|Christian Behrend Doscher: "Incumbent Upon the Plaintiff"|
DECEMBER 17, 2018
The featured item today is a response my attorney wrote to Doscher's motion demanding sanctions because our motion to dismiss was frivolous. I believe Doscher uses such motions to get a sort of "sneak preview" of how to answer the motion and improve his own response. My attorney had none of that, and he produced what I consider to be his best-crafted sentence in all the documents he wrote: "If plaintiff believes that facts relevant to the underlying question of jurisdiction were cited incorrectly or excluded, it seems incumbent upon plaintiff to cogently articulate this belief in a well-reasoned responsive brief."