What counsel cannot do is mischaracterize the state of the law. ???An attorney has a duty ???[t]o employ, for the purpose of maintaining the causes confided to him or her such means only as are consistent with truth, and never to seek to mislead the judge or any judicial officer by any artifice or false statement of fact or law.??? (Bus. & Prof. Code, ?? 6068, subd. (d).) Further, a member of the