Dishonest falsification, destruction and hiding of a document or accounts is false accounting. False accounting includes the use of such a document knowing or suspecting it to be false or misleading. The purpose of false accounting is to cause gain or loss to another.
By filing a false accounting in court, a person commits fraud upon a court. [Atty. Griev. Comm'n v. Christopher, 383 Md. 624, 651 (Md. 2004)]
For an attorney to deliberately falsify documents in a judicial proceeding in an attempt to avoid disclosure of exorbitant fees and questionable payments is manifestly contrary to the professional qualities of honesty, justice, and good character. [Office of Disciplinary Counsel v. Bell, 15 Ohio St. 3d 118, 119 (Ohio 1984)].