Motion Pattern Analytics

the motion to dismiss will narrow the scope of the suit and may eliminate claims or the defendant from the matter.

requiring defendant to engage in discovery prior to a ruling on the motion to dismiss would be unnecessarily burdensome and expensive.

plaintiff's amended complaint fails to plead sufficient facts to state a claim for relief, as defendant is a non-jural entity and plaintiff failed to allege an official policy or proper ada accommodat

I. BACKGROUND -> II. ARGUMENT AND AUTHORITIES -> III. PRAYER -> CERTIFICATE OF CONFERENCE -> CERTIFICATE OF SERVICE

UNITED STATES DISTRICT COURT -> EMERGENCY MOTION FOR PROTECTIVE CUSTODY -> TO THE HONORABLE MAGISTRATE JUDGE OF THE -> DECLARATION OF MENTAL DISABILITY AND LEG

plaintiff's response to the motions to compel arbitration and motion to join was untimely and should be taken as unopposed.

the court has subject matter jurisdiction, which is a prerequisite to enforcing arbitration clauses, and defendants are not judicially estopped from compelling arbitration.

plaintiff's claims, including dtpa and fraud, are related to the purchase agreement and loan agreement, allowing vivint defendants (as nonsignatories) to enforce the arbitration clauses via equitable

plaintiff did assert a breach of contract claim against vivint related to the purchase agreement and loan agreement.

plaintiff's 'non-contractual' claims are rooted in the purchase agreement and loan agreement, and the grigson equitable estoppel doctrine applies.

Moses H. Cone Mem'l Hosp. v. Mercury Constr. Corp., 460 U.S. 1, 24, 103 S. Ct. 927, 941, 74 L. Ed. 2d 765 (1983)

Colorado River Auth. v. Papalote Creek II, L.L.C., 858 F.3d 916, 923 (5th Cir. 2017)

Vaden v. Discover Bank, 556 U.S. 49, 59, 129 S. Ct. 1262, 173 L.Ed.2d 206 (2009)

Grigson v. Creative Artists Agency L.L.C., 210 F.3d 524, 527 (5th Cir. 2000)

Amegy Bank Nat. Ass'n v. Monarch Flight II, LLC, 870 F. Supp. 2d 441, 451 (S.D. Tex. 2012)

I. INTRODUCTION -> II. ARGUMENTS & AUTHORITIES -> A. PLAINTIFF UNTIMELY FILED HER RESPONSE -> B. SUBJECT MATTER JURISDICTION IS A PRER -> C. PLAINTIFF'S CLAIMS, INCLUDING HER DTP -> 1. PLAINTIFF DID ASSERT A BREACH OF CONT -> 2. PLAINTIFF'S “NON-CONTRACTUAL” CLAIMS -> D. THE VIVINT DEFENDANTS DID NOT WAIVE A

contract

prior_court_order

defendant admitted to violating title ix by allowing its investigator to usurp the role of the decision-maker.

defendant admitted to withholding material evidence of witness bias from john doe, violating title ix regulations.

sex was a motivating factor behind prairie view's disciplinary investigation and expulsion of john doe.

prairie view engaged in selective enforcement of title ix by failing to investigate retaliation against john doe while applying the policy against him.