Laura K. Davis, et al. - Page 33

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               In pertinent part, Rule 33(b) provides:                                
                    (b) Effect of Signature:  The signature of counsel                
               * * * constitutes a certificate by the signer that the                 
               signer has read the pleading; that, to the best of the                 
               signer's knowledge, information, and belief formed                     
               after reasonable inquiry, it is well grounded in fact                  
               and is warranted by existing law or a good faith                       
               argument for the extension, modification, or reversal                  
               of existing law; and that it is not interposed for any                 
               improper purpose, such as to harass or to cause                        
               unnecessary delay or needless increase in the cost of                  
               litigation. * * * If a pleading is signed in violation                 
               of this Rule, the Court, upon motion or upon its own                   
               initiative, may impose upon the person who signed it *                 
               * * an appropriate sanction, which may include an order                
               to pay to the other party or parties the amount of the                 
               reasonable expenses incurred because of the filing of                  
               the pleading, including reasonable counsel’s fees.                     
          The effect of a signature on a motion is the same as the effect             
          of a signature on a pleading.  Rule 50(a).                                  
               In pertinent part, Model Rules 3.1 states:  “A lawyer shall            
          not bring or defend a proceeding, or assert or controvert an                
          issue therein, unless there is a basis in law and fact for doing            
          so that is not frivolous, which includes a good faith argument              
          for an extension, modification or reversal of existing law.”                
               Mr. Jones has signed pleadings and other papers to bring and           
          defend these proceedings knowing petitioners’ claims to be                  
          meritless.8  He has done so in violation of our rules and the               

          applicable rules.                                                           
               8  The pleadings and papers we have in mind are the                    
          petitions, motions for leave to amend petition, amended                     
          petitions, and objections to the motions for summary judgment.              

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