b. Defendants’
Motion Refers to No Facts Stated in the Pleadings
In addition to the wholesale fabrication of events,
Defendants’ Motion studiously avoids addressing any of the factual allegations
stated in the pleadings; nonetheless, they manage to admit to a state-created
danger, and a “special relationship” with the Firm in performance of a “public
function” which is “required by statute,” and the attendant assumption of
liability under Monell; as well as establishing
Bealmear’s liability in the racketeering predicate acts of extortion under color
of official right pursuant to 18 U.S.C. § 1951, and violent crime in aid of racketeering
pursuant to 18 U.S.C. § 1959.
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