a reasonable attorney fee for the requesting party’s attorney” if the person holding an apparent adverse interest fails to comply with the request). At the time of the trial court proceedings in this case, section 649.5 limited attorney fees to a maximum of forty dollars. The parties do not rely on section 649.5. Of course, rule 1.413 applies in civil cases generally, not just quiet-title actions. The amount of the sanction should be sufficient to motivate the. victims of frivolous filings to enforce the rule. See Rowedder, 814 N.W.2d at 592. Yet we are mindful that large monetary sanctions may discourage advocacy and lead to additional rounds of litigation to recover attorney’s fees. See Cooter & Gell v. Hartmarx Corp., 496 U.S 384, 393, 110 S.Ct. 2447, 2454, 110 L.Ed.2d 359 (1990) (<HOLDING>); Mark S. Cady, Curbing Litigation Abuse and
recognizing rule recognizing thomas methodology but noting that it is not mandatory recognizing this rule recognizing that issue advocacy may include discussion of issues and candidates recognizing rule lls central goal of deterrence but noting concerns that it will spawn satellite litigation and chill vigorous advocacy