UNITED STATES DISTRICT COURT
Plaintiffs' Motion for Rule 11 Sanctions
FOR THE DISTRICT OF COLUMBIA
William Thomas, et. al. | C.A. No. 94-2742
Plaintiffs pro se, | Judge Charles R. Richey
The United States, et. al. |
MOTION FOR RULE 11 SANCTIONS
OR OTHER DISCIPLINARY ACTION
OR, ALTERNATIVELY, TO DISMISS THIS ACTION AS FRIVOLOUS
On January 11, 1995, on behalf of the federal defendants, the U.S. Attorney's Office filed a "Motion to Dismiss all Claims Against Defendants Richard Robbins, Stephen O'Neill and Andrew Keness and all claims for Money Damages."
Upon reflection, it seems that to dignify Defendants' Motion with an Opposition might only lend credence to an otherwise incredible document.
Therefore, in the interests of truth and justice, and for the reasons more specifically set out in the accompanying Memorandum, plaintiffs hereby move the Court to Order "a reasonable inquiry" to determine whether defendants' Motion to Dismiss is "(1) ... well grounded in fact, (2) ... warranted by existing law or a good faith argument ... or (3) interposed for any improper purpose...." Westmoreland v. CBS, 770 F.2d 1168, 1174 (parentheses substituting), and, if appropriate, impose sanctions, or such disciplinary action as the Court may deem necessary to impress upon the U.S. Attorney's Office that careless misrepresentations have no place in a civilized fact-finding process
A memorandum and a Proposed Order accompany this motion.
William Thomas, pro se
2817 11th Street N.W.
Washington, D.C. 20001
CERTIFICATE OF SERVICE
I hereby state that, on January 24, 1995, I served copies of the foregoing "Motion for Rule 11 Sanctions or Other Disciplinary Action, or Alternatively to Dismiss this Action as Frivolous" upon the office of the United States Attorney for the District of Columbia at 555 4th Street NW, Washington, D.C