To be sure, HRPC Rule 3.4(e) uses the word “knowingly,” which is defined as “denot[ing] actual knowledge of the fact in question.” HRPC Rule 1.0(f). And the “knowingly” requirement has teeth, as the Hawai‘i Supreme Court emphasized in In re Partington, 146 Hawai‘i 243, 252, 463 P.3d 900, 909 (2020), where it held that an attorney's failure to file a timely appellate brief could not be treated as a violation of HRPC Rule 3.4(e) because there was “no indication that the [Office of Disciplinary Counsel] conducted an investigation to determine whether Counsel had ‘knowingly' violated an obligation under a court rule.” But while it is settled that a violation of HRPC Rule 3.4(e) requires actual knowledge, the Hawai‘i Supreme Court has not-as far as this Court is aware-had occasion to provide further guidance as to what, precisely, an attorney must be found to actually know.