See Esposito v. Suffolk County Community College, No. 16-CV-4833, 2019 WL 1044099, at *6 (E.D.N.Y. March 4, 2019) (“Essentially, the Defendants are asking the Court to award sanctions because they believe the merits of their defense. However, resolving the Defendants' arguments would require the Court to make a factual determination regarding a claim essential to the merits of the action, an issue for which a Rule 11 motion is an inappropriate vehicle”).

Accordingly, it is inappropriate to examine the proffered documents and resolve questions of fact or disputes regarding the law on their merits at this stage. See Esposito v. Suffolk Cnty. Cmty. Coll., No. 16-CV-04833 (ADS) (ARL), 2019 WL 1044099, at *6 (E.D.N.Y. Mar. 4, 2019) (“Essentially, the Defendants are asking the Court to award sanctions because they believe the merits of their defense.

Clear and convincing evidence “produces in the mind of the trier of fact a firm belief or conviction as to the truth of the allegations sought to be established” and “enable[s] the factfinder to come to a clear conviction, without hesitancy, of the truth of the precise facts in issue.” Funk v. Belneftekhim, 2019 WL 7603139, at *3 (E.D.N.Y. Jan. 17, 2019) (Scanlon, M.J.) (internal quotation marks omitted) (quoting Esposito v. Suffolk Cnty. Cmty. Coll., 2019 WL 1044099, at *2 (E.D.N.Y. Mar. 4, 2019)). “In other words, the proof must be ‘highly probable' and ‘leave[] no substantial doubt.