Cautionary Tales from the ‘Kraken’ Litigation Sanctions Ruling

by David P. Atkins and Marcy T. Stovall
Bloomberg Law

In an article authored for Bloomberg Law, Professional Liability attorneys David P. Atkins and Marcy T. Stovall discuss how Federal Rule of Civil Procedure 11 plays a role in a recent court decision that sanctioned a team of attorneys in a lawsuit challenging the 2020 election results. 

"The decision provides all lawyers with some stark and useful reminders of the important limitations Rule 11 imposes on 'zealous advocacy' even in settings other than a high profile controversy over the outcome of a national election," they write.

David and Marcy explain the three independent requirements with respect to court filings of subsection (b) of Rule 11, and how they relate to the U.S. District Court for the Eastern District of Michigan Judge Linda V. Parker case. To read the full article, please visit

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