Mateo, thank you for your constructive criticism/feedback. Literally all my school report cards since First Grade said, "Michael is a bright boy, but he cannot accept constructive criticism." With maturity, I have improved and developed a more open mind.
I took a screen shot of your well drafted comment on my phone so that I have your points handy when I prepare the formal/final filing. What I posted here was the initial draft memorandum that I prepared last night. I will be editing before a formal filing with my name on it is sent to San Fransisco.
Your reference to a meaty intro/conclusion is well-taken. This was written as a memo forming the basis of the Complaint, but usually when I write Briefs, there is a preliminary statement summing up what this is about in a sentence or two.
If you think the contention is a stretch or that her reference did not imply to you what it implies to myself and others, that is perfectly fine. Reasonable minds can reasonably differ in their perceptions and conclusions on a whole host of things.
Just because a contention is not 100% ironclad across the board, does not mean that the contention is without merit or not worth bringing. As a lawyer who has filed multiple judicial DQ motions throughout my career, and as counseled against filing even more non-meritorious DQ motions, I feel there is merit here, and I intend to proceed.
In closing, I share my favorite quote from Donald Sutherland as Mr. X advising Jim Garrison in JFK:
"Stir the shit storm, hope to reach a point of critical mass that'll start a chain reaction of people coming forward, and then the government will crack."
I intend to stir the shit storm in support of a righteous cause, not only on my behalf, but on behalf of all others similarly situated, including yourself. It is what I do.
