I will be loyal to my client's confidences and secrets

3. I will keep my clients informed and involved in making the decisions that affect them. 4. I will communicate regularly with my client and will respond promptly and courteously to my client's communications. 5. I will endeavor to reach clear agreements with clients concerning the scope of the representation. 6. I will be loyal and committed to my client's cause, but I will not permit that loyalty and commitment to interfere with my ability to provide my client with objective and independent advice. 7. I will endeavor to achieve my client's lawful objectives in business transactions and in litigation as expeditiously and economically as possible. 8. In appropriate cases, I will counsel my client with respect to mediation, arbitration and other alternative methods of resolving disputes. 9. I will advise my clients against pursuing litigation (or any other course of action) that is without merit and against insisting on tactics which are intended to delay resolution of the matter or to harass or drain the financial resources of the opposing party. 10. While I must abide by my client's decision concerning the objectives of the representation, I nevertheless will counsel my client that a willingness to initiate or engage in settlement discussions is consistent with zealous and effective representation. 11. While I recognize that disagreements between parties may cause harsh feelings, I will act with compassion and not make personal attacks on other parties, their lawyers or the court. 12. I will advise my client that civility and courtesy are not to be equated with weakness. 13. I will not acquiesce to the demand of a client that I abuse the principles set forth in these standards while acting in his or her behalf. 151 Revised October 2023 B. Lawyer's Obligations To Opposing Parties and Their Counsel: 1. I will practice my profession with a continuing awareness that my role is to advance the legitimate interests of my clients. In my dealing with others I will not reflect the ill feelings of my clients. I will treat all other counsel, parties and witnesses in a civil and courteous manner, not only in court, but also in all other written and oral communications. 2. I will not, even when called upon by a client to do so, abuse or indulge in offensive conduct directed to other counsel, parties or witnesses. I will abstain from disparaging personal remarks or acrimony toward other counsel, parties, or witnesses. I will treat adverse witnesses and parties with fair consideration. 3. I will not encourage or knowingly authorize any person under my control to engage in conduct that would be improper if I was to engage in such conduct. 4. I will avoid attributing bad motives or improper conduct to other counsel or bringing the profession into disrepute by public accusations of impropriety. 5. I will not seek court sanctions without first conducting a reasonable investigation and unless fully justified by the circumstances and necessary to protect my client's lawful interests. 6. I will in good faith adhere to all express promises and to agreements with other counsel, whether oral or in writing, and to all agreements implied by the circumstances or local customs. 7. When I reach an oral understanding with other counsel on a proposed agreement or stipulation and a decision is made to commit it to writing I will endeavor in good faith to state the oral understanding accurately and completely. 8. I will endeavor to confer early with other counsel to assess settlement possibilities. I will not falsely hold out the possibility of settlement to obtain unfair advantage. 9. In civil actions, I will stipulate to relevant matters if they are undisputed and if no good faith advocacy basis exists for not stipulating. 10. I will not use any form of discovery or discovery scheduling as a means of harassment. 11. Whenever circumstances allow, I will make good faith efforts to resolve by agreement objections before presenting them to the court. 12. I will not request an extension of time solely for the purpose of unjustified delay or to obtain unfair advantage. 13. I will consult other counsel regarding scheduling matters in a good faith effort to avoid scheduling conflicts. 152 Revised October 2023 14. I will endeavor to accommodate previously scheduled dates for hearings, depositions, meetings, conferences, vacations, seminars, or other functions that produce good faith calendar conflicts on the part of other counsel. 15. I will promptly notify other counsel and, if appropriate, the court or other persons when hearings, depositions, meetings, or conferences are to be canceled or postponed. 16. I will agree to reasonable requests for extensions of time and for waiver of procedural formalities, provided my client's legitimate rights will not be materially or adversely affected. 17. I will take depositions only when actually needed. I will not take depositions for the purposes of harassment or other improper purpose. 18. I will not engage in any conduct during a deposition that would not be appropriate in the presence of a judge. 19. I will not obstruct questioning during a deposition or object to deposition questions unless permitted under applicable law. 20. During depositions I will ask only those questions I reasonably believe are necessary and appropriate for the prosecution or defense of an action. 21. I will carefully craft document production requests so they are limited to those documents I reasonably believe are necessary and appropriate for the prosecution or defense of an action. I will not design production requests to place an undue burden or expense on a party, or for any other improper purpose. 22. I will respond to document requests reasonably and not strain to interpret requests in an artificially restrictive manner to avoid disclosure of relevant and non-privileged documents. I will not produce documents in a manner designed to hide or obscure the existence of particular documents, or to accomplish any other improper purpose. 23. I will carefully craft interrogatories so they are limited to those matters I reasonably believe are necessary and appropriate for the prosecution or defense of an action, and I will not design them to place an undue burden or expense on a party, or for any other improper purpose. 24. I will instruct my client to respond to interrogatories reasonably and will not strain to interpret them in an artificially restrictive manner to avoid disclosure of relevant and non-privileged information, or for any other improper purpose. 25. I will base my discovery objections on a good faith belief in their merit and will not object solely for the purpose of withholding or delaying the disclosure of relevant information, or for any other improper purpose. 153 Revised October 2023 26. When an order is to be prepared by counsel to reflect a court ruling, I will promptly draft an order that accurately and completely reflects the court's ruling. 27. I will not ascribe a position to another counsel that counsel has not taken. C. Lawyers' Obligations To The Court and Other Tribunals: 1. I will be a vigorous advocate, while paying heed to the concept of common courtesy. I recognize that excessive zeal is injurious to my client's interests and the proper functioning of our system of justice. 2. I will communicate with opposing counsel in an effort to avoid litigation and to resolve existing litigation.