Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Save to My Library
Look up keyword
Like this
0Activity
0 of .
Results for:
No results containing your search query
P. 1
2:13-cv-05090 #30

2:13-cv-05090 #30

Ratings: (0)|Views: 12 |Likes:
Published by Equality Case Files
Doc 30 - Attorney General's motion to file replly in support of motion to dismiss
Doc 30 - Attorney General's motion to file replly in support of motion to dismiss

More info:

Categories:Business/Law
Published by: Equality Case Files on Nov 27, 2013
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

11/27/2013

pdf

text

original

 
 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA JONATHAN P. ROBICHEAUX, ET AL. * CIVIL ACTION NO. 13-CV-05090 * * * Versus * * JAMES D. CALDWELL, LOUISIANA * DISTRICT JUDGE: MLCF ATTORNEY GENERAL * * MAGISTRATE JUDGE: ALC * ******************************************************************************
ATTORNEY GENERAL’S MOTION FOR LEAVE TO FILE REPLY MEMORANDUM IN SUPPORT OF THE MOTION TO DISMISS FOR LACK OF JURISDICTION
NOW INTO COURT, through undersigned counsel, come the named Defendant, James D. “Buddy” Caldwell, in his official capacity as Attorney General of the State of Louisiana, who requests leave of court to file the attached reply memorandum in support of their motion to dismiss [Rec. Doc. No. 24]. 1.
 
The Plaintiffs filed an opposition to the Attorney General’s motion to dismiss on November 8, 2013 [Rec. Doc. No. 26]. 2.
 
The attached reply memorandum is submitted to respond to the Plaintiffs’ arguments and interpretations of law as set forth in the Plaintiffs’ opposition. 3.
 
The Attorney General maintains that this reply memorandum will assist the Court in its consideration of the arguments raised in the motion to dismiss.
Case 2:13-cv-05090-MLCF-ALC Document 30 Filed 11/25/13 Page 1 of 2
 
 2 WHEREFORE, the Attorney General requests leave of court to file the attached reply memorandum in support of their motion to dismiss [Rec. Doc. No. 24] in the above captioned matter. RESPECTFULLY SUBMITTED,
James D. “Buddy” Caldwell
ATTORNEY GENERAL  /s/ Jessica MP Thornhill_____________ Angelique Duhon Freel (La. Bar # 28561) Jessica MP Thornhill (La. Bar #34118) Assistant Attorneys General Louisiana Department of Justice Civil Division P. O. BOX 94005 Baton Rouge, Louisiana 70804-9005 Telephone: (225) 326-6060 Facsimile: (225) 326-6098 Email: thornhillj@ag.state.la.us freela@ag.state.la.us
 Attorneys for James D. Caldwell, in his official  capacity as Louisiana Attorney General
CERTIFICATE OF SERVICE
I hereby certify that I have served upon Plaintiff’s counsel of record a copy the foregoing Memorandum, properly addressed and with proper postage prepaid this 25th day of November 2013. _/s/ Jessica Thornhill__ Jessica MP Thornhill
Case 2:13-cv-05090-MLCF-ALC Document 30 Filed 11/25/13 Page 2 of 2
 
UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA JONATHAN P. ROBICHEAUX, ET AL. * CIVIL ACTION NO. 13-CV-05090 * * * Versus * * JAMES D. CALDWELL, LOUISIANA * DISTRICT JUDGE: MLCF ATTORNEY GENERAL * * MAGISTRATE JUDGE: ALC ******************************************************************************
THE ATTORNEY GENERAL’S REPLY MEMORANDUM IN SUPPORT OF MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION
MAY IT PLEASE THE COURT, through undersigned counsel, comes James D. “Buddy” Caldwell, in his official capacity as Attorney General of the State of Louisiana, who adopts in extension those arguments raised in his Memorandum in Support of the Motion to Dismiss for Lack of Subject Matter Jurisdiction
1
 filed on November 6, 2013 and further replies to the Plaintiffs’ “Memorandum in Opposition to the Attorney General’s Motion to Dismiss for lack of Subject Matter Jurisdiction.”
2
 The Attorney General again appears solely for the purpose of asserting the lack of subject matter jurisdiction. He specifically reserves and retains any and all rights and privileges available to him to file motions to dismiss on alternative grounds, raise affirmative defenses not now asserted, and/or contest the substance and merit of Plaintiffs’ constitutional claims including their request for injunctive relief.
I. LAW AND ARGUMENT
The Plaintiffs’ opposition memorandum fails to set forth the necessary material to support the application of the narrow
 Ex Parte Young
 exception to the Attorney General. Despite the
1
 Rec. Doc. 24.
2
 Rec. Doc. 26.
Case 2:13-cv-05090-MLCF-ALC Document 30-1 Filed 11/25/13 Page 1 of 6

You're Reading a Free Preview

Download
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->