Professional Documents
Culture Documents
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MEMORANDUM
COMES NOW, Plaintiff, by counsel and unto this
Honorable Court, respectfully submits this memorandum in
compliance with the Order dated September 20, 2017 by the
Honorable Court, which was received by the undersigned
counsel on October 18, 2017, directing the parties to submit
their respective memoranda, within fifteen days from the
receipt of such order, or until November 2, 2017, on the issue
on whether or not the complaint should be dismissed outright
on the basis of the affirmative defenses raised in the Answer,
to wit:
Arguments
As to fourth issue