IN THE CIRCUIT COURT OF THE XX
JUDICIAL CIRCUITIN AND FOR XXXXXXXXX COUNTY, STATENAME OF PLAINTIFF (COULD STATESOMETHING LIKE “AS INDENTURE Case No. XXXXXXXXXXXTRUSTEE FOR THE REGISTERED HOLDERS Bar No. XXXXXXXXXOF IMH ASSETS CORP. COLLATERALIZEDASSET-BACKED BONDS, SERIES 2005-3,”Plaintiff,v.
MOTION FOR SANCTIONS
NAME OF BORROWER,
PURSUANT TO FLA.STAT. sec. 57.105
Defendants. ____________________________________/[EDITOR’S NOTE. THIS IS GENERALLY NOT FILED WITH THE CLERK BUTIS SENT TO OPPOSING COUNSEL. IT IS FIELD WITH THE CLERK AND NOTICEDFOR HEARING WHEN BORROWER/DEFENDANT HAS WON THE MOTION TODISMISS OR OTHERWISE PREVAILED. IT APPLIES NOT JUST TO THE GENERALCLAIM BUT ANY PART OF ANY ALLEGATION THAT THE PLAINTIFF KNEW ORSHOULD HAVE KNOWN WAS NOT TRUE, THEREBY INVOKING THEREQUIREMENTS OF DUE DILIGENCE ON THE CLIENT, THE LAWYER WHO SIGNSTHE PLEADING, AND THE LAW FIRM THAT THE LAWYER FOR PLAINTIFF WORKSFOR]NAME OF PLAINTIFF, hereinafter Borrower, through undersigned counsel andpursuant to Fla.Stat. sec. 57.105, decisional law thereunder, and the record facts below,moves this Court to enter an Order of Sanctions against Plaintiff, and as grounds for same states:1.On or about DATE, Plaintiff, through its agent and attorney NAME OFATTORNEY WHO SIGNED PLEADING, Esq. of the Law Offices of NAME