King v. Whitmer CIVIL 20-13134 (E.D. Mich. Aug. 25, 2021) motion, or other paper was submitted.” Gibson v. Solideal USA, Inc., 489 Fed.Appx. 24, 29-30 (6th Cir. 2012) (quoting Merritt v. Int'l Ass'n of Machinists and Aerospace Workers, 613 F.3d 609, 626 (6th Cir. 2020)). that non-signing attorneys cannot be sanctioned were decided before the 1993 amendments to Rule 11. (See ECF No. 95 at Pg ID 4116-17.) 13 Junttila, however, did sign and docket subsequently filed motions, briefs, or other This objective standard is “intended to eliminate any ‘empty-head pure-heart' justification for patently frivolous arguments.” Fed.R.Civ.P. 11 Advisory Committee Notes (1993 Amendment); Tahfs v. Proctor, 316 F.3d 584, 594 (6th Cir. 2003) (“A good faith belief in the merits of a case is insufficient to avoid sanctions.”). papers 1. Signatures it”) (emphasis added). Plaintiffs' lawyers argue that no attorney can be sanctioned whose name appeared only in typewritten form; that no attorney besides Plaintiffs' local counsel has appeared or signed a document filed in this matter; and that the Court lacks jurisdiction to sanction any attorney who did not personally appear or sign a document filed in this matter. (ECF No. 95 at Pg ID 4116-18.) Yet, the local attorneys assert that, although they signed the filings, they did not prepare them and thus should not be responsible for them. (See ECF No. 157 at Pg ID 5322-24, 5359, 5523; ECF No. 111-1 at Pg ID 4597 ¶¶ 2, 4, 6, 7, 9, 15.) As such, no attorney wants to take responsibility now that sanctions are sought for filing this lawsuit. In this age of electronic filing, it is frivolous to argue that an electronic signature on a pleading or motion is insufficient to subject the attorney to the court's jurisdiction if the attorney violates the jurisdiction's rules of professional conduct or a federal rule or statute establishing the standards of practice. As set forth earlier, Sidney Powell, Scott Hagerstrom, and Gregory Rohl electronically signed-at least-the Complaint, Amended Complaint, and Motion for Injunctive Relief. The remaining attorneys, except Junttila, were listed as “Of Counsel” on one or more of the pleadings.13 The cases Plaintiffs cite to support their argument in which she and Plaintiffs' remaining attorneys advocated the claims asserted in their pleadings. (See, e.g., ECF No. 85 at Pg ID 3896-3906); see also Fed. R. Civ. P. 11(b) (indicating that counsel “present[s] to the court a pleading, written motion, or other paper” by, inter alia, “signing, ” “filing, ” or “later advocating For purposes of Rule 11, an attorney who is knowingly listed as counsel on a pleading, written motion, or other paper “expressly authorize[d] the signing, filing, submitting or later advocating of the offending paper” and “shares responsibility with the signer, filer, submitter, or advocate.”14 Morris v. Wachovia Sec., Inc., No. 3:02cv797, 2007 WL 2126344, at *9 (E.D. Va. 2007) (emphasis removed) (quoting Gregory P. Joseph, Sanctions the Fed. Law of Litig. Abuse, § 5(E)(1) at 110 (3d ed. 2000)). “The Court need not go through ‘mental gymnastics,' as pre-1993 courts sometimes felt compelled to do, see Sanctions, § 5(E)(1) at 109, in order [to] hold [the attorney] to account under Rule 11.” Id. 14 At the July 12 hearing, Wood asserted for the first time that he was oblivious to his inclusion as counsel for Plaintiffs in this case. The Court will address this assertion separately. Notably, because Rule 11 only requires a signature by “at least one attorney, ” Fed.R.Civ.P. 11(a), documents are frequently presented to federal courts which list several attorneys as counsel but contain the signature of only one. Regardless, as amended in 1993, Rule 11 allows for sanctions “on any attorney . . . that violated the rule or is responsible for the violation.” Fed.R.Civ.P. 11(c) (1) (emphasis added). Moreover, Michigan Rule of Professional Conduct 8.5(a) reads: “A lawyer 11