Rakofsky Motion #11: Our motion to dismiss (Updated x3)

This motion is on behalf of the 35 defendants (me included) that Marc Randazza and I represent.

I won’t bother re-hashing the Rakfosky history, you can Google it if you want.

Selected Documents:

Memo of Law

DeVoy Affidavit

Turkewitz Affidavit

Wells Affidavit

Exh G – Financial Crime

Exh H WhiteCollarCT

Exh I – Yellow Bot

Exh J – Lawyer search

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:

Affidavit of Forensic Expert

Goldsmith Affirmation

Rakofsky Affidavit

Memo of Law

Update 6/8/12 – Our Reply papers:

My Reply Affidavit: ET-ReplyAffid-Final

Our Memo of Law: RakofskyReplyMemo FINAL

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6 Responses Leave a comment

  • Elizabeth 2011.12.15 at 18:25 | Quote

    A very well-written brief. I hope this case will be behind you soon.

  • Joe 2011.12.16 at 14:14 | Quote

    A thing of beauty.

  • A Troll 2011.12.18 at 19:48 | Quote

    Well you must be doing something right.

    From W3snoop.com

    “Our records indicate that newyorkpersonalinjuryattorneyblog.com receives an estimated 1,742 unique visitors each day – a huge amount of traffic!”

  • Elliot 2012.1.2 at 15:10 | Quote

    When are his responsive papers due? I can hardly wait for the unintended comedy.

  • Eric Turkewitz 2012.1.2 at 15:49 | Quote

    When are his responsive papers due?

    The action has been stayed until March 9th.

Comments are closed.


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