Hill v. Oklahoma County Criminal Justice Auth. (May 21, 2026)

Case details
Full caption
DALTON GAGE HILL v. OKLAHOMA COUNTY CRIMINAL JUSTICE AUTHORITY
Country
United States
Jurisdiction
Federal
Decided
May 21, 2026
Majority
Suzanne Mitchell (J.) (unanimous Court)
DALTON GAGE HILL, Administrator and Personal Representative..., Slip Copy (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.12026 WL 1429765Only the Westlaw citation is currently available.United States District Court, W.D. Oklahoma.DALTON GAGE HILL, Administratorand Personal Representative of the Estateof Jeffery Allen Hill, Deceased, Plaintiff,v.OKLAHOMA COUNTY CRIMINALJUSTICE AUTHORITY et al., Defendants.Case No. CIV-24-1298-D|Filed 05/21/2026REPORT AND RECOMMENDATIONSUZANNE MITCHELL UNITED STATES MAGISTRATEJUDGE*1 Before the Court are Defendants Dr. Mark Winchesterand Terry Deason, DDS's (Defendants) motions forimposition of civil contempt sanctions, Doc. 158, and Rule11 sanctions against Plaintiff's counsel, Doc. 166. PlaintiffDalton Gage Hill has responded to Defendants' motion forcivil contempt sanctions, Doc. 161, and Defendants replied,Doc. 162. And the time for Plaintiff to respond to Defendants'motion for Rule 11 sanctions has expired. See LCvR 7.1(g).So, both motions, Docs. 158 & 166, are ripe for ruling.1For the reasons set forth below, the undersigned recommendsmoving forward with contempt proceedings against Plaintiff'scounsel, Michael D. McBride, and granting Defendants'motion for Rule 11 sanctions, Doc 166, in part.2I. Discussion.A. Procedure for contempt sanctions.“There can be no question that courts have inherent powerto enforce compliance with their lawful orders through civilcontempt.” Shillitani v. United States, 384 U.S. 364, 370(1966). Similarly, a “court's interest in ensuring a party'scompliance with its orders is a great one, enforceable by finesor imprisonment.” Ohlander v. Larson, 114 F.3d 1531, 1541(10th Cir. 1997) (citation omitted).In a matter referred to a magistrate judge under 28 U.S.C.636(b) in which the magistrate judge believes an act of civilcontempt has been committed:the magistrate judge shall forthwith certify the facts to adistrict judge and may serve or cause to be served, upon anyperson whose behavior is brought into question under thisparagraph, an order requiring such person to appear beforea district judge upon a day certain to show cause why thatperson should not be adjudged in contempt by reason of thefacts so certified. The district judge shall thereupon hearthe evidence as to the act or conduct complained of and, ifit is such as to warrant punishment, punish such person inthe same manner and to the same extent as for a contemptcommitted before a district judge.28 U.S.C.A. § 636(e)(6)(B)(iii). In certifying the facts underSection 636(e), the magistrate judge's role is “to determinewhether the moving party can adduce sufficient evidence toestablish a prima facie case of contempt.” Bowens v. Atl.Maint. Corp., 546 F. Supp. 2d 55, 71 (E.D.N.Y. 2008). “Ifthe [magistrate judge] finds [the nonmovant's] explanationto be satisfactory, she may choose not to certify the matterfor further proceedings ... On the other hand, should the[magistrate judge] not be satisfied with [the nonmovant's]explanation, she cannot adjudicate the matter herself, but mustfollow the certification process of § 636(e).” In re Kitterman,696 F. Supp. 1366, 1370 (D. Nev. 1988); see also Bowens,546 F. Supp. 2d at 71 (“[T]he magistrate judge may conducta hearing, but the magistrate judge functions only to certifythe facts and not to issue any order of contempt.”) (internalquotation and citations omitted).*2 Upon certification of the facts supporting a findingof contempt, a district court must first hold an evidentiaryhearing to make de novo factual determinations, includingrelevant credibility determinations, before it can imposecontempt sanctions. See Bowens, 546 F. Supp. 2d at 71 (citingTaberer v. Armstrong World Indus., Inc., 954 F.2d 888, 907-08(3d Cir. 1992)).1. Defendants' burden.In a motion for civil contempt, the moving party—here,Defendants—has the “burden of proving, by clear andconvincing evidence, that a valid court order existed, that[counsel] had knowledge of the order, and that [counsel]disobeyed the order.” United States v. Ford, 514 F.3d 1047,
DALTON GAGE HILL, Administrator and Personal Representative..., Slip Copy (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.21051 (10th Cir. 2008) (citation omitted). The first and secondrequirements do not appear disputed: Mr. McBride recognizesthat the Court ordered him to pay reasonable attorneys' fees toDefendants Deason, Winchester, and Bradley Logan, see Doc.143, at 3. He paid Defendant Logan's attorney's fees, see Doc.161, at 4, without issue. So, he neither disputes the validityof the Court's order nor contends he lacked knowledge of theCourt's order. The issue therefore is whether Mr. McBridehas complied with this Court's orders. And the undersigneddetermines he has not.2. Certification of facts.I hereby find and certify the following facts material to theissue of contempt:Judge Timothy D. DeGiusti referred the matter to theundersigned pursuant to 28 U.S.C. § 636(b)(1)(B)-(C). Doc.58. Defendants Deason and Winchester seek $875.00 inattorneys' fees incurred for attending the Court's September3, 2025 show cause hearing. Doc. 158, at 2 n.1. Andthese Defendants now seek contempt sanctions against Mr.McBride. See generally Doc. 158.1. On July 29, 2025, the Court ordered Plaintiff and hiscounsel, Mr. McBride to appear before the Court to showcause as to why sanctions should not be imposed under Rule11 and the Court's inherent authority for citing fictitious casesin his response to Defendant Logan's motion to dismiss. SeeDoc. 126.2. On September 5, 2025, the undersigned recommended Mr.McBride pay Defendants' reasonable attorneys' fees and costsincurred for attending the Court's show cause hearing. Doc.134.33. On December 4, 2025, Judge DeGiusti adopted the Reportand Recommendation. Doc. 143. Judge DeGiusti also orderedMr. McBride to “disclose in all future pleadings whethergenerative AI was used, the specific AI tool that was used, and[to] certify in the document that he ... checked the accuracyof any portion of the document drafted by generative AI,including all citations and legal authority.” Id. at 3.4. On March 3, 2026, the Court ordered the parties to meet andconfer and reach an agreement on the amount of attorney feesowed, given an ongoing dispute between counsel McBrideand Defendants. See Doc. 156; Doc. 158, at 3. The Courtadvised Defendants that they must file an appropriate motionno later than March 17, 2026, if an agreement was notreached. Doc. 156.5. On March 17, 2026, Defendants filed the present contemptmotion. Doc. 158.3. Violations of the Court's Order.*3 Defendants Deason and Winchester must show by clearand convincing evidence that Mr. McBride disobeyed a courtorder. Defendants contend Mr. McBride violated the Court'sDecember 4, 2025 order, Doc. 143. In response, Mr. McBrideasserts that Defendants violated the December 4, 2025 orderas they refused “to negotiate the order for ‘reasonable attorneyfees.’ ” Doc. 161, at 4.4 The Court's March 3, 2026 orderdirecting the parties to meet and confer regarding the attorneyfees and to attempt to reach an agreement, see Doc. 156,suggests the possibility of negotiating the amount of feesowed. And Mr. McBride met and conferred with Defendantsas ordered. See Doc. 158, at 3.But the December 4, 2025 order does not give Mr. McBridethe option of simply refusing to pay Defendants' attorneys'fees. See Doc. 143, at 3 (“Mr. McBride ... shall payDefendants' reasonable attorneys' fees and costs incurred forattending the hearing) (emphasis added). And “[w]hile ‘[t]hefailure to meet the strict requirements of an order does notnecessarily subject a party to a holding of contempt,' civilcontempt ‘includes failures in meaningful respects to achievesubstantial and diligent compliance.’ ” Casale v. Kelly, 710 F.Supp. 2d 347, 359 (S.D.N.Y. 2010) (quoting Aspira v. Bd. ofEduc., 423 F. Supp. 647, 649 (S.D.N.Y. 1976)). “ ‘Reasonablediligence, at the very least, requires a party to develop andexecute reasonable methods of compliance’ ” and “ ‘[i]t neednot be established that the violation was willful.’ ” Id.Three months passed before Defendants filed their motion forcontempt sanctions. And Mr. McBride had the opportunityto explain to the Court why he considers the attorneys'fees Defendants incurred unreasonable in his response toDefendants' motion. But he did not. Nor has he indicatedwhat fees would be reasonable. Instead, it appears that Mr.McBride simply refuses to pay Defendants any attorneys'fees. So, the undersigned does not find Mr. McBride's conductto be demonstrative of reasonable diligence to comply withthe Court's December 4, 2025 order.
DALTON GAGE HILL, Administrator and Personal Representative..., Slip Copy (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.3Even if the Court were to find Mr. McBride's conductregarding the attorney's fees issue to be non-contemptuous,the Court finds an additional basis for finding Mr. McBridein contempt—his ongoing noncompliance with the artificialintelligence disclosure requirement. See Doc. 162, at 1-2.Defendants note that Plaintiff's response fails to “contain thecertification required by the Sanctions Order.” Id. at 1. Andthe undersigned identifies the following erroneous citationsin Petitioner's response:(1) Plaintiff quotes Dodd Ins. Servs., Inc. v. Royal Ins.Co. of Am., 935 F.2d 1152 (10th Cir. 1991) for theproposition that “Rule 11 should not be used as alitigation tactic or to chill zealous advocacy.” Doc. 161,at 2-3. This sentence is nowhere to be found in the TenthCircuit's opinion.(2) Plaintiff next cites Cooter & Gell v. Hartmarx Corp.,496 U.S. 384, 393 (1990), for the proposition that“Courts are especially cautious to prevent misuse ofsanctions in civil rights litigation.” Doc. 161, at 6. AsDefendants note, Doc. 162, at 3, Cooter is an antitrustcase. And although the provided pincite discusses thepurposes behind Rule 11, it does not support thisheightened Rule 11 sanctions standard for civil rightscases.*4 Perhaps Mr. McBride simply did not read the citedauthorities closely,5 but even if the Court were to granthim that, the Court's generative AI disclosure requirementwas designed to prevent the present issue from becominga recurring issue. But Mr. McBride has made no effortto comply with the requirement in his subsequent filings.For example, the Court struck Plaintiff's second amendedcomplaint, in part, for his failure to include the required AIdisclosure. See Doc. 165; Doc. 164. And his response toDefendants' contempt motion also includes no AI disclosure.See Doc. 161. This repeated failure to follow the Court'sorder supports a finding of contempt as the Court's priorsanctions have not sufficiently deterred counsel's conduct.See O'Connor v. Midwest Pipe Fabrications, Inc., 972 F.2d1204, 1211 (10th Cir. 1992) (“Sanctions for civil contemptmay only be employed for either or both of two distinctremedial purposes: ‘(1) to compel or coerce obedience toa court order ...; and (2) to compensate the contemnor'sadversary for injuries resulting from the contemnor'snoncompliance[.]’ ” (quoting Shuffler v. Heritage Bank, 720F.2d 1141, 1147 (9th Cir. 1983))).B. Rule 11 standard.Rule 11(b) of the Federal Rules of Civil Procedure provides:By presenting to the court a pleading, written motion, orother paper— whether by signing, filing, submitting, orlater advocating it—an attorney or unrepresented partycertifies that to the best of the person's knowledge,information, and belief, formed after an inquiry reasonableunder the circumstances:...(3) the factual contentions have evidentiary support or,if specifically so identified, will likely have evidentiarysupport after a reasonable opportunity for furtherinvestigation or discovery[.]“Rule 11 establishes a standard of objective reasonableness”and “[t]he test for imposition of Rule 11 sanctions is whethercounsel's conduct was reasonable under the circumstancesof the case.” Est. of Strong v. City of Northglenn, 2018 WL6589813, at *2 (D. Colo. Dec. 14, 2018), adopted, No. 17-cv-1276-WJM-SKC, Doc. 108 (D. Colo. Jan. 14, 2019). “Itdoes not require a finding of subjective bad faith on the partof the offending attorney.” Id.1. Complained-of conduct.The gist of Defendants' Rule 11 motion is that Mr. McBrideviolated Rule 11 by filing “several false statements of factwhich could or should have been discovered through theexercise of ordinary diligence upon a cursory review ofavailable medical records.” Doc. 166, at 2.6 Specifically,Defendants take issue with allegations in Plaintiff's amendedcomplaint that the decedent's (Jefferey Allen Hill) penicillinallergy was recorded in his medical file. Id. at 5.7 And thatDefendant Deason was aware of Mr. Hill's dental infectionand examined him at SSM but failed to remove Mr. Hill'sinfected tooth and “knowingly disregard[ed] the excessiverisk an infected tooth can and did pose.” Doc. 53, at 7; Doc.166, at 7-9.*5 Both allegations are crucial components of Plaintiff'sdeliberate indifference claim against Defendants. ForDefendant Winchester, Plaintiff alleges that the prescriptionof penicillin in contravention of Mr. Hill's recorded allergy is“additional evidence that Mr. Hill was not receiving propermedication at the Jail, in reckless and deliberate indifferenceto his known, obvious and substantial medical needs.” Doc.
DALTON GAGE HILL, Administrator and Personal Representative..., Slip Copy (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.453, at 8. And that Defendant Deason's failure to remove theinfected tooth led to Mr. Hill dying from “sepsis due to aninfected tooth.” Id. at 11.Defendants point to Mr. Hill's medical records, attached toDefendant Winchester's answer to the amended complaint, asproof that Mr. McBride was aware that Mr. Hill's penicillinallergy was not recorded in his medical file when he filedthe amended complaint against Defendants. Doc. 166, at 5;Doc. 128, Ex. 1. The medical records state that “previously[Mr. Hill] listed that he had [no known drug allergies] perhis history and medical records available” and that Mr. Hill“had [a] severe allergic reaction after being given penicillinPO on 1/22/2024.” Doc. 128, Ex. 1, at 1; see also id. at 2-6.Defendants also maintain that “[t]here is no documentationin [Turn Key Health's] records of [Defendant] Deason everseeing [Mr.] Hill at the Oklahoma County Detention Centeror at SSM Health.” Doc. 166, at 8.Rule 11 imposes a duty of candor, which the violation ofwarrants “sanctions for continuing to advocate a positionafter learning that it ceases to have merit or is no longertenable.” Est. of Strong, 2018 WL 6589813, at *2. WhileMr. McBride did not respond to Defendants' Rule 11 motion,Defendants note that on February 5, 2026, Mr. McBrideinformed Defendants' counsel that he had not received theSSM health records. Doc. 166, Ex. 3. And Turn Key's medicalrecords show that on January 25, 2024, a “dental sick call”requested by Mr. Hill was held and Defendant Deason notesin the call record that Mr. Hill complained of “pain in backright wisdom tooth,” and “reports it's ‘sawn in half.’’ Doc.166, Ex. 1, at 9. And the same call notes state that Mr. Hill hada “severe reaction to penicillin” and “had to be hospitalizedand while there, had his wisdom tooth removed.” Id. So,the documentation available to Mr. McBride does showat least some interaction between Mr. Hill and DefendantDeason, and that Defendant Deason had knowledge of theongoing medical issues regarding Mr. Hill's infected tooth.The undersigned finds Defendants have not met their burdenof showing that Mr. McBride violated his duty of candor tothe Court regarding his allegations toward Defendant Deason.On the other hand, the lack of apparent evidentiary supportfor Plaintiff's contention that Mr. Hill's penicillin allergywas recorded in his medical file is more troubling. Mr.McBride has had access to the medical records since August6, 2025, when Defendant Winchester answered the amendedcomplaint, see Doc. 128.8 And the attached medical recordsrepeatedly state that Mr. Hill had no known drug allergies.Doc. 128, Ex. 1. Mr. McBride did not seek leave to amendthe complaint to remove this allegation after DefendantWinchester's answer was filed. Instead, Mr. McBride movedfor leave to file a second amended complaint, stating: “Mr.Hill is allergic to penicillin and this allergy is noted in hismedical file.” Doc. 7, Att. 1, at 7.*6 Rule 11 instructs attorneys “to ‘stop, look, and listenbefore signing a document subject to Rule 11.’ ” McNealv. Zobrist, 2006 WL 2692816, at *10 (quoting Adamson v.Bowen, 855 F.2d 668, 673 (10th Cir. 1988)) (emphasis addedby McNeal). And Mr. McBride ultimately failed to do so.So, “sanctions are necessary to deter future similar conduct.”Id. (finding Rule 11 sanctions warranted when “plaintiff'scounsel was made aware of evidence ... flatly contradict[ing]material averments in the Third Amended Complaint [and]did not correct any of her filings with the Court”).2. Requested sanctions.Defendants urge the Court to:(1) Strike the false allegations in Plaintiff's amendedcomplaint;(2) Permit them to re-urge their respective motions todismiss; and(3) Enter an order directing Mr. McBride to payDefendants' reasonable attorneys' fees incurred from theinception of the case.Doc. 166, at 12.“[I]n determining whether (and what) sanctions areappropriate, a court should consider: ‘(1) the degree of actualprejudice to the [D]efendant[s]; (2) the amount of interferencewith the judicial process; ... (3) the culpability of the litigant,'and (4) whether the court warned the party in advancethat dismissal of the action would be a likely sanction fornoncompliance.’ ” Grady v. Broderson, 2015 WL 1384371, at*4 (D. Colo. Mar. 23, 2015) (quoting Ehrenhaus v. Reynolds,965 F.2d 916, 920 (10th Cir. 1992)). “Before a court ordersdispositive sanctions, it should also consider the efficacy oflesser sanctions.” Id.The undersigned finds it currently unnecessary to strikePlaintiff's allegation that Mr. Hill's penicillin allergy wasrecorded in his medical file. Likewise, Defendants' requestto re-urge their respective motions to dismiss should also
DALTON GAGE HILL, Administrator and Personal Representative..., Slip Copy (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.5be denied. Discovery has not yet closed, and the deadlineto file dispositive motions has also not passed. See Doc.155, at 2. Defendant Winchester may address any lack ofevidentiary support for the allegations regarding Plaintiff'sdeliberate indifference claim against him at the summaryjudgment stage.And Defendants request for Mr. McBride to pay theirattorneys' fees incurred since the inception of the case isexcessive. “Rule 11 is not intended to function as a fee-shifting provision or to reward parties who are victimized bylitigation.” Est. of Strong, 2018 WL 6589813, at *2.Nonetheless, the undersigned finds that some monetarysanctions are appropriate here, given the costs of litigating theRule 11 motion and counsel McBride's conduct. DefendantWinchester was prejudiced by having to move forward withthis motion to address the apparent lack of evidentiary supportfor one of Plaintiff's crucial allegations against him. AndMr. McBride's failure to reasonably investigate and correctthe amended complaint interfered with the judicial processas the Court had to devote time and judicial resources inadjudicating Defendants' Rule 11 motion.As for the culpability of the litigant, Mr. McBride wasnotified on January 30, 2026, by Defendants' counsel's letter,Doc. 161, Ex. 1, at 2, that the medical records contradictedPlaintiff's claims towards Defendants. Mr. McBride has alsohad the Turn Key records since August 2025. Yet, Mr.McBride made no effort to amend his pleading or to evenrespond to the allegations in Defendants' Rule 11 motion.In short, three of the Ehrenhaus weigh in favor of issuingsanctions under Rule 11.As to the fourth Ehrenhaus factor, Mr. McBride was notwarned that dismissal was a possible sanction. But theundersigned does not find dismissal to be an appropriatesanction, and lesser sanctions are appropriate here. Grady,2015 WL 1384371, at *4.*7 The undersigned recommends the Court order Mr.McBride to pay Defendant Winchester's attorneys' feesincurred for the costs of litigating the Rule 11 motion.II. Recommendation and notice of right to object.The undersigned certifies the above facts and recommendsthat the Court move forward with finding Mr. McBride incontempt of the Court's order, Doc. 143. The undersignedrecommends granting Defendants' motion for Rule 11sanctions, Doc. 166, in part, and order Mr. McBride to payDefendant Winchester's reasonable attorney fees incurred forthe filing of the Rule 11 motion.9The undersigned advises Plaintiff and his counsel, Mr.McBride, of their right to object to this Report andRecommendation. See 28 U.S.C. § 636(b)(1) and Fed. R. Civ.P. 72(b)(2). Any such objection must be filed with the Clerk ofthe Court on or before June 11, 2026. Plaintiff and his counselare further advised that failure to make timely objection to thisReport and Recommendation waives their right to appellatereview of the factual and legal issues addressed herein. Moorev. United States, 950 F.2d 656, 659 (10th Cir. 1991).This Report and Recommendation does not dispose of allissues and does not terminate the referral to the undersignedMagistrate Judge in the captioned matter.ENTERED this 21st day of May, 2026.All CitationsSlip Copy, 2026 WL 1429765Footnotes1Given the overlapping factual allegations in Defendants' motions regarding Plaintiff's counsel's conduct, the undersignedfinds it appropriate to address both of Defendants' motions in one Report and Recommendation for judicial efficiency.2Plaintiff also failed to respond to Defendants' Rule 11 motion. So, it is deemed confessed. See LCvR 7.1(g) (“Any motionthat is not opposed within 21 days may, in the discretion of the court, be deemed confessed.”). Nonetheless, out of anabundance of caution, the undersigned will address the merits of Defendants' motion to determine whether sanctions arewarranted. See Talece Inc. v. Zhang, 2021 WL 242913, at *2 (N.D. Cal. Jan. 25, 2021) (“ ‘Rule 11 is an extraordinaryremedy, one to be exercised with extreme caution.’ ” (quoting Operating Eng'rs Pension Trust v. A-C Co., 859 F.2d 1336,1345 (9th Cir. 1988))).
DALTON GAGE HILL, Administrator and Personal Representative..., Slip Copy (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.63For a summary of the pattern of conduct by Mr. McBride that resulted in the September 2025 show cause hearing, seethe undersigned's prior Report and Recommendation on the issue, Doc. 134.4In his response, Plaintiff suggests Defendants' counsel has conducted himself improperly and moves for Rule 11sanctions against Defendant's counsel. See Doc. 161, at 7-9. As Defendants note, Doc. 162, at 6, Plaintiff's request forRule 11 sanctions in a responsive pleading violates LCvR 7.1(c), and is therefore, improperly raised. LCvR 7.1(c)(“Aresponse to a motion may not also include a motion or a cross-motion made by the responding party.”). So, the Courtdoes not address Plaintiff's request any further.5Defendants' counsel states he ran Mr. McBride's response through an AI text detection program. See Doc. 162, at 3 n.2(citing Ex. 1). The undersigned makes no findings as to the veracity of the tool used by Defendants' counsel.6Rule 11 imposes certain procedural requirements on parties seeking sanctions. A party must submit the motion forsanctions separately from other motions or requests and specifically describe the conduct that allegedly violates Rule11(b). The party must serve the motion on the opposing party. If, after 21 days, the offending party does not withdraw thechallenged conduct, the party seeking sanctions may file its motion for sanctions with the court. See Fed. R. Civ. P. 11(c)(2). In his response to Defendants' contempt motion, Doc. 161, Mr. McBride suggests that Defendants' motion “ignoresRule 11 procedural requirements.” Id. at 6. Setting aside that Mr. McBride was responding to a contempt motion, theundersigned finds Defendants satisfied Rule 11's procedural requirements. On January 30, 2026, Defendants' counselsent a letter to Mr. McBride with the Rule 11 motion enclosed therein. Doc. 161, Ex. 1. And again, on March 20, 2026,Defendants sent a letter to Mr. McBride with the repeated Rule 11 allegations. Doc. 161, Ex. 2, at 2-3. Mr. McBridereceived these letters as he attached them to his response to the contempt motion. See Doc. 161, Exs. 1 & 2, at 2-3.The undersigned therefore finds Defendants fully complied with the procedural requirements of Rule 11 prior to filingtheir motion.7For a complete recitation of the factual allegations raised in Plaintiff's amended complaint, see the undersigned's Reportand Recommendation, denying Defendant Winchester's motion to dismiss. Doc. 155.8Defendants state, “upon information and belief, Plaintiff has possessed [the Turn Key medical records] since December10, 2024, at the latest[.]” Doc. 166, at 5 (emphasis added). Defendants have not put any documentation before the Courtsupporting their assertion that Mr. McBride has had the Turn Key medical records since December 2024.9The Court should require Defendants' counsel to submit to the Court a full accounting of their attorney's fees and costsassociated with litigating the Rule 11 motion to the Court.End of Document© 2026 Thomson Reuters. No claim to original U.S.Government Works.
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