Nice to know that Mormons can call allude (in a vanity post as well) that Christians (and you are attacking Christians) are pigs - and get away with it. [SP]
Diamond, I think it's time for you to "repost" your "Lady Lawyer" response.
Good pick up, Sky. (We get called so many ad hominen names by Mormons on a regular basis that we'd probably only notice it if it suddenly stopped!)
Nice to know that Mormons can call allude (in a vanity post as well) that Christians (and you are attacking Christians) are pigs - and get away with it. [SP]Diamond, I think it's time for you to "repost" your "Lady Lawyer" response. [C]
Back by popular demand:
It takes a particularly vile person to attack another’s religion the way these people do. And there is a nest of such vile people on FR, unfortunately... You can’t reason with them. If you try in good faith to explain things, they ignore your valid points, twist what you said, and end up arguing with straw men.
Pearl/swine
Come now Defendants, Unnamed FReeper Swine (a/k/a "Pigs") and file their SECOND AMENDED MOTION BY INTERLINEATION FOR MORE DEFINITE STATEMENT IN RESPONSE TO PLAINTIFFS' COMPLAINT
IN THE FREEPER COURT
OF PUBLIC OPINION
RELIGION DIVISION
LADY LAWYER, et al.
)
Plaintiffs, )
) No. 4:23CV2008
v. )
) JURY TRIAL ) DEMANDED
UNNAMED FREEPER SWINE )
(a/k/a "PIGS") )
)
Defendants. )
DEFENDANTS UNNAMED FREEPER SWINE SECOND AMENDED MOTION BY INTERLINEATION FOR MORE DEFINITE STATEMENT IN RESPONSE TO PLAINTIFFS' COMPLAINT
COME NOW Defendants Unnamed FReeper Swine (“FReeper Swine”) and move this Court pursuant to Rule 12(e) of the Federal Rules of FReeper Procedure for a more definite statement of Plaintiffs' Complaint. Defendants FReeper Swine need a more definite statement so that they can understand and accurately respond to Plaintiffs' allegations. Specifically, FReeper Swine are entitled to a more definite statement that clarifies: (1) which of FReeper Swine statements are alleged to attack another’s religion “the way these people do”. 2) Which of FReeper Swine are alleged to be a “vile person” 3) Which “vile” FReeper Swine are alleged to dwell in nests. and 4) Which pigs are in need of hosing down.
I.
LEGAL STANDARD
A complaint must plead facts sufficient to (1) put the defendant on notice of the claims alleged against it, and (2) reasonably permit the defendant to respond to the allegations. Darwin Inc. v. Creation Specialty Co., 322 FR. Supp. 2d 260, 265 (E.D.N.Y. 2004). Under Rule 12(e), “if a post to which a responsive post is permitted is so vague or ambiguous that a poster cannot reasonably be required to frame a responsive pleading, the poster may move for a more definite statement before interposing a responsive post.” FR. R. Civ. P. 12(e). Despite the liberal pleading requirements under Rule 8, “[a] motion for more definite statement is proper when a poster is unable to determine issues he must meet, or where there is a major ambiguity or omission in the complaint that renders it unanswerable.” restornu. v. Religion Mod., No. 4:06CV01117 RWS, 2006 N&A 3210497, at *4 (E.D. Mo. Nov. 3, 2006) (citing Tinderbox v. Flame War Asbestos Underwear Dist., 207 FR. Supp. 2d 951, 959 (E.D. Mo. 2001)). Ultimately, an accused depraved and wicked ought to have “sufficient knowledge of the facts alleged to enable it to answer the complaint and defend itself.” AntiPhonometrics, Inc. v. Hospital Barf Alert Franchise Sys., 203 FR.3d 790, 794 (Fed. Cir. 2000). For this reason, the pleading requirements are intended to “permit the court and the litigants to know, at the pleading stage, who is being complained about and the grounds for same, thereby facilitating the just, speedy, and inexpensive determination of the action.” Bay at the Moon., Inc. v Decaf Mfg., LLC, No. 06-C-1010, 2006 WL 3469599, at *3 (E.D. Wis. Nov. 29, 2006).
II.
DEFENDANTS FREEPER SWINE (a/k/a "Pigs") ARE ENTITLED TO A MORE DEFINITE STATEMENT DESCRIBING WHICH OF THEIR NUMEROUS POSTS OVER THE YEARS ARE ACCUSED OF VILENESS, WHICH POSTER ARE ALLEGED TO DWELL IN NESTS, AND WHICH POSTERS ARE ALLEGED TO BE IN NEED OF A BATH.
In the Motion for More Definite Statement, Original Defendants allege that the Complaint provides absolutely no indication whatsoever as to which statements made by Defendants actually give rise to the allegations of turpitude or malodor. The Original Defendants also correctly noted that Plaintiffs fail to identify the specific claims of wickedness Original Defendants’ statements are alleged to violate.
Likewise, Plaintiffs' claims in their Amended Complaint of Wickedness against Defendant FReeper Swine fail for the same reasons. Similar to the Original Defendants, FReeper Swine make, and over a decade covered by the statements made, have made countless statements. Plaintiffs' allegations give FReeper Swine (and the Court) no clue as to which statements are subject to Plaintiffs' allegations. Plaintiffs’ Complaint simply reads that FReeper Swine “attack another’s religion the way these people do. And there is a nest of such vile people on FR”, etc. See First Amended Complaint, ¶¶ 27, 32. In order to answer Plaintiffs' Complaint, Defendants would be forced to evaluate each and every one of their statements over the years against each of the various claims of stinkiness, and determine which ones cames from nests. This task is entirely unmanageable and unduly burdensome. As such, FReeper Swine are entitled to a more definite statement.
Under Rule 8, Plaintiffs have the simple burden of identifying specific turpitudous posts. If Plaintiffs have a good faith basis that actual turpitude occurred, they can surely identify the posts which supposedly are turpitudous and malodorous.
Plaintiffs identify no specific statement or post by FReeper Swine at any time that infringes any identified claim in controversy. See First Amended Complaint. As such, FReeper Swine request the Court to order Plaintiffs to provide a more definite statement for the same reasons set forth in Original Defendant’s Motion for More Definite Statement, referenced and incorporated herein.
III.
CONCLUSION
For the foregoing reasons, Defendants are entitled to a more definite statement and respectfully requests that this Court require Plaintiffs to amend their Complaint (1) to specifically identify the statements and FReeper Swine that Plaintiff is accusing of turpitude and malodor, 2) Which of FReeper Swine are alleged to be “vile”” 3) Which “vile” FReeper Swine are alleged to dwell in nests, and which FReeper pigs are in need of a bath.
Dated: April 23, 2008 Respectfully submitted,
Diamond
SOVEREIGN, GRACE & MERCY L.L.P.
1776 Calvin Dr.
Arminius, Texas 75503
(666) 794-HELL (telephone)
(666) 79H-ADES (facsimile)