Defendant lost a summary judgment and has filed another. This is a medical malpractice case, I'm the plaintiff. Defendant states that they have stated additional undisputed material facts which allow a second summary judgment. The additional undisputed facts are simply additional general statements from the original medical records that were already in their possession from the first summary judgment. I feel confident that I will prevail again, however I will have to spend a lot of time to put my opposition together. What kind of sanctions, if any ,can I ask for? The new filing is simply harassment and possibly on chance that I won't oppose it?