King v. Whitmer CIVIL 20-13134 (E.D. Mich. Aug. 25, 2021) newspaper article alerted him to the sanctions motion filed against him and this is why. 17 The existence of a misunderstanding seems improbable given that several similar lawsuits seeking to overturn the presidential election results were filed in Georgia, Wisconsin, and Arizona, each bearing the same “Of Counsel” listing for Wood as appears here. See Compl., Pearson v. Kemp, No. 1:20-cv-04809 (N.D.Ga. filed Nov. 25, 2020), ECF No. 1 at ¶ 103; Compl., Feehand v. Wisconsin Kimberly Hunt, the office manager for the City's attorneys, affirms in an affidavit that she mailed via First Class U.S. Mail a copy of the Safe Harbor Letter and the Safe Harbor Motion to Wood, among others, on December 15, 2020, and that no copies were returned as undeliverable. (ECF No. 164-3 at Pg ID 6393 ¶¶ 5, 8.) And despite being told that he had the opportunity to attach an affidavit to his supplemental brief in order to put his oath behind his factual assertions (see ECF No. 157 at Pg ID 5517), Wood surprisingly chose not to do so.19, 20 Elections Commission, No. 2:20-cv-01771 (E.D. Wis. filed Dec. 1, 2020), ECF No. 1 18 Notably, while Wood stated at the July 12 at ¶ 51; Compl., Bowyer v. Ducey, No. hearing that he only learned about the 2:20-cv-02321 (D. Ariz. filed Dec. 2, motions seeking sanctions against him 2020), ECF No. 1 at ¶ 53. Wood moved for when he read about it in a newspaper pro hac vice admission in the Arizona article, Wood suggests in his supplemental proceedings. See Remark, Bowyer, No. brief that he in fact learned of his purported 2:20-cv-02321 (D. Ariz. Dec. 4, 2020). He involvement in the lawsuit when he did not do so in Wisconsin but, like received a call from one of the attorneys in Michigan, the District Court for the Eastern this matter in mid- to late-June 2021, District of Wisconsin does not permit pro alerting him to the Court's order requiring hac vice motions. E.D. Wis. LR 83(c)(2) him to appear at the hearing on the (E). sanctions motions. (ECF No. 162 at Pg ID 6102.) First, the City's motion for sanctions was filed on January 5, 2021. (ECF No. 78.) At no time between that date and the July 12 hearing did Wood ever notify the Court that he had been impermissibly included as counsel for Plaintiffs in this action. Almost a month before the motion hearing, the Court entered an order requiring “[e]ach attorney whose name appears on any of Plaintiffs' pleadings or briefs” to be present at the hearing. (ECF No. 123.) Wood still did not submit anything to the Court claiming that his name was placed on those filings without his permission. No reasonable attorney would sit back silently if his or her name were listed as counsel in a case if permission to do so had not been given. Second, Wood is not credible.18 He claims that he was never served with the City's motion for sanctions; however, counsel for the City represents that the motion was sent to Wood via e-mail and regular mail. (ECF No. 157 at Pg ID 5363-64.) 19 Wood asserts in his supplemental brief that he “and his legal assistant have performed a diligent search of all email correspondence as well as U.S. mail at Mr. Wood's Atlanta office and elsewhere. They have turned up no evidence to indicate they were provided with any Rule 11 notice prior to the filing of the motion.” (ECF No. 162 at Pg ID 6122.) Yet no affidavit is offered from Wood or his legal assistant to attest to these assertions. And notably, the address listed for Wood on the filings in this matter (and thus where the City's attorneys mailed items to him) is a post office box, not his firm's address. 20 Wood contends that he is entitled to a “full evidentiary hearing”-“should the Court determine that material factual questions do exist”-so that he “may present to the Court with the evidence of record, sufficient to establish the factual 13