Excerpt: "The U.S.D.C. S.D. California on Mar. 2, 2001, tackled for the first time a procedural issue under the Private Securities Litigation Reform Act - at what point in a securities lawsuit, a district court must make mandated Fed. R. Civ. P. 11 findings that could lead to the imposition of sanctions (DeMarco v. Depotech Corp., S.D. California, Case No. 98-CV-0675 W (POR), 03/02/2001).

Judge Thomas Whelan determined that the statute's phrase requiring Rule 11 findings upon "final adjudication of the action" occurs upon the district court's termination and final disposition of the underlying action and does not require any additional exhaustion of appellate remedies." This result is consistent with those of courts in other jurisdictions that have considered the issue, Whelan noted.