King v. Whitmer CIVIL 20-13134 (E.D. Mich. Aug. 25, 2021) “overturn[] the will of the people” as evinced by statements made by some of Plaintiffs' attorneys. (ECF No. 78 at Pg ID 3636-43.) The City also contends that Plaintiffs' claims were not well-grounded in law, in contravention of Rule 11(b)(2). This is so, the City argues, not only because of Eleventh Amendment immunity, mootness, laches, and standing, but also because the factual allegations could not support Plaintiffs' claims or the relief they requested. (Id. at Pg ID 3658-62.) The City further contends that Plaintiffs' allegations were not well-grounded in fact, in contravention of Rule 11(b)(3): 1. Plaintiffs alleged that “Republican challengers were not given ‘meaningful' access to the ballot processing and tabulation at the Absent Voter Counting Board located in Hall E of the TCF Center, ” knowing that the assertion lacked evidentiary support because it was rejected in Costantino, the state court case decided before Plaintiffs filed the Complaint (id. at Pg ID 3644 (citing Am. Compl. at ¶¶ 13, 42, 47, 57, 59-61)); 2. Plaintiffs alleged that “Republican challengers were exclusively barred from entering the TCF Center, ” knowing that the assertion was rejected in Costantino (id. at Pg ID 3645 (citing Am. Compl. at ¶¶ 62-63)); 3. Plaintiffs alleged that some absentee ballots were “pre-dated, ” knowing that the assertion was rejected in Costantino (id. at Pg ID 3645-46 (citing Am. Compl. at ¶¶ 88, 90)); 4. Plaintiffs alleged that ballots were “counted more than once, ” knowing that the assertion was both rejected in Costantino and “conclusively disproven by the Wayne County canvass” (id. at Pg ID 364647 (citing Am. Compl. at ¶ 94)); 5. Plaintiffs alleged that a “software weakness” in Dominion machines “upended Michigan's election results, ” knowing that the “two instances of errors [to which Plaintiffs cite]-one in Antrim County and one in Oakland County (Rochester Hills)”-did not constitute evidentiary support for the allegation (id. at Pg ID 3647-49); 6. Plaintiffs “intentional[ly] lie[d]” by filing the partially redacted declaration of “Spider”-who Plaintiffs identified as “a former U.S. Military Intelligence expert” and “former electronic intelligence analyst with the 305th Military Intelligence”which was signed by Joshua Merritt, who never completed the entry-level training course at the 305th Military Intelligence Battalion and is not an intelligence analyst (id. at Pg ID 3651-52 (citing Am. Compl. at ¶¶ 17, 161)); 7. Plaintiffs “intentional[ly] lie[d]” by filing the declaration of Russell James Ramsland, Jr., who claimed (i) that there were “reports of 6, 000 votes in Antrim County that were switched from Donald Trump to Joe Biden and were only discoverable through a hand counted manual recount, ” when “there were no hand recounts in Michigan as of that date”; (ii) “statistically improbable” voter turnouts, including a turnout of 781.91% in North Muskegon, where the publiclyavailable official results were known, as of election night, to be approximately 78%, and a turnout of 460.51% (or, elsewhere on the same chart, 90.59%) in Zeeland Charter Township, where it was already known to be 80%”; and (iii) that “‘ballots can be run through again effectively duplicating them, '” when there were “safeguards in place to prevent double counting of ballots in this way” (id. at Pg ID 3652-54 (emphasis in original)); and 7