I wouldn’t. Sanctions aren’t appropriate for mere mistakes or even plain bad / stupid lawyering - and judges typically don’t take kindly to bandying about sanctions motions. Granted I don’t litigate, but I have been a lawyer for a while now and all the stories I hear tell of sanctions involve behavior that is borderline (or obviously) criminally fraudulent - lies, hiding documents, intentional omission of facts, theft, evidence tampering. This isn’t that - it’s just a sloppy, shitty, poorly thought out argument. It gets dismissed, but very likely not with sanctions - and given that Avenatti has a shitload of motion practice ahead of him in the near future, it likely would not be wise to bring a rule 11 which may just piss off the judge.

But what the fuck do I know.