Opinion
21-CV-4746 (LTS)
09-17-2021
DECLARATION
I am a plaintiff in this action and I respectfully submit this declaration in response to the Court's order dated September 16, 2021. I have signed this declaration as proof that I have read the amended complaint in this action (ECF 7) and that I am a plaintiff in this action.
Under Rule 11(b) of the Federal Rules of Civil Procedure, I certify that to the best of my knowledge, information, and belief, formed after an inquiry reasonable under the circumstances:
(1) the complaint is not being presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation;
(2) the claims and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law;
(3) 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; and
(4) the denials of factual contentions are warranted on the evidence or, if specifically so identified, are reasonably based on belief or a lack of information.