Can an attorney be held liable as a principal for documents prepared and submitted for his client?

An attorney may incur criminal liability as a principal for documents he has prepared and submitted for his client. See United States v. Lopez, 728 F.2d 1359, 1361-63 (11th Cir.), cert. denied, --- U.S. ----, 105 S.Ct. 112, 83 L.Ed.2d 56 (1984); United States v. Librach, 520 F.2d 550, 552 (8th Cir.1975), cert. denied, 429 U.S. 939, 97 S.Ct. 354, 50 L.Ed.2d 308 (1976). For example, in Lopez the defendant attorney was convicted for violating section 1001 when he falsified priority dates on applications for permanent resident status he submitted on behalf of his immigration clients, in order to speed up the administrative process and permit his clients to pursue a class action. 728 F.2d at 1361-62. The Lopez court found that the attorney's actions constituted a material false statement prohibited by section 1001, even though the actions were taken on behalf of the clients. Id. at 1362-63.