I won’t bother re-hashing the Rakfosky history, you can Google it if you want.
Update 3/9/12: Our motion to dismiss was served December 15th, but the court clerk declined to take it at the time because the date of service was so far in front of the motion’s return date in March. While we waited, a stay in the case was reinstated. It expired today, March 9th. So the motion was re-filed today.
Update 5/21/12 Rakofsky has served the following documents in opposition to our motion to dismiss:
Update 6/8/12 – Our Reply papers:
My Reply Affidavit: ET-ReplyAffid-Final
Our Memo of Law: RakofskyReplyMemo FINAL