MEMORANDUM ORDER Before the Court is Petitioner Universitas Education, LLC’s (“Petitioner” or “Universitas”) Motion for the Imposition of Rule 11 Sanctions Against Roger Stavis, Esq., and Mintz & Gold LLP (“M&G”, and together, the “Stavis Parties”), former counsel for Respondent Grist Mill Capital, LLC (“GMC”) in this action. (Docket entry no. 707 (the “Sanctions Motion”).) The Court has carefully considered all of the submissions and arguments in connection with the instant motion. For the following reasons, the Sanctions Motion is denied in its entirety. BACKGROUND The factual and procedural history of these actions is detailed at length in the Court’s prior decisions, familiarity with which is assumed. (See generally docket entry nos. 341, 366, 474, 722.) As the Court has previously explained: This case is part of a lengthy and ongoing dispute over the disposition of the $30 million in proceeds of two life insurance policies obtained by the late Sash A. Spencer, who was the Chief Executive Officer of Holding Capital Group, Inc. Mr. Spencer placed the two life insurance policies into the Charter Oak Trust Welfare Benefit Plan (“Charter Oak Trust”) which was “established to provide for the acquisition of and investment in various types of insurance policies to provide a welfare benefit fund or estate planning benefits,” pursuant to a Funding Obligation Agreement and Power of Attorney. [ ]. Mr. Spencer named Petitioner the sole, irrevocable beneficiary of a Charter Oak Trust death benefit comprising the proceeds payable under two life insurance policies, whose face values totaled $30 million (the “Life Insurance Proceeds”). [ ]. Mr. Spencer died in June 2008, and Petitioner made a valid and timely claim to the Life Insurance Proceeds. (Ex. 18 at 3-4.) Nova Group, Inc. (“Nova”) and the Charter Oak Trust Welfare Benefit Plan (“Charter Oak Trust”) are two of the hundreds of business entities organized and controlled, directly or indirectly, by respondent Mr. Carpenter. [ ]. Nova is the corporate trustee of the Charter Oak Trust. [ ]. After Petitioner made its death beneficiary claim, [the president of Nova] sought payment from the insurer, acknowledging in writing that Nova had “a fiduciary responsibility and legal obligation to carry out Mr. Spencer’s wishes as he intended in a timely fashion to pay those death proceeds to a charity that he established prior to his death.” [ ]. The insurer paid Charter Oak Trust $30.67 million in Life Insurance Proceeds[.]…In May 2009, after receiving payment of the Life Insurance Proceeds, Nova denied Petitioner’s death benefit claim. Petitioner challenged the denial through a demand for arbitration filed on June 17, 2010; a binding arbitration award against Nova…was issued on January 24, 2011 in the amount of $26,525,535.98…. (Docket entry no. 341 at 2-3.) After Nova failed to pay the arbitration award, Petitioner filed an action seeking to enforce it; that action was removed to this Court, and consolidated with a separate action Nova had brought to vacate the award in the District of Connecticut, which had been transferred to this Court pursuant to 28 U.S.C. section 1404(a). On June 7, 2012, judgment was entered in favor of Petitioner upon the arbitration award in the amount of $30,181,880.30, including prejudgment interest. (Docket entry no. 41.) As relevant here, extensive post-judgment discovery and turnover proceedings ensued. In August 2014, the Court entered judgment against Nova’s former principal Daniel E. Carpenter and several affiliates he controlled, including Respondent GMC, in respect of funds fraudulently conveyed to those affiliates, at Mr. Carpenter’s direction, in a scheme to prospectively render the arbitration award and the judgment issued against Nova in these actions unrecoverable.1 (See docket entry nos. 474 (“Turnover Opinion”), 475 (“Turnover Judgment”).) Over six years later, Mr. Carpenter, on November 13, 2020, and GMC, on February 19, 20212, moved, pursuant to Federal Rules of Civil Procedure 60(b)(4) and 60(b)(6), to vacate the Turnover Judgment. (See docket entry nos. 666, 696.) Both motions argued principally that the Court lacked personal jurisdiction over Mr. Carpenter and GMC at the time of the Turnover Judgment. Universitas then moved, pursuant to Federal Rule of Civil Procedure 11, seeking sanctions against Mr. Carpenter (docket entry no. 676) and against counsel for GMC, for having filed the motions to vacate. On April 20, 2021, approximately one month after Universitas filed the Sanctions Motion against Mr. Stavis and M&G, the latter filed their opposition, and separately moved to withdraw as counsel for GMC, citing an irreparable breakdown of the attorney-client relationship due to a disagreement regarding litigation strategy. (See docket entry no. 714 (“Opp.”); docket entry no. 710 (the “Withdrawal Motion”).) Universitas did not oppose the Withdrawal Motion, although Mr. Carpenter, as GMC’s principal, did and argued that M&G had failed to comply with the Court’s individual rules in using their best efforts to informally resolve the dispute. (See generally docket entry no. 718.) On June 2, 2021, the Court granted M&G’s Withdrawal Motion, finding that M&G had proffered satisfactory reasons for withdrawal, and that, because GMC’s motion to vacate was fully briefed and it had filed its opposition to the Sanctions Motion, withdrawal would not stall the case. (See docket entry no. 721 at 3-4.) On September 28, 2021, in a Memorandum Opinion and Order, the Court denied in their entirety Mr. Carpenter’s and GMC’s motions to vacate the Turnover Judgment, and granted in part and denied in part Petitioner’s motion for sanctions against Mr. Carpenter. (Docket entry no. 722 (the “Rule 60 Order”).) The Court imposed sanctions on Mr. Carpenter for raising in his motion arguments concerning lack of subject matter jurisdiction, improper service of process, and noncompliance with Federal Rule of Civil Procedure 58, that were frivolous and/or had previously and explicitly been rejected by the Court.3 (Rule 60 Order at 21-22.) The Court, however, declined to impose sanctions in connection with Mr. Carpenter’s personal jurisdiction argument, finding that it was not “entirely frivolous” and had not been previously rejected by the Court. (Id.) Mr. Carpenter and GMC, through new counsel, appealed the Rule 60 Order. (See docket entry no. 725.) On January 20, 2022, the Court, in light of the pending appeal, deferred resolution of Petitioner’s pending motion for sanctions as against the Stavis Parties until the Court of Appeals had resolved the appeal. (See docket entry no. 735.) On February 23, 2023, the Second Circuit affirmed the Rule 60 Order, characterizing the “numerous” challenges that Appellants raised as “baseless” and, in particular, Appellants’ challenge to this Court’s subject matter jurisdiction as “frivolous.” Universitas Educ., LLC v. Grist Mill Capital, LLC, No. 21-2690, 2023 WL 2170669, at *3 (2d Cir. Feb. 23, 2023) (summary order). The panel also reminded counsel for Appellants “to be mindful stewards of judicial resources and taxpayer dollars,” and that “they are duty-bound to avoid pursuing frivolous appeals and presenting clearly meritless arguments to [the Court of Appeals].” See id. at *3 n.3. Following the Second Circuit’s affirmance, Universitas submitted a reply in support of its Sanctions Motion (docket entry no. 740 (the “Pet. Reply”)), and GMC, through its new counsel, filed additional opposition papers (docket entry no. 741). These submissions supplemented the briefing on the Sanctions Motion that had been completed prior to the Court’s decision to defer resolution of the motion. The Court also received a letter submission from Mr. Stavis, who noted that the new opposition was filed by new counsel, that neither he nor his firm joined in or were involved in drafting that submission, and that they would rely instead on their earlier submissions. (See docket entry no. 742.) DISCUSSION Petitioner moves, pursuant to Federal Rule of Civil Procedure 11, for sanctions against the Stavis Parties, arising out of their filing of their motion to vacate, arguing principally that the motion raised frivolous and duplicative arguments. The thrust of the Sanctions Motion is that the Stavis Parties were complicit in Mr. Carpenter’s (and thus, GMC’s) yearslong “war of attrition” against Universitas, which was calculated to shrink its financial resources and render it prohibitive costly to continue its collection efforts. (Sanctions Motion at 13.) Rule 11 requires that motions and other papers presented to the Court not be “presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation,” that “the claims, defenses, and other legal contentions” presented “are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law,” and that the factual contentions in such motions and other papers “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)(1), (b)(2), (b)(3). The Court may sanction a party for violation of Rule 11 “after notice and a reasonable opportunity to respond.” Fed. R. Civ. P. 11(c)(1)-(2). Sanctions should only be imposed, however, “if it is patently clear that a claim has absolutely no chance of success, and all doubts should be resolved in favor” of the filing party. K.M.B. Warehouse Distributors, Inc. v. Walker Mfg. Co., 61 F.3d 123, 131 (2d Cir. 1995) (citation and internal quotation marks omitted). The “main purpose of Rule 11 is to deter improper behavior, not to compensate the victims of it or punish the offender.” Universitas Educ., LLC v. Nova Grp., Inc., 784 F.3d 99, 103 (2d Cir. 2015) (quoting 5A Charles Allen Wright & Arthur R. Miller, Federal Practice and Procedure §1336.3 (3d ed. 2004)). Finally, in considering “whether to impose a sanction or what sanctions would be appropriate in the circumstances,” the Court weighs, among other factors, “[w]hether the improper conduct was willful, or negligent; whether it was part of a pattern of activity, or an isolated event; whether it infected the entire pleading, or only one particular count or defense; whether the person has engaged in similar conduct in other litigation; whether it was intended to injure; what effect it had on the litigation process in time or expense; [and] whether the responsible person is trained in the law.” Fed. R. Civ. P. 11 advisory committee note to the 1993 amendment. After considering the goals of Rule 11 and the above factors, the Court concludes that sanctions against the Stavis Parties are not warranted under these circumstances. First, the Court notes that the Stavis Parties’ representation of GMC spanned just four months, during which they litigated two motions — one to vacate the Turnover Judgment and one to withdraw their representation. Second, Mr. Stavis proffers in his declaration in support of his opposition to the Sanctions Motion that the Stavis Parties were aware that the Court had previously sanctioned Respondent Nova and one of its former counsel for making duplicative arguments with respect to the Turnover Judgement, and that they sought to determine — and in their view, did determine — that a separate, colorable argument existed in favor of vacating the Turnover Judgment as to GMC. (See docket entry no. 715 (“Stavis Decl.”)
10-15.) Third, after Petitioner first served its Rule 11 papers on the Stavis Parties, they withdrew their initial motion to vacate, and submitted a revised version based on narrower grounds — removing a challenge as to the Court’s subject matter jurisdiction, and principally focusing on the Court’s purported lack of personal jurisdiction over GMC, and an alleged deprivation of due process in that GMC lacked counsel at entry of the Turnover Judgment.4 (See id.
