The BankAtlantic Motion for Rule 11 Sanctions.

This is a very interesting read, particularly in light of recent efforts to return Rule 11 to the mandatory/no safe harbor regime we had in place during the go-go 80s, which many argue was a bust for reasons having little to do with having any judicial sympathy for vexatious litigants.


  1. That ish is tight. Wish I had me five minions on my signature block. Gene: "yo, you over there . . . Yous gots paragraphs 1, 6, 11, 16, and 21. You with the nice breastages, you gots 2, 7, 12, 17 and 22. Any questions mofos. Okay, go do the lord's work".

  2. The motion is "very interesting." But not nearly as interesting as the response will be. This motion is a neat trap. Plaintiffs will make a response loaded with evasions and half hearted admissions of "mistakes," etc. But then Stearns will file a response that basically puts their positions and assertions in a noose. I wonder if Plaintiffs' counsel will hire their own lawyer or just walk off the plank unassisted.

  3. Sterns comes across as a crybaby. The defendant should respond that it proved the case to a jury and won, that the Judge has denied Stern's motion for new trial in the event she is reversed in tossing the verdict, and that the judge found stern's client committed fraud.

    This is the pleading of a lawyer who got his ass kicked in trial and was saved by the Judge; but whose ego is so excessively large that he cannot stand to be happy with the outcome.

    Judge Ungaro should deny it outright.

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