King v. Whitmer CIVIL 20-13134 (E.D. Mich. Aug. 25, 2021) change the fact that a reasonable inquiry was not done before Ramsland's initial affidavit was presented.72 72 It is unclear from counsel's answers to the Court's questions at the July 12 hearing whether Plaintiffs' attorneys questioned Ramsland about the startling numbers in his affidavit before it was filed or after. (See ECF No. 157 at Pg ID 5395-96 (Kleinhendler explaining that he asked Ramsland about “these numbers” and “[Ramsland] said, ‘Yes, yes, I did question them. Yes, I did review, and yes, it was an error' that he corrected on his reply affidavit.”).) However, even if Kleinhendler questioned Ramsland about the numbers before the affidavit was filed, such inquiry clearly was insufficient considering the readily available data contradicting them. For the reasons discussed in subsections a-e above, the Court concludes that Plaintiffs' counsel presented pleadings for which the factual contentions lacked evidentiary support. 3. Whether Plaintiffs' counsel acted with an improper purpose in violation of Rule 11(b)(1) The Court already concluded that Plaintiffs' counsel acted with an improper purpose when affirmatively labeling as an “illegal vote dump” the 100, 000 ballots discussed on the news, despite failing to inquire as to the gaps that established the relevant affidavit as nothing more than conjecture. Evidence of improper purpose can also be found in their decision to label as “eyewitness testimony” an affidavit that does not state that the affiant saw election workers manually changing votes, especially when opting not to even ask the affiant if she saw such a thing. And still, evidence of bad faith abounds. First, Campbell filed an emergency motion within hours of the July 12 hearing's conclusion, asking the Court to publicly release the recording of the proceeding. (ECF No. 152.) In that motion, some of the attorneys representing Plaintiffs argued: [O]n June 17, 2021, the Court issued an order that “[e]ach attorney whose name appears on any of Plaintiffs' pleadings or briefs shall be present at the motion hearing.” [ECF No. 123.] Media around the country picked up this story, including large internet news sites such as Yahoo, The Hill, and MSN.... Indicative of the public's interest, the Sanctions Hearing, at its peak, “attracted more than 13, 000 people watching the live video” on YouTube as broadcasted by the Court. The national media, from the Associated Press to CNN to the New York Times, ran stories on the hearing. Most outlets presented a narrative that counsel for plaintiffs believe to be incorrect. Those characterizations may change if the Court republishes the video and allows others to view it.... [T]he recording is no longer available on the Court's website. Consequently, counsel is unable to refute what they believe to be public mischaracterizations.... There was a lot of “spirit” in the hearing in this court, which the public should be able to experience in its entirety-enabling citizens to draw their own inferences from the presentations instead of depending on media presentations. (Id. at Pg ID 5284-89 (emphasis added and footnotes omitted).)73 73 Plaintiffs' attorneys also asserted that the video would assist them with the drafting of their supplemental briefs; however, this justification for releasing the video was not made until late in their brief and was addressed in only two paragraphs of the 15-paragraph submission. (ECF No. 152 at Pg ID 5289-90.) 37