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Message: moore`s memo of opposition on pacer

moore`s memo of opposition on pacer

posted on Mar 18, 2005 02:28PM
Moore`s legal team has filed a 7-page memo in opposition to Patriot`s request to file a motion asking Fogel to reconsider. Their major points:

A. Plaintiff`s Request Was Improperly Filed By Plaintiff`s Disqualified Counsel. [Rather than by Carlton Johnson, presumably.]

B. Disqualified Counsel`s Belated Claim Of Its Own Incompetence Is Not A Proper

Basis To Allow Reconsideration.

C. Plaintiff`s Unsupported Claim That The Court Erred On Virtually Every Issue Is

Insufficient To Merit Leave to File a Motion for Reconsideration.

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