“[A]n erroneous statement of fact in a pleading ‘can give rise to the imposition of sanctions only when the particular allegation is utterly lacking in support.'” In re AOL, Inc. Repurchase Offer Litig., No. 12 Civ. 3497 (DLC), 2013 WL 6331802, at *3 (S.D.N.Y. Dec. 5, 2013) (quoting Kiobel v. Millson, 592 F.3d 78, 81 (2d Cir. 2010)). When the accuracy of statements attributed to a witness in a complaint is at issue, the witness's subsequent repudiation of those statements is not dispositive of whether the plaintiff's counsel met their Rule 11 obligations.
Thus, Rule 11"imposes on attorneys ‘an affirmative duty to conduct a reasonable inquiry into the facts and the law.’ " In re AOL, Inc. Repurchase Offer Litig., 2013 WL 6331802, at *3 (S.D.N.Y. Dec. 5, 2013) (quoting Bus. Guides, Inc. v. Chromatic Commc'ns Enters., Inc., 498 U.S. 533, 551, 111 S.Ct. 922, 112 L.Ed.2d 1140 (1991) ). 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."