PREPARING AND OFFERING FALSE DOCUMENTS FOR TRIAL
California Penal Code sec. 132 makes it a felony to offer false evidence at a trial. Defense counsel USED a false document to impeach the prosecution's witness (apparently successfully). Is this OFFERING? Yep, says this Court of Appeal, close enough for government work. Penal Code sec. 134 makes it a felony to prepare a false document for use at trial. Here, the defendant induced DMV to create the false document. You guessed it, again it's close enough for government work.
People v. Bhasin; 2009 DJ DAR 11626; DJ, 8/10/09; C/A 4th