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Served Pursuant to Fed. R. Civ. P.

11(c)(2)

UNITED STATES DISTRICT COURT


EASTERN DISTRICT OF NEW YORK

Ricardo Sibrian, individually and on behalf of


all others similarly situated,
Case No. 2:19-cv-00974-JS-GRB
Plaintiff,

v. MEMORANDUM OF LAW IN
SUPPORT OF DEFENDANT’S
Cento Fine Foods, Inc., MOTION FOR SANCTIONS UNDER
FED. R. CIV. P. 11
Defendant.

Defendant Cento Fine Foods, Inc. (“Defendant” or “Cento”) submits this Memorandum of

Law in support of its Motion for Sanctions under Rule 11 of the Federal Rules of Civil Procedure,

respectfully showing the Court as follows:

I. INTRODUCTION

Plaintiff Ricardo Sibrian, through his counsel Spencer Sheehan of Sheehan & Associates,

P.C. 1, filed this putative class action alleging that Defendant’s San Marzano Peeled Tomatoes (the

“Products”) are not certified as San Marzano tomatoes by the appropriate third party certifier and

are grown outside the proper regions in Italy that allow San Marzano status. Plaintiff’s counsel

must be sanctioned for signing and filing a baseless pleading that: (1) makes numerous factual

allegations and insinuations that have no evidentiary support; (2) asserts frivolous claims not

warranted by any existing law; and (3) fails to identify that any of those allegations will likely need

reasonable investigation or discovery to develop. Fed. R. Civ. P. 11(b)(2), (b)(3).

First, Plaintiff makes baseless and scandalous allegations in his Complaint designed to have

the Court (and any potential factfinder) believe that they serve as the basis of an investigation

1
Subsequently joined by Michael R. Reese of Reese LLP as co-counsel. Dkt. No. 5.
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conducted specifically into Defendant’s practices, when in reality they merely constitute a

mishmash of conclusory statements and innuendos about the tomato industry in general. Plaintiff

alleges that a “fraud” is perpetrated due to the “abundance of lower quality Chinese processed

tomato products imported into Italy,” claims that “[t]he Italian Mafia reaps profits by placing lesser

quality tomatoes into cans and labeling them San Marzano,” and most egregiously, relies on

graphics and quotes from a New York Times animation that clearly cannot be about, and makes

no mention of, Defendant’s products. In reality, a reasonable inquiry would have shown that none

of these spurious accusations attach to Defendant.

Second, Plaintiff’s apparent main contention—that Cento’s San Marzano Tomatoes are not

grown in the proper region in Italy and are not certified by a particular third-party, independent

certifier—is demonstrably false and not a cognizable claim under the law. To be clear, Plaintiff

does not, and cannot, allege that Defendant misleadingly represents consumers into believing that

it is certified by one organization when it is not. Instead, Plaintiff brings this frivolous lawsuit to

mistakenly allege that Defendant’s Products can’t possibly be true “San Marzano” tomatoes

because they are certified by a different certifier. Plaintiff cannot identify a single EU regulation

that Defendant has allegedly violated to support his allegations that the tomatoes in Cento cans are

not what they claim to be. Had Plaintiff performed even the most cursory investigation into his

claims, he would learn that there is more than one certifying entity with respect to San Marzano

tomato farming and production. Moreover, Plaintiff has failed to identify any facts that establish

that Defendant’s grow operation is violating any regulation promulgated by European Union or

U.S. agencies that regulate food products. Instead, he relies on bare conclusions and guesses that

were gleaned from sloppy media reporting and targeted Cento as a potential deep pocket. Such

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conduct should be admonished and Defendant should be made whole for being forced to defend

its good will amongst consumers.

Defendant presents supporting evidence establishing that Plaintiff and his counsel

conducted no meaningful investigation whatsoever before filing this lawsuit. This evidence

includes not only Cento’s authentic certification documents concerning the traceability and quality

of its Products, but an affidavit from a charter and current member of the Consortium for the

Protection of S. Marzano Pomodoro Dell’agro Sarnese Nocerino (hereinafter, the “Consortium”)

(the very body that Plaintiff claims is the only legitimate organization that can issue San Marzano

certifications) attesting to the certification and quality of Cento’s San Marzano Products –

information that Plaintiff’s counsel could have attained had he performed a reasonable inquiry.

Moreover, Plaintiff’s failure to withdraw the Complaint when faced with damning proof that his

claims must fail is defined as conduct worthy of sanctions pursuant to Rule 11.

Third, Plaintiff’s Complaint fails to qualify that key allegations require further

investigation or discovery. Plaintiff’s spurious and false background allegations and his factual

contentions concerning Defendant’s seeds and certifier are not specifically identified as needing

further evidentiary support after reasonable investigation or discovery. The only conclusion that

can be reached is that Plaintiff and his counsel performed no such reasonable inquiry, relying

solely on a news article that did not mention or address Defendant’s products, and had no

evidentiary support for their allegations at the moment their Complaint was signed and filed into

this Court.

For these reasons, explained more fully below, the Court should grant Defendant’s Motion

for Sanctions and allow reasonable sanctions, attorneys’ fees and costs in Defendant’s favor.

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II. FACTUAL BACKGROUND

A. Plaintiff’s Allegations

Plaintiff alleges that there are two types of peeled plum tomatoes from Italy: regular peeled

and regular peeled grown in the region San Marzano sul Sarno. (Dkt. No. 1, Complaint, ¶ 5).

Displaying an image of Defendant’s product, Plaintiff states, “Defendant represents its Products

as ‘Certified San Marzano Organic Peeled Tomatoes.’” (Id. ¶ 8). Plaintiff then alleges that

premium pricing for San Marzano tomatoes—which he claims is twice as much as non-San

Marzano tomatoes—causes an ongoing battle against fraudulent tomatoes. (Id. ¶ 13). Plaintiff

alleges that “[t]his fraud is abetted by the abundance of lower quality Chinese processed tomato

products imported to Italy…to use in the finished tomato products.” (Id. ¶ 14). Plaintiff states that

the head of the Consortium for the Protection of the San Marzano Tomato Dell’agro Sarnese

Nocerino estimates that only five percent of tomatoes marked as San Marzano are real San

Marzano tomatoes. (Id. ¶ 15). The article from which Plaintiff derives this statistic, id. n. 2, makes

no mention of Defendant or its products. Plaintiff then alleges that “[t]he Italian Mafia reaps

profits by placing lesser quality tomatoes into cans and labeling them San Marzano[.]” (Id. ¶ 16).

i. Frivolous reliance on a New York Times animation.

By naming the next section of his Complaint “The Mystery of San Marzano, NY Times,”

Plaintiff undoubtedly refers to the New York Times interactive animation entitled “The Mystery

of San Marzano” that is the source of Plaintiff’s Mafia allegation. (Id. ¶ 16, n.3). Plaintiff

selectively presents two slides from the animation, the second of which is named “HOW TO SPOT

A FAKE.” (Id. ¶ 17). In this “HOW TO SPOT A FAKE” slide, there are two pertinent indications

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given: “[t]he label does not say ‘Pomodoro S. Marzano dell-Agro Sarnese-Nocerino’”; and

“[m]issing the D.O.P. 2 seal and the seal of the consortium.” (Id.).

ii. Defendant not being certified by the “relevant authority.”

Plaintiff alleges that Defendant’s Cento San Marzano Organic Peeled Tomatoes are

certified by the Instituto per la Certificazione Erica e Ambientale (ICEA). (Id. ¶ 19). Plaintiff

alleges that ICEA does not certify that Defendant’s products “are compliant with the San Marzano

guidelines,” id. ¶ 20, but notably Plaintiff does not allege at any point in his Complaint what the

“San Marzano guidelines” are or how Defendant has run afoul of any such guideline. Plaintiff

alleges that Agri-Cert is a company that supplies Defendant with San Marzano seeds and possibly

certifies whether Defendant’s products are organic, “as opposed to certifying the growing and

quality of the final product.” (Id. ¶ 23). Plaintiff appears to contend that Defendant’s certifiers are

either not the appropriate certifier, or do not certify the entire finished product. (Id. ¶¶ 32, 44).

Importantly, Plaintiff does not allege that Defendant’s products are not certified by ICEA and Bio

Agri-Cert. Plaintiff also alleges that the “Find My Field” section of Defendant’s website returns

only four fields, and that it is implausible that Defendant can cultivate only four fields for all of its

San Marzano tomato products. (Id. ¶¶ 26-30).

Plaintiff alleges that he purchased Defendant’s products and paid a premium because he

“saw and relied on the misleading representations.” (Id. ¶ 59). Plaintiff does not allege what

statements he relied on in purchasing Defendant’s product. Plaintiff’s seeks to bring a nationwide

class, alleging unfair trade practice statute violations of nearly every U.S. state and the District of

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“D.O,P.” stands for Denominazione d' Origine Protetta, and refers to the Consortium from the Protection of
Pomodoro S. Marzano dell-Agro Sarnese-Nocerino, a third-party certification organization referenced in Plaintiff’s
Complaint at ¶ 15.

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Columbia. (Id. ¶ 71). Plaintiff’s additional causes of action are for negligent misrepresentation,

breach of express and implied warranties, fraud, and unjust enrichment.

B. The Reality of Cento’s San Marzano Tomato Certifications

Giuseppe Napoletano, a charter and current member of the Consortium—the certifying

entity that Plaintiff wrongly asserts is the only one that can certify San Marzano tomatoes—attests

that Defendant’s seeds are approved and certified; that its farmlands, factory, and production are

indeed located in Sarnese-Nocerino area and are certified as San Marzano compliant by a third-

party certifier; and further states that “Cento has been honorable and true to quality.” (Ciccotelli

Declaration, ¶11, Ex. B (“Napoletano Affidavit”), ¶¶ 1-3, 7).

Patrick M. Ciccotelli, the President and CEO of Cento, confirms that Agri-Cert certifies

the Products, and that this certification is recognized by the European Union for certification of

San Marzano tomatoes. (Ciccotelli Decl., ¶ 7). Mr. Ciccotelli further confirms that Cento’s

certifications are not only for the seeds, but rather constitute a complete San Marzano tomato

certification for the entire product and process, from the seeds and growing, and all the way

through and including canning. (Id.). Cento employs Italian farmers who grow exclusively in the

Sarnese Nocerino area of the Campania region of Italy (Id., ¶4). It’s production facility is also

located in the Sarnese Nocerino area. (Id.). Cento’s farming partners operate 10 to 30 fields per

growing season, depending on demand and yield conditions. (Id., ¶5). For the 2018 growing

season, 25 fields were cultivated in the Sarnese Nocerino area. (Id., ¶6).

III. MOTION FOR SANCTIONS STANDARD

Rule 11(b) provides in relevant part that, by presenting to the court a pleading, written

motion or other paper, an attorney “certifies that to the best of the person's knowledge, information,

and belief, formed after an inquiry reasonable under the circumstances,” the pleading, written

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motion or other paper is not being presented for any “improper purpose,” that the claims, defenses

and other legal contentions are “warranted by existing law or by a nonfrivolous argument for the

extension, modification of reversal of existing law or the establishment of new law[,]” and that

“the factual contentions have evidentiary support, or if specifically so identified, will likely have

evidentiary support after a reasonable opportunity for further investigation or discovery[.]” Fed.

R. Civ. P. 11(b). A violation of Rule 11 is thus triggered “when it appears that a pleading has been

interposed for any improper purpose, or where, after reasonable inquiry, a competent attorney

could not form a reasonable belief that the pleading is well grounded in fact and is warranted by

existing law or a good faith argument for the extension, modification or reversal of existing

law.” ResQNet.com, Inc. v. Lansa, Inc., 382 F. Supp. 2d 424, 452-53 (S.D.N.Y. 2005) (quoting

Eastway Constr. Corp. v. City of New York, 762 F.2d 243, 254 (2d Cir. 1985) (emphasis in

original)).

A party moving to impose Rule 11 sanctions must therefore establish “a showing of

objective unreasonableness on the part of the attorney or client signing the papers.” ATSI

Commc'ns, Inc. v. Shaar Fund, Ltd., 579 F.3d 143, 150 (2d Cir. 2009) (internal quotation marks

and citation omitted); see also Eastway Constr., 762 F.2d at 253 (observing that Rule 11

“explicitly and unambiguously imposes an affirmative duty on each attorney to conduct a

reasonable inquiry into the viability of a pleading before it is signed”). When it becomes clear that

a party (or its counsel) does not have evidentiary support for claims made in a Complaint, it is

“objectively unreasonable” for that party to refuse to withdraw its unsupported claims. Cameau

v. Nat'l Recovery Agency, Inc., No. CV 15-2861 (DRH) (AKT), 2018 U.S. Dist. LEXIS 132993,

*22 (E.D.N.Y. Aug. 6, 2018) (finding Rule 11(b)(3) violation for failure to withdraw unsupported

claims).

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IV. ARGUMENT

A review of Plaintiff’s background allegations and the accuracy of Defendant’s

certifications reveal that Plaintiff’s counsel filed this frivolous lawsuit despite performing no

reasonable pre-suit investigation whatsoever. Further, when presented with evidence that refutes

his allegations and doom the Complaint, Plaintiff has failed to withdraw the frivolous pleading.

Such conduct is ripe for Rule 11 sanctions.

A. Plaintiff’s scandalous background allegations were not reasonably


investigated and had material factual omissions, both of which violate Rule
11(b)(3).

After specifically identifying Defendant’s product label, Plaintiff first alleges a global

fraudulent tomato conspiracy wherein many tomatoes identified as San Marzano are actually part

of a Mafia-led enterprise using Chinese goods. (Complaint, ¶¶ 8-16). Of course, Plaintiff cannot

actually make any factual connection between this alleged criminal activity and Cento, but the

mere existence of these allegations in his Complaint imply that a serious investigation was

performed, and that Defendant is a culprit in this criminal enterprise. In reality, nothing can be

further from the truth. Plaintiff had no basis in which to make these allegations against Cento in

his Complaint. Because Plaintiff’s erroneous Mafia and “low quality Chinese processed tomato”

allegations are “utterly lacking in support[,]” sanctions under Rule 11(b)(3) are warranted. First

Cent. Sav. Bank v. Meridian Residential Cap., No. 09-CV-3444 (DLI) (LB), 2011 U.S. Dist.

LEXIS 34234, at *5 (E.D.N.Y. Mar. 30, 2011) (citation omitted) (quoting Storey v. Cello Holdings,

L.L.C., 347 F. 3d 370, 388 (2d Cir. 2003)).

Similarly, Plaintiff bases his frivolous Complaint on a New York Times animation graphic

that on its face cannot be about Defendant or its Products. Plaintiff’s counsel clearly failed to view

the entire animation. A review of the animation reveals no reference whatsoever to Defendant or

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its Products. (Declaration of Daniel S. Tyler (“Tyler Decl.”), ¶ 10). Furthermore, one slide from

the animation, not shown in the Complaint, states:

[l]ast week in Brooklyn, craving a tomato sauce, I picked up a can of San Marzano
tomatoes, only to read in small print that they were grown in the United States. The
label was partly in Italian – “San Marzano,” “Pomodoro Pelati” – but the product
was American. How is this possible?

(Tyler Decl., ¶¶ 7-9) 3. Plaintiff does not allege that any of Defendant’s Products stated anywhere

on its packaging or labeling that they are “grown in the United States.” Nor could he, as the

Products correctly identify that they are grown in Italy. (Ciccotelli Decl. ¶¶ 4, 5, 7, 15, Ex. C

“Napoletano Affidavit”). Nor has the labeling of Defendant’s Cento San Marzano Tomatoes ever

contained the phrase “Pomodoro Pelati.” It is thus impossible that the New York Times author /

animator was looking at a can of Defendant’s products. It is therefore impossible that the New

York Times Animation concerned or even mention Defendant or its Products - yet Plaintiff’s

counsel decided to base the entire lawsuit on this animation. Consequently, any following slides

or conclusions from the animation, including the “HOW TO SPOT A FAKE” slide inserted into

Plaintiff’s Complaint, cannot and do not apply to Defendant’s Products. These material omissions

of fact merit sanctions against Plaintiff’s counsel. Ark. Teacher Ret. Sys. v. State St. Bank & Tr.

Co., No. 11-cv-10230-MLW, 2018 U.S. Dist. LEXIS 111409 (D. Mass. May 14, 2018) (“Rule 11

applies both to disclosures and omissions.”) (citing In re Ronco, Inc., 838 F.2d 212, 218 (7th Cir.

1988)); see also Gurman v. Metro Housing and Redevelopment Auth., 842 F. Supp. 2d 1151, 1154

(D. Minn. 2011) (“[A]s required by Rule 11(b)(3), plaintiffs’ factual contentions must ‘have

evidentiary support’ and must not be misleading by omission.”) (internal quotation omitted).

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See also https://www.nytimes.com/interactive/2015/08/16/opinion/sunday/food-chains-mystery-of-san-
marzano.html, Animation Slide Number 6 of 14 total slides (last accessed on April 4, 2019 at 6:08 p.m. CST).

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Plaintiff’s counsel clearly failed to review the entire animation, or even review the labeling of

Defendant’s San Marzano products.

Similarly, Plaintiff’s tangential allegations that searches of Defendant’s “Find My Field”

webpage only results in four farming fields is completely untrue. Defendant’s Products are grown

in up to 40 fields exclusively and verifiably located in the Sarnese Nocerino area of Italy,

depending on demand of the growing season. (Ciccotelli Decl. ¶ 4-5). Plaintiff or his counsel either

did not make a reasonable attempt to enter multiple field codes, or carelessly entered a limited

number of lot codes. Either way, the evidence demonstrates that the “Find My Field” webpage

works properly and shows dozens more than four fields. Moreover, Plaintiff’s inability to operate

a website cannot form a basis of fact to support allegations in his Complaint.

At best, Plaintiff’s counsel should be sanctioned for conducting no reasonable inquiry into

his source material, none of which bear any connection to Defendant or its Products. At worst,

Plaintiff’s counsel should be sanctioned for knowingly creating a wrongful association between

Defendant and these wrongful activities and unrelated sources. In either scenario, Plaintiff (and

his counsel) failed to allege facts concerning any aspect of Defendant’s farming practices, failed

to allege sustainable arguments for relief; and failed to withdraw the frivolous Complaint when

they were confronted with evidence that dooms their claims. This is the definition of sanctionable

conduct.

B. Plaintiff’s counsel did not reasonably research the certification of San


Marzano tomatoes, further violating Rule 11(b)(3) and resulting in a frivolous
claim under Rule 11(b)(2).

Plaintiff, bringing deceptive business practice and false advertising claims under New York

statutory and related common law (including fraud), fails to identify what statements on

Defendant’s product labeling are misleading or even which statements he relied upon in purchasing

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the products. (Complaint, ¶¶ 59-60, 72-75, 77-82). Plaintiff also fails to identify how Defendant’s

use of a specific third-party certifier misleads reasonable consumers. (Id. ¶¶ 47-48). Notably,

Plaintiff does not allege that Defendant’s Products are not actually certified by Agri-Cert and

ICEA. Nor does Plaintiff allege that Defendant failed to meet any governmental certification

requirements. Rather, Plaintiff erroneously asserts that there is only one entity that can certify San

Marzano tomatoes, and that Defendant’s products are not certified by that entity. (Complaint, ¶¶

15, 31-45). Plaintiff’s allegations create the false assumption that only one entity can certify San

Marzano tomatoes: the Consortium. (Complaint, ¶¶ 15, 45). That is demonstrably false, as even

participating members of the Consortium agree. (Ciccotelli Decl. ¶11, Ex. C “Napoletano

Affidavit”). A reasonable inquiry as required by Rule 11(b)(3) would have dispelled him of that

erroneous and unfounded belief. Having failed to conduct a reasonable inquiry, Plaintiff’s counsel

brought forth a frivolous claim in violation of Rule 11(b)(2).

Defendant’s Products meet all European Union standards for certification of San Marzano

tomatoes. (Ciccotelli Decl. ¶ 7-11). The Agri-Cert certification documents constitute a complete

certification of the challenged Products and allow Defendant to label them as San Marzano

tomatoes in the United States. (Id.). As such, Plaintiff’s allegations that Defendant’s certifications

do not certify the entire product is baseless. Moreover, the Consortium, who Plaintiff erroneously

believes is the only appropriate San Marzanos certifier, confirms the origins and quality of

Defendant’s Cento San Marzano Tomatoes. (See Napoletano Affidavit).

Having failed to perform even a cursory investigation into how San Marzanos tomatoes

are certified, Plaintiff presented a legal claim that was completely unfounded and frivolous: that

Defendant’s tomatoes are not certified by the “relevant authority.” (Complaint, ¶ 45). Plaintiff does

not even bother to state what claims he was misled by; what the appropriate “San Marzano

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guidelines” are (Id. ¶ 20); or what are the proper “identity and composition” requirements for

Defendant’s products. (Id. ¶ 47). As such, Rule 11 sanctions are necessary because a reasonable

pre-suit inquiry would have revealed that all of Defendant’s certifications are appropriate and are

applicable to its entire finished product, and that even the competing certifying entity that Plaintiff

contends is the only San Marzano certifier also stands by Defendant’s products. Moreover,

Plaintiff was put on notice of these undeniable facts and given “safe harbor” to withdraw the

Complaint, but refused. Such conduct is ripe for sanctions.

Plaintiff’s legal claim is accordingly frivolous because there can be no wrongdoing where

a party merely uses a different certifying company for its products. Cento’s labeling accurately

informs consumers of its San Marzano certifications, and Plaintiff did not (and cannot) allege

otherwise. Having presented no specific label claim or statement as misleading, Plaintiff’s only

legal contention is “patently contrary to existing law[.]” Storey, 347 F. 3d at 391.

However, even if the Court finds Plaintiff’s legal claim is meritless or misguided but not

unwarranted under existing law, this should not change any analysis of Plaintiff’s failure to make

a reasonable inquiry into his factual contentions:

A baseless factual contention poses a greater threat to justice than a baseless legal
contention. The evidentiary foundation upon which an attorney rests his assertions
of fact is, for the most part, exclusively within the control of the attorney and his
client. In order to function, the court must repose trust in the attorneys who come
before it to make factual representations supported by evidence.

In re September 11th Liab. Ins. Coverage Cases, 243 F.R.D. 114, 124 (S.D.N.Y. 2007). As such,

Plaintiff’s frivolous factual allegations alone merit sanctions under Rule 11.

C. Plaintiff failed to specifically identify any allegation as requiring further


investigation.

Finally, Plaintiff and his counsel cannot plausibly argue that they specifically identified

certain factual allegations as needing further investigation, as required by Rule 11(b)(3). When

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tying Defendant and its products to the Mafia or to a supposed “fraud” where “lower quality

Chinese processed tomato products” are marked as San Marzano tomatoes, Plaintiff did not qualify

these allegations are requiring further investigation. (Complaint, ¶¶ 13-16). When connecting the

New York Times animation to Defendant’s products, Plaintiff did not allege that additional

discovery would be needed to make the association. (Id. ¶¶ 17-19). Plaintiff did not claim that its

allegations concerning Defendant’s ICEA and Agri-Cert certifications were subject to further

inquiry. (Id. ¶¶ 20-25). Because Plaintiff did not “specifically so identif[y]” that he will need

further investigation or discovery of his most salacious claims, he is not saved from sanctions

under Rule 11.

V. CONCLUSION

Plaintiff claims that “Defendant’s claim of certification is a weak half-truth, without much

effort put in.” (Complaint, ¶ 42). In reality, Plaintiff’s entire lawsuit is a complete lie, with no

effort put in. Defendant asks that this Motion for Sanctions be granted, and that Plaintiff and

Plaintiff’s counsel, jointly be sanctioned by this Court in the form of Defendant’s attorneys’ fees

and costs associated with bringing this Motion and defending this lawsuit. Fed. R. Civ. P. 11(c)(4).

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Dated: May 23, 2019. Respectfully submitted,

By: /s/ Erin R. Conway


Erin R. Conway
New York Bar No. 4842316
E.D.N.Y. Bar Code: EC2492
Daniel S. Tyler
Illinois Reg. No. 6315798
AMIN TALATI UPADHYE, LLP
100 S. Wacker Dr., Suite 2000
Chicago, IL 60606
Telephone: (312) 784-1061
Erin@amintalati.com
Daniel@amintalati.com

Attorneys for Defendant, Cento Fine Food, Inc.

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