These summaries were prepared by McGuireWoods LLP lawyer Thomas E. Spahn. They are based on the letter opinions issued by the Virginia State Bar. Any editorial comments reflect Mr. Spahn's current personal views, and not the opinions of the Virginia State Bar, McGuireWoods or its clients.

LEO Num	Topics	Summary
1495	27-Litigation Tactics (Including Misrepresentations, Tape Recordings) 56-Duty to Advise the Court	A Virginia lawyer may not ask a court to issue an unenforceable subpoena duces tecum addressed to a North Carolina resident, and may not request a show cause based on failure to comply. This conduct would violate the rule prohibiting a lawyer from engaging in dishonest conduct.

Copyright 2000, Thomas E. Spahn