Which statement best describes the condition for relying on your client as evidentiary support under Rule 11(b)(3)?

• A. You must thoroughly question the client.
• B. The client's account must be objectively reasonable.
• C. Both you must thoroughly question the client and the account must be objectively reasonable.
• D. You may rely on the client's account without questioning.

Answer: (C)

Under Rule 11(b)(3), a attorney certifies that the factual contentions have evidentiary support or will likely have such support after a reasonable opportunity for further investigation or discovery. That certification rests on a reasonable inquiry into the facts. Reasonable inquiry isn’t satisfied by simply relaying a client’s story; it requires you to thoroughly question the client and assess whether the account is objectively reasonable in light of what you can verify and what you learn through discovery. If the client’s account is not the product of thorough questioning or if it isn’t objectively reasonable, you wouldn’t have the evidentiary support Rule 11 requires. Therefore, the best description is that you rely on the client’s account only if you have thoroughly questioned the client and the account is objectively reasonable.