…if this Court does find Wilson’s Amended Complaint deficient in any respect Wilson respectfully prays that he be given opportunity to amend his complaint to cure whatsoever deficiencies the Court might find.
While team Wilson was praying Judge Hittner would prescribe a cure, Defendant Steve Patterson’s attorney, Hiram Eastland, filed a Rebuttal declaring the deficiencies fatal.
Plaintiff’s opposition fails to resolve any of the shortcomings addressed in Mr.Patterson’s Motion to Dismiss. From denying the existence of a heightened pleading standard for fraud, to reiterating the same legally insufficient factual allegations, Wilson can point to nothing that would save his complaint from dismissal.
After finding there was “nothing that would save” Wilson’s complaint, Eastland eviscerated Wilson’s Opposition to Patterson’s Motion for Dismissal.
Plaintiff has failed to shed any new light on his Amended Complaint that would allow it to endure against Mr. Patterson. All of the fatal flaws that are reiterated in this reply exist for a reason: this is simply not a RICO case.
Eastland’s arguments, while specific to Patterson, have implications for other defendants and/or other litigation,, particularly those where the distinction between unethical and unlawful conduct has been blurred : Continue reading “Is there a doctor in the court? Patterson”