When a disciplinary tribunal finds that a practitioner intentionally misled the court, the finding must be assessed against the [name withheld] standard with proper regard to competing inferences available from the objective background circumstances. A practitioner's incompetence and confusion may support an alternative inference inconsistent with intentional misleading. However, deliberate omission of material information from correspondence to opposing practitioners, particularly when contrasted with contemporaneous communications to the practitioner's own client disclosing the same information, is capable of supporting a finding of intentional misleading to the [name withheld] standard.
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