Notice of Motion and Motion for Sanctions provided to defendant after Answer to Amended Complaint contained obviously disengunious, contradicory and frivolous assertions, defenses and counterclaims. The document provides and example of the format and applicable statutes under Wisconsin law.
This motion was used to compel defendant's counsel to withdraw the offending assertions and make a clear and accurate record before the court. The defense responded by characterizing the motion as "absurd." Nonetheless, ALL of the offending assertions were withdrawn and the Amended Answer to the Amended Complaint relected a series of admisssions that secured plaintiff's victory at trial.
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