King v. Whitmer Defendants' election failure protocol; to follow another of CIVIL 20-13134 (E.D. Mich. Aug. 25, 2021) proper those paragraphs relate to when a co-inventor of certain Dominion-related patents joined Dominion's predecessor; and the other court; [and] referring the matter to disciplinary authorities.”12 Fed.R.Civ.P. 11 Advisory Committee Notes (1993 Amendment). 12 Plaintiffs maintain that the City's Rule 11 that motion is procedurally defective because it Defendants failed to post certain absentee seeks “both Rule 11 sanctions and . . . ballot information before certain times on disbarment of attorneys and their referral to Election Day. (See ECF No. 6 at Pg ID 934 state bar associations for disciplinary ¶ 166, 952 ¶¶ 221, 224.) Plaintiffs have not action.” (ECF No. 95 at Pg ID 4114-45.) availed themselves of Rule 11's allowance Plaintiffs note that Rule 11 motions “must for claims that “will likely have evidentiary be made separately from any other support after a reasonable opportunity for motion[.]” (Id. at Pg ID 4145 (citing further investigation or discovery, ” except Fed.R.Civ.P. 11(c)(2) (emphasis added by for arguably in the latter two instances. Plaintiffs)).) relates to Plaintiffs' allegation Plaintiffs' argument is frivolous. The separate-motion requirement Any sanction imposed pursuant to Rule 11 “must be limited to what suffices to deter repetition of the conduct or comparable conduct by others similarly situated.” Fed.R.Civ.P. 11(c)(4). This is because “the central purpose of Rule 11 is to deter baseless filings in district court.” Cooter & Gell v. Hartmarx Corp., 496 U.S. 384, 393 (1990). Thus, “[e]ven if the careless litigant quickly dismisses the action, the harm triggering Rule 11's concerns has already occurred[, ]” and “the imposition of such sanctions on abusive litigants is useful to deter such misconduct.” Id. at 399. Rule 11 “de-emphasizes monetary sanctions and discourages direct payouts to the opposing party.” Rentz v. Dynasty Apparel Indus., Inc., 556 F.3d 389, 395 (6th Cir. 2009) (quoting Ridder, 109 F.3d at 294 (citing Fed.R.Civ.P. 11 Advisory Committee Notes (1993 Amendment))). “The amended rule recognizes, however, that ‘under unusual circumstances deterrence may be ineffective unless the sanction not only requires the person violating the rule to make a monetary payment, but also directs that some or all of this payment be made to those injured by the violation.'” Id. (quoting Fed.R.Civ.P. 11 Advisory Committee Notes (1993 Amendment)). In addition, a variety of possible sanctions are available under Rule 11, including, but not limited to, “requiring participation in seminars or other education programs; ordering a fine payable to the is designed only “to prevent [the sanctions request] from being tacked onto or buried in motions on the merits, such as motions to dismiss or for summary judgment.” Ridder, 109 F.3d at 294 n.7. The City's request for referral and disbarment are merely the sanctions sought for Plaintiffs' alleged Rule 11 violations. As indicated above, a “variety of possible sanctions” may be imposed for a Rule 11 violation, including those requested by the City. In the Sixth Circuit, the test for imposing Rule 11 sanctions is “whether the individual's conduct was objectively reasonable under the circumstances.” Nieves v. City of Cleveland, 153 Fed.Appx. 349, 352 (6th Cir. 2005) (citing Jackson v. Law Firm of O'Hara, Ruberg, Osborne & Taylor, 875 F.2d 1224, 1229 (6th Cir. 1989)). To determine objective reasonableness, the court must ask “whether the position advanced by a party was supported by a reasonable inquiry into the applicable law and relevant facts.” Advo Sys., Inc. v. Walters, 110 F.R.D. 426, 430 (E.D. Mich. 1986) (citations omitted). Whether a “reasonable inquiry” was conducted “is judged by objective norms of what reasonable attorneys would have done.” In re Big Rapids Mall Assoc., 98 F.3d 926, 930 (6th Cir. 1996). “Courts must not ‘use the wisdom of hindsight,' but must instead test what was reasonable to believe at the time the pleading, 10