“The Court finds that an award of attorney’s fees and costs is a necessary deterrent to Plaintiff and others similarly situated from pursuing frivolous litigation, especially where an improper purpose may be inferred,” U.S. District Judge Claude M. Hilton of the Eastern District of Virginia wrote in an opinion filed Sept. 1. “As to Plaintiff’s ability to pay, there is no evidence that Plaintiff lacks the financial resources to pay this sanction. She claims to be an extremely frugal retiree without any real property or assets, however, she has not provided any supporting financial information or documentation.”