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Perhaps the one piece of information common to all trial lawyers is that they are officers of the court obligated to be honest with the courts. This common law duty was codified in California’s original 1872 Civil Code, and now is located at Bus. & Prof. Code § 6068: “It is the duty of an attorney to do all of the following: … (d) To employ, for the purpose of maintaining the causes confided to him or her those means only as are consistent with truth, and never to seek to mislead the judge or any judicial officer by an artifice or false statement of fact or law.”