King v. Whitmer CIVIL 20-13134 (E.D. Mich. Aug. 25, 2021) bar to the court ....” Ridder, 109 F.3d at 298 (quoting In re Ruben, 825 F.2d 977, 984 (6th Cir. 1987)). B. Sanctions Pursuant to Rule 11(b) and (c) 10 10 Although the Court mentioned the availability of imposing Rule 11 sanctions on its own initiative during the July 12 hearing, it recognizes such sanctions must be preceded by a show cause order, which was not issued here. See Fed.R.Civ.P. 11(c) (3). Moreover, for the reasons discussed infra, the Court need not rely on that authority to sanction Plaintiffs' counsel. the sanctioning of attorneys other than presenters who are “responsible” for a violation of the rule. Id.; Fed.R.Civ.P. 11(c)(1). As the Advisory Committee Notes explain: “The revision permits the court to consider whether other attorneys in the firm, co-counsel, other law firms, or the party itself should be held accountable for their part in causing a violation.” Fed.R.Civ.P. 11 Advisory Committee Notes (1993 Amendment). 11 None of the allegations in the Amended Complaint contain “specific[ ]” reference to the need for additional factual support from investigation or discovery. And Plaintiffs plead on “information and belief” Rule 11(b) reads, in part: By presenting to the court a pleading, written motion, or other paper-whether by signing, filing, submitting, or later advocating it-an attorney . . . certifies to the best of the person's knowledge, information, and belief formed after an inquiry reasonable under the circumstances: in only three of the Amended Complaint's 233-paragraphs. One of those paragraphs does not contain a fact asserted upon information and belief but seems to be concluding that facts asserted elsewhere reflect, upon information and belief, Defendants' election failure protocol; to follow another of proper those paragraphs relate to when a co-inventor of certain Dominion-related patents joined Dominion's predecessor; and the other (1) it is not being presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation; (2) the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law; [and] (3) the factual contentions have evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable opportunity for further investigation or discovery ....11 relates to Plaintiffs' allegation that Defendants failed to post certain absentee ballot information before certain times on Election Day. (See ECF No. 6 at Pg ID 934 ¶ 166, 952 ¶¶ 221, 224.) Plaintiffs have not availed themselves of Rule 11's allowance for claims that “will likely have evidentiary support after a reasonable opportunity for further investigation or discovery, ” except for arguably in the latter two instances. 11 None of the allegations in the Amended Complaint contain “specific[ ]” reference to the need for additional factual support from investigation or discovery. And Plaintiffs plead on “information and belief” in only three of the Amended Complaint's Fed. R. Civ. P. 11(b) (emphasis added). Much of the italicized language was added to Rule 11 in 1993. See Fed.R.Civ.P. 11 Advisory Committee Notes (1993 Amendment). Also added in 1993 was the provision in subsection (c) allowing for 233-paragraphs. One of those paragraphs does not contain a fact asserted upon information and belief but seems to be concluding that facts asserted elsewhere reflect, upon information and belief, 9