King v. Whitmer CIVIL 20-13134 (E.D. Mich. Aug. 25, 2021) violated by a restriction on that expression.”77 Id. at 719. 77 The Court drew Plaintiffs' counsel's attention to Mezibov at the motion hearing in response to their repeated refrain that the First Amendment protects them from any sanctions for their conduct in this litigation. Despite doing so and urging counsel to review the Sixth Circuit's decision (see ECF No. 157 at Pg ID 5497), Junttila continued to argue First Amendment protection in her supplemental brief-albeit in a more illogical and incoherent fashion. (ECF No. 165 at Pg ID 6563-64). Third, the Court finds an improper purpose because Plaintiffs' counsel failed to conduct the pre-filing reasonable inquiry required of them as officers of the court, despite most of the attorneys acknowledging that “no one is immune to confirmation bias” and, therefore, “attorneys should look beyond their prejudices and political beliefs, and view evidence with a level of professional skepticism.” (Supp. Br. Filed by Campbell, ECF No. 161 at Pg ID 5818.) Plaintiffs' attorneys attempt to excuse their failure to objectively evaluate their “evidence” because “[they] are not the only individuals who viewed the[] affidavits [attached to their pleadings] as evidence of serious fraud.” (Id. at Pg ID 5817.) They say Former President Trump “susp[ected]” it too (id. at Pg ID 5817-18), and “millions of [] Americans . . . believed that their president would not intentionally mislead them” (id. at Pg ID 5817). As officers of the court, Plaintiffs' counsel had an obligation to do more than repeat opinions and beliefs, even if shared by millions. Something does not become plausible simply because it is repeated many times by many people.78 78 This is a lesson that some of the darkest periods of history have taught us. Counsel's failure to “look beyond their prejudices and political beliefs” during this litigation and before filing this lawsuit strongly suggests improper motive. The evidence of bad faith and improper motive becomes undeniably clear when paired with the fact that Plaintiffs' counsel violated Rule 11 in a multitude of ways. See supra. In other words, by failing to take the basic pre-filing steps that any reasonable attorney would have taken and by flouting well-established pleading standards-all while knowing the risk associated with failing to remain professionally skeptical, Plaintiffs' counsel did everything in their power to ensure that their bias-that the election was fraudulent, as proclaimed by Former President Trump-was confirmed. Confirmation bias notwithstanding, Plaintiffs' counsel advanced this lawsuit for an improper purpose and will be held to account for their actions. Fourth, circumstances suggest that this lawsuit was not about vindicating rights in the wake of alleged election fraud. Instead, it was about ensuring that a preferred political candidate remained in the presidential seat despite the decision of the nation's voters to unseat him. Before the 2020 general election, Powell appears to have been certain that those who did not support Former President Trump already engaged in fraudulent illegal activity. On Election Day, Powell gave an interview during which she described “the many multifaceted efforts the democrats are making to steal the vote, ” including “develop[ing] a computer system to alter votes electronically, ” spreading the “COVID . . . apocalypse hoax, ” and ensuring that “people . . . have not gotten their absentee ballots” even though “they've . . . request[ed] them three different times[] and been told they were cancelled.” (See, e.g., Interview Tr., U.S. Dominion, Inc. v. Powell, No. 21-cv-00040 (D.D.C. filed Jan. 8, 2021), ECF No. 120 at ¶ 2:13-24.) Why would someone, who believes that election fraud is already happening and will likely reach peak levels on Election Day, not raise the alarm with the entity the individual claims can fix things-specifically, the judiciary? It is because Plaintiffs' counsel was equally certain-even before the polls closed-that Former President Trump was 40