In response to Defendant Shawn Carter's motion for sanctions, the Plaintiff argues that the motion is both frivolous and procedurally improper. The Plaintiff contends that Carter's reliance on a single television interview to challenge the veracity of events that occurred twenty-four years ago, when the Plaintiff was thirteen, does not substantiate a claim for sanctions. They emphasize that discrepancies in recollection, especially concerning traumatic events from decades prior, are common and do not equate to bad faith or warrant sanctions. Furthermore, the Plaintiff highlights that Carter's attempt to bypass the mandatory twenty-one-day safe harbor provision under Rule 11 lacks legal precedent and justification, rendering his request to expedite the filing deadline to one day as unfounded.

The Plaintiff also underscores that expecting a sexual assault victim, particularly one who was a minor at the time and has disclosed being autistic, to have precise recall of all details is unreasonable. They reference New York courts' recognition that survivors of childhood sexual abuse may not remember exact dates or times, which does not invalidate their claims. The Plaintiff asserts that Carter's threats of immediate sanctions are intended to intimidate and silence the Plaintiff and other potential claimants, constituting an abuse of the judicial process. They conclude by urging the court to deny Carter's motion, stating that it lacks substantive merit and is procedurally defective.


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