King v. Whitmer CIVIL 20-13134 (E.D. Mich. Aug. 25, 2021) unwarranted suspicion); proffering factual allegations and claims without engaging in the required prefiling inquiry; and dragging out these proceedings even after they acknowledged that it was too late to attain the relief sought. And this case was never about fraud-it was about undermining the People's faith in our democracy and debasing the judicial process to do so. While there are many arenas-including print, television, and social media-where protestations, conjecture, and speculation may be advanced, such expressions are neither permitted nor welcomed in a court of law. And while we as a country pride ourselves on the freedoms embodied within the First Amendment, it is well-established that an attorney's freedom of speech is circumscribed upon “entering” the courtroom.2 rules, and attempted to undermine the integrity of the judiciary along the way.3 As such, the Court is duty-bound to grant the motions for sanctions filed by Defendants and Intervenor-Defendants and is imposing sanctions pursuant to Rule 11 of the Federal Rules of Civil Procedure, 28 U.S.C. § 1927, and its own inherent authority. 3 Plaintiffs' counsel and their counsel have suggested that this Court's handling of these proceedings and any resultant decision can be expected based on the President who appointed the undersigned. This is part of a continuing narrative fostered by Plaintiffs' counsel to undermine the institutions that uphold our democracy. It represents the same bad faith that is at the base of this litigation. To be clear, all federal judges, President regardless appoints them, of which take oaths 2 See Mezibov v. Allen, 411 F.3d 712, 717, affirming that they will “faithfully and 720-21 (6th Cir. 2005) (quoting Gentile v. impartially discharge” their duties, 28 State Bar of Nev., 501 U.S. 1030, 1071 U.S.C. § 453, and uphold and protect the (1991)) (“[The Supreme Court] has noted . Constitution of the United States, 5 U.S.C. . . that ‘[i]t is unquestionable that in the § 3331. courtroom itself . . . whatever right to ‘free speech' an attorney has is extremely circumscribed.... [I]n filing motions and advocating for his client in court, [an attorney is] not engaged in free expression; he [is] simply doing his job. In that narrow capacity, he voluntarily accept[s] almost unconditional restraints on his personal speech rights .... For these reasons, . . . in the context of the courtroom proceedings, an attorney retains no personal First Amendment rights ....”). Indeed, attorneys take an oath to uphold and honor our legal system. The sanctity of both the courtroom and the litigation process are preserved only when attorneys adhere to this oath and follow the rules, and only when courts impose sanctions when attorneys do not. And despite the haze of confusion, commotion, and chaos counsel intentionally attempted to create by filing this lawsuit, one thing is perfectly clear: Plaintiffs' attorneys have scorned their oath, flouted the I. Procedural History On November 3, 2020, a record 5.5 million Michigan residents voted in the presidential election, resulting in then-Former Vice-President Joseph R. Biden, Jr. securing over 150, 000 more votes than then-President Donald J. Trump.4 By the following evening, President Biden had been declared the winner in the State.5Even though Michigan law establishes an extensive procedure for challenging elections, see Mich. Comp. Laws §§ 168.831-.832, .879, Plaintiffs did not avail themselves of those procedures, as they conceded at the July 12, 2021 motion hearing before this Court (ECF No. 157 at Pg ID 5332-33). 4 Moving forward, the Court refers to the current and former presidents as President Biden and Former President Trump, respectively. 2

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