UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MASSACHUSETTS

Springfield Division

KHALID DRIHMI, et al.,

Plaintiffs,

PLAINTIFF KHALID DRIHM

Accused.

NOTICE TO COURT REGARDING

DISMISSAL OF MOTION FILED BY LITTLE CAESAR ENTERPRISES INC

INTRODUCTION

Defendant KHALID DRIHM hereby requests that the motion filed by defendant LITTLE

CAESAR ENTERPRISES INC "motion to dismiss" [Dkt. No. 17] questioning my standing to pursue

the claims against Little Caesar. Khalid Drihmi's Chapter 7 bankruptcy case has been closed,

restoring his position. However, all of Khalid Drihmi's remaining arguments on why the motion

should be dismissed remain valid.

I. BACKGROUND
Defendant Little Caesar Enterprises, Inc. filed its Motion to Dismiss Plaintiffs' Complaint

on September 29, 2021 [Dkt. No. 10], arguing that this action should be dismissed in accordance

with the inherent authority of the Court to exercise discretion over its file, dismissing a claim for

duplication; We fervently deny that there is a duplication claim and the defendant did not provide

sufficient evidence to validate this claim.

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Alternatively, the motion moves the Court to dismiss the action regarding plaintiff Abdel Drihmi

because, among other things, he lacks standing to pursue his claims in light of his Chapter 7

bankruptcy. This is due to the fact that Abdel Drihmi did not reveal his allegations against Litle.

Cesar in his bankruptcy case. Bankruptcy Petition, In re Abdel Drihmi Ch. 7 Bankruptcy, Case

No. 3: 20-bk-30499 (October 8, 2020 Bankr. D. Mass.) [Dkt. No. 1].

Chapter 11 of the Bankruptcy Law of the United States allows companies in the United States

with financial problems to reorganize under the protection of the law. Although Chapter 11 is

also valid for individuals, it is often used for businesses. On the other hand, Chapter 7 regulates

the introduction of bankruptcy by liquidation and Chapter 13 applies to most individuals. As

indicated in Chapter 11 of the Bankruptcy Law “allows companies in the United States with

financial problems to reorganize under the PROTECTION of the law, if Your Honor, under the

Protection, a Bankruptcy situation cannot be used as a preliminary judgment. of the plaintiff,

does not excuse this situation the responsibility of the defendant LITTLE CAESAR

ENTERPRISES INC.

Khalid Drihmi, on the other hand, revealed his claims against Little Caesar in his bankruptcy

case after Little Caesar objected to the confirmation of his Chapter 13 plan. Amended Summary

of Assets and Liabilities, In re Khalid Drihmi Ch. 7 Bankruptcy , Case No. 5: 20-bk-

31144 (Bankr. NDNY) [Dkt. No. 35]. In its Supplemental Memorandum ofILaw in support of Little

Caesar notified the Court of its motion to dismiss the conversion of plaintiff Khalid

Drihmi's bankruptcy to a Chapter 7 case, which also deprived him of standing. As indicated

above, I cannot hold the legitimacy of a plaintiff for a Bankruptcy situation, we fervently deny,

this point presented by the defense.

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The bankruptcy administrator never filed a formal notice dropping Khalid Drihmi's claims against

Litle Caesar. On August 25, 2021, the US Bankruptcy Court for the Northem District of New York

granted a discharge to Khalid Drihmi, and on September 10, 2021, he issued a Final Decree and

closed the bankruptcy case. In re Khalid Drihmi Ch. 7 Bankruptcy, Case No. 5: 20-bk-31144

(Bankr. NDNY) [Dkt. Nos. 66, 68].

II. DISCUSSION
The defendant, in a desperate last minute action, tries to close this case by filing a motion

which has no solid legal basis, LITTLE CAESAR ENTERPRISES INC. It tries to cling to arguments

such as “duplicate counterclaim”, “lack of legitimation due to Bankruptcy”, they even try to modify

the jurisdiction trying to get rid of the responsibilities that weigh on their shoulders in a very precarious

way, without presenting a solid proof of What they indicate, without presenting solid jurisprudence of

situations that could be taken as an example, here your Honor, The reality is all the regret, suffering,

anguish, that the plaintiff has had to go through KHALID DRIHM, the reality is the discriminatory and

fraudulent acts that took place and that led the plaintiff to this extreme situation of loss of home, loss

of investment, of the mental anguish that he suffered and even today continues to suffer, the unfair

and deceptive commercial practices that result in fraud, in foreclosure, in home loss; Your Honor, you

consider that a United States citizen, acting lawfully, adhering to the tax laws, whose sole purpose was

to work and progress in this country, may, by filing a motion WITHOUT GROUNDS, lose his opportunity

to claim, lose your right to equality before the law, we know, your honor, that this will not be the case,

we know, your honor, that you will not allow it.

Finally, your Honor, and if we may, report that our fundamentals, by sound assumptions, are

based and affirmed on the magnanimous laws of the United States, but also on the reports

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of private federal investigators, which I mention below and that have been presented in a timely manner:

1) We have affidavits and canceled checks that we were forced to bribe directors to do business

with.

2) We have proof of prepaid checks paid to blue line of merchandise for three years, which was a

Little Caesars tactic, and they even rejected merchandise within that time frame.

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 CONCLUSION
For the reasons stated above, KHALID DRIHM withdraws its request to dismiss the

motion presented by LITTLE CAESAR ENTERPRISES INC, the Lawsuit in this matter must

continue until the corresponding judgment is issued, which is the only way that justice will be

served.

Respectfully,

Celli Marcos Ariel Attorney

Direction:

Attorney Miami Office

550 SW 69th Av.
Miami, FL 33144

dr.cellimarco@gmail.com

Date: October 12, 2021 Lawyer of KHALID DRIHM.

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 SERVICE CERTIFICATE
I hereby certify that this document was submitted through the CM / ECF system and
that paper copies will be sent by first class mail from the U.S. Postal Service on October 13,
2021 to those listed as non-participants. registered and electronic copies will be sent to the
email address. provided by the Plaintiffs as their contact address in their Complaint: