What is the severity of a federal prosecutor's misconduct in the context of misrepresentation of testimony from a grand jury?

In analyzing severity, among the elements to consider is the "extent to which the misconduct was intentional". Id. See United States v. Universita, 298 F.2d 365, 367 (2d Cir.) ("The prosecutor has a special duty not to mislead; the government should, of course, never make affirmative statements contrary to what it knows to be the truth."), cert. denied, 370 U.S. 950, 82 S.Ct. 1598, 8 L.Ed.2d 816 (1962). The government cannot properly, either explicitly or implicitly, mischaracterize the substance of grand jury testimony. Here, the prosecutor's repeated statements or implications that all of the broker nonwitnesses who received checks received loans were contrary to the grand jury testimony of four such brokers. This violated the due process prohibition against a prosecutor's making "knowing use of false evidence", including by misrepresenting the nature of nontestimonial evidence. Miller v. Pate, 386 U.S. 1, 6-7, 87 S.Ct. 785, 787-788, 17

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