Jes Staley And The Third Party Reply Memorandum In Support Of The Motion To Dismiss (Part 1) (8/5/24)

The Epstein Chronicles

The Jes Staley Third Party REPLY MEMORANDUM IN SUPPORT OF MOTION TO DISMISS:

1. Purpose: The document is a reply memorandum supporting a motion to dismiss a third-party complaint or claim.
2. Arguments:
   • Lack of Jurisdiction: The third-party defendant argues that the court lacks jurisdiction over the case, often due to improper service of process or lack of personal jurisdiction.
   • Failure to State a Claim: The memorandum asserts that the third-party plaintiff has failed to state a claim upon which relief can be granted. This can include arguments that the complaint does not meet legal standards for sufficiency.
   • Procedural Issues: Any procedural deficiencies in the filing of the third-party complaint are highlighted. This can include failure to comply with relevant rules or deadlines.
   • Merits of the Case: The third-party defendant addresses the substantive merits of the case, arguing that even if the procedural hurdles are overcome, the underlying claims lack merit.
3. Supporting Evidence: The memorandum may include references to legal precedents, statutes, and factual evidence supporting the motion to dismiss.
4. Conclusion: The document concludes with a request that the court grants the motion to dismiss the third-party complaint or claim.

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source:
Microsoft Word - MTD Reply - Doe an(11210113.11).docx (courtlistener.com)
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