The following excerpt is from In re Marathon Home Loans, 101 BR 216 (Bankr. E.D. Cal. 1989):
The leading case in this circuit enunciating the standards for applying Rule 11 sanctions recognizes that there are two prongs to the rule: frivolousness and improper purpose. Zaldivar v. City of Los Angeles, 780 F.2d 823, 830 (9th Cir.1986). Improper purpose is implicated in this case by virtue of harassment or abusive litigation activity.
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