Advances in micro-electronic fabrication technology have allowed the creation of Micro-Electrical Mechanical Systems (MEMS) capable of motion and applying force at the micron level. By using micro-electronic fabrication techniques, MEMS devices may be mass-produced in batches. Such micro-electronic fabrication techniques can include release etching and wet etching. Vibration and/or agitation during and/or subsequent to wet etching of MEMS devices can result in contact between component surfaces of the MEMS devices. Surface tension or capillary action of the fluid used in the etching process can cause stiction between the components of the MEMS device. Components capable of motion may be displaced from their intended path of motion so as to become inoperable. It remains a difficult challenge to fabricate a plurality of MEMS devices having components capable of motion while minimizing errant motions of the components during the fabrication process, especially during the etching process and/or other process steps where such components may be subject to vibration and/or agitation that can result in contact between component surfaces of the MEMS devices.