Beruflich Dokumente
Kultur Dokumente
13
July
Time: 9:30 a.m.
21 Place: U.S. Dist. Ct., Bankruptcy Courtroom
1300 18 t Street, Bakersfield, CA
22
Date Action Filed: January 6, 2007
23 Trial Date: December 2, 2008
24
25 Defendants respectfully submit this memorandum in opposition to Plaintiffs motion for
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3 conl1pl:3.mt reqUln~d
IS reqUln~d to rwn,uu,p
nrn'V1f'''' statement
pleadl~r IS emrue:a
denlied out
denlled
1 a
22 Not content with repeating them three times, for good measure, Plaintiff throws in a
23 fourth repetition of paragraph 29. See paragraph 144. Thoughtful repetition can be an effective
24 tool of advocacy. However, this is a pleading and we ought to observe some rules. (Other
25 paragraphs in the complaint are already repeated multiple times but they, thankfully, are not
26 before us.)
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1 c. Paragraph 148.
2 Paragraph 148 presents a slightly different issue. Paragraph 148 adds an allegation that
5 pres:ents
nresents a problern.
pf()bll~m.
preparing to dlsclo:se
reCluest to a
Hl~,lU'JHjl"" a Po:ssilbie
are IS no reason
21 been proposed earlier. At this point, there is no way to avoid prejudice to the Defendants. Either
22 we stay on schedule and Defendants have no meaningful opportunity to discover facts about this
23 new claim or we revise the scheduling order, extend discovery and continue the trial and,
27 contained in these two paragraphs add nothing to any claims already alleged.
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DEFENDANTS' MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION
TO PLAINTIFF'S MOTION FOR LEAVE TO FILE THIRD SUPPLEMENTAL COMPLAINT
Case 1:07-cv-00026-OWW-TAG Document 158 Filed 06/25/2008 Page 4 of 4
1 E. Paragraph 229.
2 Finally, paragraph 229 raises issues analogous to those raised by the proposed addition
3 par2lgralJh 1
paralgralJh alleges delamatlc)ll
c1elamatlcm a~~ainst
a~~amst
detam:atlcm
a delam.atlcm
sub!stalltial am'endment to
reasons, De:lerldants
Uetendarlt5 reQ1Uest
n~qllest
cause
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