Rule 3.4 Fairness to Opposing Party and Counsel. In all, the court found out of state counsel referred to the defense witnesses and opposing counsel as "liars" or that they "lied," at least 19 times.This presentation will discuss issues, options, and barriers in dealing with problem lawyers. The Appellate Rules Committee of the North Carolina Bar Association (the. These rules shall govern the procedure in the superior and district courts of the State of North Carolina in all actions and proceedings of a civil nature.