Initial post on June 3rd: Attached at the bottom are a set of motion papers being served today in Joseph Rakofsky’s suit against 81 defendants (including me) for defamation. I have previously given my thoughts on it, as a defendant, and my defense of vade et caca in pilleum. (Updated 6/20/11 below, Rakofsky’s opposition and our Reply)
But since I am now the attorney of record for 33 out of the 81 defendants, I will no longer be providing much in the way of opinion on this blog (other than what may be in papers being filed).
The motion is to extend the time to answer for all defendants, so that we have unified scheduled for making motions and answering, and to admit Marc Randazza pro hac vice.
Attached are the following:
Exhibits to motion include:
Update 1: 6/20/11 Updated Docs (Opposition and Reply):
Update 2: 6/30/11 Updated Docs (Sur-Replies and court appearance 6/29/11)
Update 3: 9/21 Update: The motion was heard on oral argument on September 15th and the motion to admit Randazza pro hac vice was granted. An order will follow. The court also granted Rakofsky more time to find new counsel and set down a briefing schedule for motions to dismiss. The schedule is as follows:
Nov 15: Plaintiff to obtain new counsel by this date or the corporate defendant (Rakofsky PC) is dismissed as corporations must have a lawyer. Rakofsky can proceed pro se in his individual capacity.
January 13, 2012: Due date for all pre-answer motions to dismiss or answers;
February 13: Opposition due for all motions to dismiss;
March 13: All Replies due on motions to dismiss
March 14: Return date of the motions
All other activity is stayed by the Court.
Documents: Order (Typed Version Unofficial)