In United States v. LaPage (9th Cir. 2000) 231 F.3d 488, the defendant was prosecuted and convicted for making false statements to a federally insured bank to obtain a loan. The Ninth Circuit reversed the conviction because the prosecutor had knowingly used false testimony from a key witness: "It is fundamentally unfair for a prosecutor to knowingly present perjury to the jury. . . . Because the use of known lies to get a conviction deprives a defendant of his constitutional right to due process of law, we must reverse the defendant's conviction unless the third-party witness's testimony was 'harmless beyond a reasonable doubt.'" (Id. at p. 491.) The court concluded, "No lawyer, whether prosecutor or defense counsel, civil or criminal, may knowingly present lies to a jury and then sit idly by while opposing counsel struggles to contain this pollution of the trial. . . . A prosecutor has a special duty commensurate with a prosecutor's unique power, to assure that defendants receive fair trials." (Id. at p. 492.) Although the Ninth Circuit in dictum addressed the obligation of lawyers in civil actions not to use false testimony, LaPage involved a prosecutor's knowing use of false testimony to obtain the defendant's conviction. That is a far different situation from a civil dispute between private parties in which a third-party witness allegedly testified falsely on cross-examination when asked if he had ever telephoned plaintiff's counsel. LaPage emphasized the unique ethical obligation of prosecutors, who, as the court expressly stated, have "a special duty commensurate with a prosecutor's unique power, to assure that defendants receive fair trials." (LaPage, supra, 231 F.3d at p. 642.)