Motion in Opposition to Motion to Dismiss Julian Marcus Raven v. Smithsonian Kim Sajet, Dr. Kurin

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United States District Court For The District of Columbia November 26th, 2017 Julian Marcus Raven ) plaintiff ) ) v. ) Hon. Judge McFadden ) #17-­‐cv-­‐01240-­‐TNM Kim Sajet, Richard Kurin Et Al. ) defendants )

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Motion: Opposition to Defendants Motion To Dismiss

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To the honorable Judge McFadden, in the interest of Justice, plaintiff ‘pro se’ Julian

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Marcus Raven, motions the court to immediately DENY Defendants’ Motion to

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Dismiss Plaintiff’s Amended Complaint that is before the Court for the following

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reasons:

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Please find attached Plaintiff’s Memorandum of Law and Authorities in support of

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this motion to DENY Defendant’s Motion to Dismiss on multiple grounds.

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The premise upon which Defendants construct their Memorandum of Law in

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support of Defendants’ Motion to Dismiss is ‘fatally flawed.’

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Defendants selectively leave out essential factual claims. Steering clear from these

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essential facts allows Defendants to create their theory for their defense that is

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‘fatally flawed.’

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