My lawyer sent the following document to me yesterday for my approval, and I said, sure, why not? The legal fees are already staggering (this one can't be paid in Milk Bones) and I guess my only hope is to have the whole case dismissed. On the positive side, no other defendants have signed on to the case. Perhaps they aren't as upset by this whole thing as Ziggy, Bella, Runa and Troy seem to be. I actually thought that dogs would be amused by the silly antics cats get into.
Well, folks, if I suddenly stop blogging, you can assume that I've gone broke and had to sell my computer and turn off my internet connection. My lawyer assures me that it won't get to that point, and I guess I just need to trust the professionals.
________________________________________________
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW JERSEY
FOR THE DISTRICT OF NEW JERSEY
Ziggy
Bella
Runa Von HippleDePip
Troy Gilpin
Plaintiffs
v.
The Yarn Lady
Defendant
DEFENDANT THE YARN LADY’S MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM WITH RELEVANT SUBJECT MATTER JURISDICTION
COMES NOW, THE YARN LADY and files this Motion to Dismiss For Failure To State A Claim With Relevant Subject Matter Jurisdiction and respectfully shows:
SUMMARY OF GROUNDS FOR MOTION
1. This motion asks that this case be dismissed because 7 U.S.C. §§ 2131—2159 only addresses physical neglect of animals, including food water, sanitation and housing.
2. NJ Statute 4:22-26(c) only addresses food, shelter, protection from the elements and protection from inhumane conditions in a vehicle. Neither federal or state law requires parity in literary pursuits.
3. In addition, the blog entries written by The Yarn Lady promote affection for animals, whether wild or domesticated, and therefore could be considered supportive of conditions for said animals.
For the reasons cited in this Motion, The Yarn Lady requests that Plaintiff’s Complaint against Internet Unlimited be dismissed under Rule 12(b)(1), FED. R. CIV. P.
Respectfully submitted,
____________________________________
By: Cooper McKenna
Attorney-in-Charge
ATTORNEY FOR DEFENDANT
THE YARN LADY
2. NJ Statute 4:22-26(c) only addresses food, shelter, protection from the elements and protection from inhumane conditions in a vehicle. Neither federal or state law requires parity in literary pursuits.
3. In addition, the blog entries written by The Yarn Lady promote affection for animals, whether wild or domesticated, and therefore could be considered supportive of conditions for said animals.
For the reasons cited in this Motion, The Yarn Lady requests that Plaintiff’s Complaint against Internet Unlimited be dismissed under Rule 12(b)(1), FED. R. CIV. P.
Respectfully submitted,
____________________________________
By: Cooper McKenna
Attorney-in-Charge
ATTORNEY FOR DEFENDANT
THE YARN LADY
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