California, United States of America
The following excerpt is from People v. Stanley, B252979 (Cal. App. 2016):
silence so broadly. In each case cited to us, counsel "engaged in an affirmative presentation of facts to obtain judicial action and concealed material facts of which he knew the [tribunal] was not otherwise aware. Under these circumstances, the making of affirmative representations itself created the duty to also disclose other material facts that counsel knew were unknown to [the court]." (Crayton v. Superior Court, supra, 165 Cal.App.3d at p. 451.)
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