The posture of this case arises in a context where for motion to dismiss purposes, the allegations contained in plaintiffs complaint are to be accorded great weight and deemed to be true.ÊÊ Yet, those allegations, and the voluminous substantiating information that plaintiff filed and relied on are not at all mentioned or acknowledged in the Memorandum Decision.
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The Memorandum Decision constitutes the opposite namely: the rejection of plaintiffs' facts - those that are among the precious few that are even mentioned, let alone assessed, still less considered to be true. This refers to plaintiffs' Request for Correction filed with the National Institute of Standards and Technology (NIST) on March 8, 2007.Īccordingly, therefore, the Memorandum Decision does not show how the conclusion ÷ "one of plaintiffs' asserted legal claims can withstand defendants' motions to dismiss" ÷ could possibly have been reached absent mention of them and absent acknowledgement of their being materially true. Morgan Reynolds is not challenging why the "World Trade Center buildings collapsed on 9/11." That is a clear misapprehension of his information.Įven more glaringly fundamental to this assertion of misapprehension of plaintiffs claim is the fact that the document that is specifically incorporated into the complaint that gave rise to plaintiffs assertions of fraud and that constitutes the very essence of the "information" upon which his status as a qui tam relator is based is not mentioned, not referenced, not even acknowledged to exist anywhere in the Memorandum Decision. "In separate actions, three different plaintiffs, who are all represented by the same attorney, commenced individual lawsuits attempting to challenge the investigative findings, of the National Institute of Standards and Technology ("NIST"), as to how and why the World Trade Center buildings collapsed on 9/11. 7Īllegations are even mentioned, let alone acknowledged for motions to dismiss purposes tobe true. New Hampshire Department of Employment Security ,Ĥ55 U.S. Paul Weiss Rifkind Wharton & Garrison LLP et al.Ģ008 U.S.
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Local 1, American Postal Workers Union, AFL-CIO,ġ994 U.S.