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A Rule 11 Agreement must be in writing, signed, and filed with the court in order to be enforceable. It is better to respond to discovery late than not at all. You should respond to the discovery as soon as possible. You may file a motion to ask the court to push back the discovery due date.
Rule 11 has a safe harbor that allows the opposing party to withdraw an offending pleading within 21 days after he is served with the motion for sanctions. Many sanctions motions are denied because the party seeking sanctions writes a letter to the opponent, but does not actually serve a motion for sanctions.
Rule 11 is intended to make sure that when an attorney or a party submits a legal document to the Court in a civil litigation, he believes in good-faith that the document is truthful, supported by the law, and is being submitted for an appropriate purpose.
Under new Rule 91a, a party may move to dismiss a cause of action that has no basis in law or fact. A claim has no basis in law if the allegations, taken as true, together with any reasonable inferences, do not entitle the claimant to relief. A claim has no basis in fact if no reasonable person could believe the
Rule 11 states that a lawyer should not file papers in court that are not well-grounded in fact. Cheeseman's Rule 11 motion argued in essence that the plaintiff's lawsuit lacked factual support and that an adequate pre-suit investigation would have revealed that.