How do you fight a motion to dismiss and to impose sanctions under F.S. 57.105, in small claims,?

Mr. C is correct. In fact the entire purpose of a motion for sanctions, and its only effectiveness, is when the court determines that the issue you raised or claim you brought was meritless and that you refused to recognize this within the 21 day "safe harbor" provison and take proper corrective action. In that instance there would be no defense if you are wrong and you would have some "lumpins" coming your way. The best defense to 57.105 or Rule 11 sanctions is being legally correct in your actions. As as aside, that you make an inquiry about the small claims rules AFTER you are involved in litigation, presumably as a Plaintiff, is beyond disconcerting. If you have such little knowldge of the rules of court, you are not likely prepared to be acting pro-se without expecting a disasterous result. You should consider hiring a lawyer in your area to help you immediately. Finally, and this is unrelated to any representation issue, I am taking a personal poll of pro-se litigants on several issues, if you would be so kind as to contact my office I would like to ask a few questions about your experiences in "the system".

You mention a motion to dismiss and then breach of contract. You have to include a copy of the contract you allege was breached. That may be the entire basis of the motion to dismiss. You can file an amended complaint and add the contract. The 57.105 motion is particularly interesting as an initial pleading. Its either a bluff or your complaint really lacks merit. Sanctions are often based on a set of facts that one party thinks is so overwhelming that it deserves some sort of penalty on the other party. Issues of facts, however, are cannot be argued in a motion to dismiss. Or, pro se litigants often put to much of their emotion in the complaint. "He did this to me and I didn't like it." That falls short of the requirement for a legal complaint. The complaint could have been written in such a manner as to not really request the court to do anything.