Accountability (the Code) states that "the existence of a free and independent society depends upon the recognition of the concept that justice is based on the rule of law" and a lawyer's "failure to abide by the Code results in sanctions."

Section 8 of the Code requires a lawyer to "not misquote, misrepresent or mislead the court as to the existence or contents of any document, argument, evidence, law or other legal authority." Section 11 further mandates that a lawyer "shall not make false representations or statements" and they "shall be liable for any material damage caused by such false representations or statements."

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