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A tenant sued her landlord in federal court alleging that the landlord entered her apartment, stole jewelry, and discriminated against her based on national origin. Before filing, the tenant's lawyer interviewed the tenant, reviewed a police report saying the jewelry was missing, and found text messages from the landlord using slurs. The lawyer did not interview two neighbors who later said they saw a maintenance worker, not the landlord, entering the unit. The complaint also included a claim under a statute that had been repealed three years earlier.
The landlord immediately filed a Rule 11 sanctions motion with the court without first serving it on the tenant. The motion also seeks Rule 11 sanctions for a later request for production that the landlord says was overbroad. After receiving the motion, the tenant withdrew the repealed-statute count but maintained the theft and discrimination claims.
How should the court resolve the sanctions motion? Discuss the certification standard, legal and factual contentions, safe harbor, discovery papers, and possible sanctions.