Does an attorney for a plaintiff have to verify accusations prior to filing an adversary complaint

Yes, the plaintiff's attorney has a duty to make a reasonable inquiry into the validity of the allegations and can be sanctioned for presenting a claim (adversary) that isn't valid. Bankruptcy Rule 9011 requires that ANY papers submitted to the court constitute a certification that, to the best of the person's knowledge, after a reasonable inquiry, that the allegations and factual contentions made have evidentiary support.    On top of that, if the adversary is brought under section 523(a)(2) of the bankruptcy code (alleging the money/loan was obtained through fraud) and the plaintiff loses, then the defendant/debtor can recover attorney's fees and costs in defending the action from the plaintiff. Mark Markus has been practicing exclusively bankruptcy law in California since 1991.  He is a Certified Specialist in Bankruptcy Law by the State Bar of California Board of Legal Specialization,  AV-Rated by martindale.com, and A+ rated by the Better Business Bureau.