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.'