Lockheed Martin Energy Systems, Inc. v. Slavin
The court addresses Plaintiff Lockheed Martin Energy Systems, Inc.'s motion for sanctions against Defendant Edward A. Slavin, Jr., an attorney who represented himself in a collection action. The underlying litigation sought to compel Mr. Slavin to repay over $27,000 in attorney fees as ordered by the United States Department of Labor (DOL). Mr. Slavin's answer and subsequent filings were found to be 17 pages long, replete with frivolous, baseless, irrelevant, and offensive claims, personal attacks against Lockheed and its counsel, and a disregard for court procedures and prior rulings. The court found Mr. Slavin violated Rule 11 in six specific ways, including asserting frivolous challenges to jurisdiction and defenses, denying ARB authority, and engaging in personal attacks. Citing Mr. Slavin's history of similar conduct before administrative law judges, the court imposed sanctions: a public reprimand, a written apology to opposing counsel and plaintiff, payment of Lockheed's reasonable attorney fees and expenses, and a suspended monetary sanction of $10,000 to the Clerk of Court, conditioned on future compliance with Rule 11 standards.