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    Plaintiff Case Study

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    COMES NOW, PLAINTIFF Jackie Valenzuela, by and through her attorneys of record, and hereby submit the following Points and Authorities in support of their Opposition to Defendants’ Gio Giovanni, and Fedex Corporation, Fedex Ground Package System, Fedex Corporate Services, Inc. (hereinafter referred to as "Defendant" or "FedEx") Motion to Dismiss Plaintiffs' Complaint. I. INTRODUCTION Defendants’ Motion to Dismiss pursuant to Federal Rules of Civil Procedure 12(b)(6) seek to dismiss Plaintiff’s complaint on the following grounds: failure to state a claim upon which relief can be granted for, negligence, vicarious liability, and punitive damages. All of these arguments lack support and should be immediately rejected. In respect to Defendant's…

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    Plaintiff Case Study

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    PLAINTIFFS' MOTION TO COMPEL PRODUCTION OF DOCUMENTS Plaintiff DARLA WILLIAMS moves for an order compelling Defendant SARAH MINER to produce documents withheld on the grounds of privilege under the work-product doctrine. Plaintiffs request that Defendant be ordered to produce said documents by close of business on March 17, 2017. I. ARGUMENT A. THERE’S A SUBSTANTIAL NEED FOR STATEMENTS MADE TO THE DEFENDANT’S INSURANCE ADJUSTERS. Federal Rule 26(b)(3) provides that: “ordinarily, a party may not…

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    DISCRIMINATION AND RETALIATION 46. That at all times herein relevant, Plaintiff VELEZ was in a position subordinate to Defendant BESIKO with regard to her employment with Defendant EXPRESS. 47. That at all times herein relevant, Plaintiff HUDSON was in a position subordinate to Defendant BESIKO with regard to her employment with Defendant EXPRESS. 48. That at all times herein relevant, Plaintiff VELEZ would be given directives and take work orders from Defendant BESIKO in the course of her…

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    legal basis for her position, Plaintiff simply proposes the same flawed legal theories that she asserted in her original Complaint, but now provides further allegations in her Proposed First Amended Complaint (Dkt 28-2 Exhibit “B”) as same allegedly pertains to both “enterprise and “individual” coverage theories. The Defendants’ contend that Plaintiffs’ Motion to Amend the Complaint…

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    Shawano, Wisconsin is targeted at Ford Motor Company (FMC) to seek redress for the various damages they caused with their negligence. The plaintiffs, or accusers, in this case are 210 current and former residents of Shawano, and all are members of the historic Menominee Indian Tribe, according to attorney Michela May. The plaintiffs seek compensation from defendants FMC and the Shawano County Solid Waste Management Authority (SCSWMA) for mishandling and misconduct at the Shawano Mines…

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    to modify scheduling order, and in support thereof, states as follows: I. Plaintiff’s Motion to Stay Proceedings with Regard to Its Pending Declaratory Judgment Action. 1. On March 16, 2016, Plaintiff filed a complaint for declaratory judgment seeking a declaration as to the rights of the parties under a putative contract. 2. On March 17, 2016, Defendant filed a separate complaint alleging that Plaintiff breached the…

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    (www.differencebetween.com) Crime is of a serious nature that poses threats to “peace and order of society.” (www.differencebetween.com) The legal perspective says that crime is an act that violates criminal law of a country. (www.differencebetween.com) Because of the high value put on freedom, defendants have more rights and protections than civil defendants. (www.rbs2.com) In criminal cases, the state will always have the burden of proof. (www.rbs2.com) They have to prove the defendant…

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    The Ninth Circuit affirmed the ruling that the NCAA do unlawfully restrain trade – in order words, do violate antitrust laws – but reversed the district courts ruling regarding compensating student-athletes beyond the full cost of attending college through deferred payments. The ruling was appealed to the Supreme Court as well, but the Supreme Court rejected their option to review the case. This lawsuit could potentially have forced the NCAA and their schools to pay million – perhaps even…

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    Business Case Summary

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    controlled subsidiaries and affiliates (the "Class") from at least as early as January 1, 2000 to the present (the “Class Period”). In January 2015, the plaintiffs’ class counsel sent a Notice of Claim to MCO’s, allegedly including APS Healthcare, Inc. (APS), which potentially fell within the Class. Recipients of the Notice of Claim were required to opt out of the Class by February 3, 2015. Plaintiffs’ class counsel indicated that APS had been identified as a MCO because in entered into a…

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    Thelma Agnes Smith v. David Phillip Riley, Statement of facts. The plaintiff and defendant cohabited together for numerous years without entering into marriage or civil union. Although, there was a romantic relationship. Unfortunately, the relationship has soured resulting in the need to liquidate assets that were acquired within joint ownership. The plaintiff and defendant had both agreed previously to how the assets would be divided, this agreement was not followed therefore litigation…

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