Plaintiff appealed adverse judgment claiming the trial court erred in refusing a jury instruction regarding an adverse inference from the opposing party’s concealing evidence during discovery. This decision holds that the plaintiff forfeited the issue on appeal by misstating the record in her brief–asserting that the trial court had found that the defendant improperly concealed documents, when the trial court actually found to the contrary. Plaintiff’s brief did not even cite the trial court’s remarks in that record. They appeared for the first time in respondent’s brief. Plaintiff violated her duties of candor and providing a complete, fair statement of the facts, thus forfeiting the issue on appeal.