Laura K. Davis, et al. - Page 27

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          Respondent implies that counsel filed the motions only to vex               
          respondent.  Respondent argues that the lack of citation to                 
          relevant legal authorities in the oppositions to the motions for            
          summary judgment signed by both Mr. Jones and Ms. Lacorte                   
          indicates their lack of legal research or their willful disregard           
          of adverse authority.  Respondent concludes:                                
                    Mr. Jones’ entire conduct in this case constitutes                
               bad faith, in that he knowingly or recklessly filed                    
               petitions, motions for leave to amend petitions,                       
               amended petitions, and oppositions to respondent’s                     
               summary judgment motions that raised nothing but                       
               frivolous, groundless, or statutorily precluded                        
               arguments.  Ms. Lacorte’s involvement was limited to                   
               participation in the filing of motions for leave to                    
               amend petition and oppositions to respondent’s summary                 
               judgment motions.                                                      
          Respondent claims that he incurred excessive costs of $25,800 in            
          litigating all of these cases and asks payment in that amount.              
               Alternatively, if we do not impose excess costs on Mr. Jones           
          and Ms. Lacorte under section 6673(a)(2), respondent asks that we           
          sanction both individuals under Rule 33(b), which sets standards            
          in connection with counsel’s signature on a pleading and provides           
          that counsel may be sanctioned for failure to meet those                    
               Mr. Jones and Ms. Lacorte advance as their own defense the             
          arguments made on behalf of each petitioner.  They also claim               
          errors in respondent’s calculation of his costs.  Mr. Jones                 
          states that, at all times relevant to these cases, Ms. Lacorte              
          was his employee, subject to his direction and advice, and is in            

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