Palintiff's Notice of Motion and Motion for Sanctions addresses pleadings made in violation of statutes with regard to the attorneys certification to the court.

In this instance the defendant had made contradictory assertions within the same document, claimed insufficient information to answer allegations regarding defendant's own actions, and asserted frivolous defenses.

The Notice of Motion and Motion was used to compel the defense to withdraw the violating assertions so as to establish specific elements of plaintiff's claims on the record.