King v. Whitmer CIVIL 20-13134 (E.D. Mich. Aug. 25, 2021) 24 As discussed earlier, Rule 11(c)(2) does not require a memorandum of law or exhibits to satisfy the safe harbor requirements. Star Mark Mgmt., 682 F.3d at 176; Ideal Instruments, Inc., 243 F.R.D. at 339; Burbidge Mitchell & Gross, 622 Fed.Appx. at 757. And as to the claimed violations of Rule 11(b)(3), the motion was specific as to the violative conduct: All of the allegations discussed in the Rule 11(b)(3) analysis below (with the exception of one) concern supposed fraud in the processing and tabulation of absentee ballots by the City at the TCF Center (see infra 68-78)-just as the City specifically identified. And the one exception concerns a key factual allegation that was debunked in Costantino. (See ECF No. 31-15 at 2440-41.) Moreover, in the Safe Harbor Motion, the City expressly refers to its response to Plaintiffs' Motion for Injunctive Relief “for a detailed debunking of Plaintiffs' baseless factual contentions.”25 (ECF No. 161-3 at Pg ID 6064 (citing ECF No. 39 at Pg ID 2808-2[8]33).) 25 Even if the City did not specify every allegation in Plaintiffs' pleading lacking evidentiary support, the same conduct could be sanctioned (and, as found infra, is sanctionable) under the Court's inherent authority. C. Sanctions Pursuant to the Court's Inherent Authority “Even if there are sanctions available under statutes or specific federal rules of procedure, . . . the ‘inherent authority' of the court is an independent basis for sanctioning bad faith conduct in litigation.” Dell, Inc. v. Elles, No. 072082, 2008 WL 4613978, at *2 (6th Cir. June 10, 2008) (citing Chambers v. NASCO, Inc., 501 U.S. 32, 49-50 (1991)); see also Runfola & Assocs. v. Spectrum Reporting II, Inc., 88 F.3d 368, 375 (6th Cir. 1996) (“In addition to Rule 11 and 28 U.S.C. § 1927, a district court may award sanctions pursuant to its inherent powers when bad faith occurs.”). To award attorneys' fees under this “bad faith exception, ” a district court must find that (i) “the claims advanced were meritless”; (ii) “counsel knew or should have known this”; and (iii) “the motive for filing the suit was for an improper purpose such as harassment.” Big Yank Corp. v. Liberty Mut. Fire Ins. Co., 125 F.3d 308, 313 (6th Cir. 1997) (citation omitted) (“The district court has the inherent authority to award fees when a party litigates in bad faith, vexatiously, wantonly, or for oppressive reasons.” (internal quotation marks omitted)). The Sixth Circuit has further explained: For a court to impose sanctions under its inherent powers, it is not necessary that the court find that an action was meritless as of filing, or even shortly thereafter. It can become apparent part-way through a suit that an action that initially appeared to have merit is in fact meritless; parties and attorneys have a responsibility to halt litigation whenever they realize that they are pursuing a meritless suit.... [M]oreover, a party or firm might enter an action long after the filing of the initial complaint, but may still be sanctionable under a court's inherent powers if it acts in bad faith. The “something more” that a court must find to meet the third prong of the Big Yank test may similarly occur at any stage of the proceedings. A court imposing sanctions under its inherent powers may consider the nature and timing of the actions that led to a finding of bad faith in determining whether to impose sanctions on conduct from that point forward, or instead to infer that the party's bad faith extended back in time, perhaps even prior to the filing of the action. BDT Prod., Inc. v. Lexmark Int'l, Inc., 602 F.3d 742, 753 n.6 (6th Cir. 2010) (emphasis in original). The Supreme Court has held that “a federal court's inherent authority to sanction a litigant for bad-faith conduct by ordering it to pay 18