What do you certify as to the FACTUAL support for denials in your pleading? That your denials are:

• A. Warranted on the evidence
• B. If specifically identified, are reasonably based on belief or lack of information
• C. Based on the client's personal beliefs
• D. Based on the court's orders

Answer: (B)

Under Rule 11, when signing pleadings, you certify that, to the best of your knowledge after reasonable inquiry, the factual contentions have evidentiary support and that denials are warranted by evidence or reasonably based on belief or lack of information. The statement that, if a denial is specifically identified, it is reasonably based on belief or lack of information best matches that certification. It allows a denial to be grounded either in actual evidence or in a lawyer’s reasonable belief formed after inquiry, or in a lack of knowledge that prevents forming a belief. This keeps denials meaningful and prevents frivolous or unfounded assertions from being filed. The other options are too narrow or misstate the basis: denials aren’t limited to evidence alone, they aren’t simply based on the client’s personal beliefs, and they aren’t derived from court orders.