King v. Whitmer CIVIL 20-13134 (E.D. Mich. Aug. 25, 2021) he was identified as co-counsel for Plaintiffs, and as a result, shares the responsibility with the other lawyers for any sanctionable conduct. 3. Emily Newman & Gregory Rohl Newman contends that she had a limited role in this lawsuit, having “not play[ed] a role in drafting the complaint” and spending “maybe five hours on [the matter]” “from home.” (ECF No. 157 at Pg. ID 5317-18, 5324.) Therefore, Newman argues, she should not be subject to sanctions. By placing her name on the initial and amended complaints, Newman presented pleadings to the Court asserting that Defendants committed constitutional and state law violations. Newman does not suggest that her name was included without her permission. In addition, Newman does not cite case law suggesting that an attorney may not be sanctioned under Rule 11 or any other source of sanctions authority if the time spent on the relevant lawsuit does not surpass an unidentified threshold. (See generally ECF No. 168.) And Newman's responsibility for any Rule 11 violation is not diminished based on where those working hours were spent (particularly during a global pandemic when many individuals were working remotely from home). See Fed.R.Civ.P. 11 Advisory Committee Notes (1993 Amendment) (“[S]anction[s] should be imposed on the persons-whether attorneys, law firms, or parties-who have violated the rule or who may be determined to be responsible for the violation.... The revision permits the court to consider whether other attorneys in [a] firm, co-counsel, other law firms, or the party itself should be held accountable for their part in causing a violation, ” even if they were not “the person actually making the presentation to the court.”); see Morris, 2007 WL 2126344, at *9. So long as the attorney bears some responsibility, the attorney may be sanctioned. Fed.R.Civ.P. 11(c)(1). In an affidavit filed in this case, Rohl stated that at “approximately 6:30 PM” on the day this lawsuit was filed, he “was contacted by an associate who asked Rohl if he would assist in litigation involving alleged election fraud in Michigan.” (ECF No. 111-1 at Pg ID 4597.) He thereafter received a copy of “the already prepared” 830page initial complaint and Rohl “took well over an hour” to review it. (Id.) “[M]aking no additions, deletions or corrections” to the Complaint (id. at Pg ID 4598), Rohl had his secretary file it at 11:48 p.m. (Id. at Pg ID 4597; ECF No. 1.) To the extent Rohl asserts he should not be sanctioned because he read the pleading only on the day of its filing, the argument does not fly. Rule 11(b) “obviously require[s] that a pleading, written motion, or other paper be read before it is filed or submitted to the court, ” Fed.R.Civ.P. 11 Advisory Committee Notes (1993 Amendment), and the Court finds it exceedingly difficult to believe that Rohl read an 830-page complaint in just “well over an hour” on the day he filed it. So, Rohl's argument in and of itself reveals sanctionable conduct. Rule 11(b) also explains that, by presenting a pleading to the court, an attorney certifies that “to the best of the person's knowledge, information, and belief, formed after a reasonable inquiry under the circumstances, ” the complaint is not being filed for an improper purpose and is well-grounded in law and fact. Fed.R.Civ.P. 11(b) (emphasis added). The Court finds it even more difficult to believe that any inquiry Rohl may have conducted between the time he finished reading the Complaint and 11:48 p.m. could be described as a “reasonable” one. But also, Rohl cannot hide behind his co-counsel. As a signer of the complaints, Rohl certified to the Court that the claims asserted were not frivolous. Moreover, because his co-counsel were not admitted to practice in the Eastern District of Michigan, the complaints could not have been filed without Rohl's signature. See E.D. Mich. LR 83.20(f)(1), (i)(1)(D)(i). Therefore, to the extent Rohl contends that he was only helping cocounsel, he still failed to fulfill his obligations as an officer of the court. 4. Safe Harbor Requirement 15