Recently, U.S. District Judge Donald Middlebrooks of the Southern District Florida imposed stiff monetary sanctions under Fed. R. Civ. P. 11 on the lawyers for the plaintiff in Donald Trump v. Hillary Clinton et al., No. 22-CV-14102 (S.D. Fl. Nov. 11, 2022) (ECF 284). (Judge Middlebrooks had already dismissed the claim on the merits, which is currently subject to appeal before the Eleventh Circuit.) The complaint alleged a vast civil RICO conspiracy by those associated with the 2016 Clinton campaign to undermine President Trump by vilifying him with fabricated information tying him to Russia. This information was collected in the so-called "Steele Dossier," and has been the subject of criminal investigation and one indictment upon which the defendant was recently acquitted.