Judge Denise Cote
Watkins represents claimants before administrative agencies. Taneja and Soleil represented him in his action charging two groups of lawyers (the Eisen Defendants and Phillips Defendants) with civil RICO violations, Sherman Antitrust Act violations, and unfair business practices. Defendants purportedly recruited Dugue to pose as a potential client, and fabricate sexual harassment claims against Watkins, in their conspiracy to extort settlements and reduce competition in Watkins’ field of work. Following extensive discussion of Federal Rule of Civil Procedure 11 and Rule 11(c)(2)’s "safe harbor" requirements, district court partly granted defendants’ Aug. 22 and Sept. 17, 2012, sanctions motions. Taneja and Soleil had to pay all the Phillips Defendants’ attorney fees in opposing Watkins’ amended complaint, and half of those costs incurred by the Eisen Defendants. Monetary sanctions could be imposed on Watkins for his filing of an amended complaint containing "factual allegations…utterly lacking in evidentiary support." However, sanctions were not imposed because the record offered little indication of Watkins’ participation in the decisions about which individuals and entities to name as defendants.
