proof in this record is the official data on the Pennsylvania open data portal correctly listing the ballots requested as 3.08 million. The above identified misstatements violate Rules of Professional Conduct 4.1 and 8.4(c). On November 17, 2020 respondent appeared as the attorney for plaintiff on a matter captioned Donald J. Trump for President, Inc. v Boockvar (Boockvar), in the United States District Court for the Middle District of Pennsylvania (502 F Supp 3d 899, affd 830 Fed Appx 377 [3d Cir 2020]). He was admitted pro hac vice based on his New York law license. Respondent repeatedly represented to the court that his client, the plaintiff, was pursuing a fraud claim, when indisputably it was not. Respondent’s client had filed an amended complaint before the November 17, 2020 appearance in which the only remaining claim asserted was an equal protection claim, not based on fraud at all. The claim concerned the experience of two voters having their mail-in ballots rejected and challenged the notice and cure practices concerning mail-in ballots in different counties. The plaintiff’s original complaint had included claims about canvassing practices. The plaintiff, however, voluntarily withdrew those claims when it served the amended complaint. Notwithstanding, respondent insisted on extensively arguing a fraud case based on the withdrawn canvassing claims. 6 7 We accept for purposes of this proceeding respondent’s characterization of the withdrawn claim as a fraud claim. It is not clear to us that this characterization is correct, but it does not affect our analysis. 6 Coincidently, while the parties were in court that day, they received word that the state claims regarding canvassing had been decided against the plaintiff in the Supreme Court of the State of Pennsylvania (In re Canvassing Observation, 241 A3d 339 [Pa 2020], 7 11