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In conducting a review of the district court's factual findings in support of the sanctions, a court 'would be justified in concluding that [the court] had abused its discretion in making [the findings] only if [they] were clearly erroneous.' Id. at 386, 110 S.Ct. 2447. The district court's legal findings must be affirmed unless they result from a 'materially incorrect view of the relevant law.' Id. at 402, 110 S.Ct. 2447.


An attorney has a duty prior to filing a complaint not only to conduct a reasonable factual investigation, but also to perform adequate legal research that confirms whether the theoretical underpinnings of the complaint are 'warranted by existing law or a good faith argument for an extension, modification or reversal of existing law.' Golden Eagle Distrib. Corp. v. Burroughs Corp., 801 F.2d 1531, 1537 (9th Cir.1986). One of the fundamental purposes of Rule 11 is to 'reduce frivolous claims, defenses or motions and to deter costly meritless maneuvers, ... [thereby] avoid[ing] delay and unnecessary expense in litigation.' Id. at 1536 (internal quotation marks and citations omitted). Nonetheless, a finding of significant delay or expense is not required under Rule 11. Where the complaint is ...

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