Re: [Vo]:Another motion filed in Rossi suit

2016-07-05 Thread Jed Rothwell
a.ashfield wrote: So why did you make the claim if you don't know? > I do know, but I have agreed not to discuss details which has not been made public by Rossi or I.H., so I cannot discuss specifics. If you would like to learn more, you must contact them. > On

Re: [Vo]:Another motion filed in Rossi suit

2016-07-05 Thread a.ashfield
So why did you make the claim if you don't know? On 7/5/2016 6:26 PM, Jed Rothwell wrote: a.ashfield > wrote: I've asked you for a reference to confirm what happened several times and you have not answered it. Who was the

Re: [Vo]:Another motion filed in Rossi suit

2016-07-05 Thread Jed Rothwell
a.ashfield wrote: > I've asked you for a reference to confirm what happened several times and > you have not answered it. > Who was the customer? > When was the offer? > What was the offer? > You need to ask Rossi or I.H. If Rossi responds, you may find he is not

Re: [Vo]:Another motion filed in Rossi suit

2016-07-05 Thread a.ashfield
Stephen, I neither know nor care about the details of Jed's relationship with Rossi. I recall that he fell out with him some time ago. Jed maybe an expert but he wasn't there and is relying on second hand information, so it doesn't matter. He claims the instrumentation was bad/unsuitable

Re: [Vo]:Another motion filed in Rossi suit

2016-07-05 Thread a.ashfield
Jeds, "It is obvious IH were stalling for time. Do you really believe they could not find a customer in a year? They found a customer. Rossi rejected that customer in favor of his own pretend company." I've asked you for a reference to confirm what happened several times and you have not

Re: [Vo]:Another motion filed in Rossi suit

2016-07-05 Thread Stephen A. Lawrence
On 07/05/2016 04:06 PM, Jed Rothwell wrote: a.ashfield > wrote: Jed, When you start with certainty that Rossi is a fraud all becomes clear to you. I did not start with that idea. On the contrary, as you see in the quote from me

Re: [Vo]:Another motion filed in Rossi suit

2016-07-05 Thread Jed Rothwell
a.ashfield wrote: Jed, When you start with certainty that Rossi is a fraud all becomes clear > to you. > I did not start with that idea. On the contrary, as you see in the quote from me ending Lewan's book, I started with the assumption that his claims are real. I now

Re: [Vo]:Another motion filed in Rossi suit

2016-07-05 Thread a.ashfield
Jed, When you start with certainty that Rossi is a fraud all becomes clear to you. Someone will always come up with a scheme about how Rossi cheated on any test. Craig is right. Far better to leave the judgement to an unbiased expert. Even then some will doubt it, as we now see. It is

Re: [Vo]:Another motion filed in Rossi suit

2016-07-05 Thread Jed Rothwell
Craig Haynie wrote: > If I were Rossi, what I would want is an independent evaluation of the > device, from which, neither side could dispute the results. > He did not do that. On the contrary, his test was a farce. It was as bad as his previous tests. Anyone with

Re: [Vo]:Another motion filed in Rossi suit

2016-07-05 Thread Lennart Thornros
Craig, I like your analysis. Therefore I think any statements in regards to technial,legal and moral status is very disturbing. Personal judgment based on the situation is just slander. I am not a betting man, but I think the odds are reversed. On Jul 4, 2016 20:13, "Craig Haynie"

Re: [Vo]:Another motion filed in Rossi suit

2016-07-04 Thread Craig Haynie
On 07/03/2016 08:25 PM, Jed Rothwell wrote: a.ashfield > wrote: But I have reason whatsoever to believe that somebody's idea of how Rossi could cheat was actually implemented. Yes, you do have a clear idea. The person who told

Re: [Vo]:Another motion filed in Rossi suit

2016-07-04 Thread Lennart Thornros
Jed (from your kill list), I think people are entitled to be believed until proven wrong. You are spewing your 'wisdom; as if you were the only one with a right to be believed. Whatever is the result IH has handled this poorly. One could expect better from an investor of their size. I am

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread Jed Rothwell
a.ashfield wrote: Jed we have been through this twice already. I do not find anything Rossi > has said shows that he was cheating. > There are none so blind as those who will not see. You have no idea what machinery was in the J M Products' plant although you > also

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread a.ashfield
Jed we have been through this twice already. I do not find anything Rossi has said shows that he was cheating. The agreement at the start of the trial was that no one from IH should visit J M Products, nor that anyone from J M Products was allowed to visit the 1 MW plant. Presumably both had

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread Jed Rothwell
a.ashfield wrote: > But I have reason whatsoever to believe that somebody's idea of how Rossi > could cheat was actually implemented. > Yes, you do have a clear idea. The person who told you how Rossi cheats is Rossi himself. He said refused to allow anyone into his

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread a.ashfield
Jack, " You give AR the benefit of the doubt, but everyone else gets the doubt. " I said I didn't know if Rossi was right. But I have reason whatsoever to believe that somebody's idea of how Rossi could cheat was actually implemented. Even the author didn't say it was. All the recent anti

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread Jack Cole
I understand Adrian. You give AR the benefit of the doubt, but everyone else gets the doubt. "AR says" carries more weight in your opinion than Jed, the people Jed has talked to who have seen the data, Dewey Weaver, and IH. Multiple sources say the swapped out flow meter was inappropriate, so

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread a.ashfield
Jones Beene, AA "Rossi was right when he forecast that no test would ever be accepted but it would take the sale of working commercial reactors to quiet the critics." JB. Rossi was right, was he? LOL. That is you informed opinion?" AA. Is that really the best you can do? Pray tell me what

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread a.ashfield
Jack, I give Rossi the benefit of the doubt, until proven otherwise. As I said, I don't know, but neither do the skeptics. If you don't think there have been wild flights of imagination you have not been following the story. GG's analysis means nothing: it is just another possible way of

RE: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread Jones Beene
From: a.ashfield Rossi was right when he forecast that no test would ever be accepted but it would take the sale of working commercial reactors to quiet the critics. Rossi was right, was he? LOL. That is you informed opinion? Then tell us why the skeptics aren’t they quiet now – since Rossi

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread Jack Cole
"I have no reason to think Dewey Weaver is a credible witness. I don't know what happened and am quite willing to wait for solid facts. The pathological skeptics jump on every wild flight of imagination and state that is what happened, while in fact being clueless. Rossi was right when he

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread a.ashfield
I have no reason to think Dewey Weaver is a credible witness. I don't know what happened and am quite willing to wait for solid facts. The pathological skeptics jump on every wild flight of imagination and state that is what happened, while in fact being clueless. Rossi was right when he

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread a.ashfield
What "fabrications of a delusional career criminal"? You just repeated what Goatguy said without an iota of evidence to show it was true, writing that that was what happened. So no, you haven't "got this straight." On 7/3/2016 12:49 PM, Jones Beene wrote: So let me see if I’ve got this

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread Jack Cole
"Your bias is showing again. Goatguy suggested a possible method to scam the results and then you take it as read that that was done. Really?" It is altogether possible that he was not so clever as GG thinks, as Jed suggests, but could have still taken advantage of the design flaw noted by GG.

RE: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread Jones Beene
So let me see if I’ve got this straight. It’s not biased to the repeat the fabrications of a delusional career criminal, and to persist with non-stop trolling of this “Rossi says” crap, but it is biased for anyone else to comment on the most likely way he pulled off the latest scam? From:

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread a.ashfield
Jed, You never replied to my request for a reference confirming what you said that IH offered a customer but Rossi turned it down. On 7/3/2016 11:16 AM, Jed Rothwell wrote: Jones Beene > wrote: Basically,in the center of the “reactor

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread a.ashfield
There you go again. IH was not allowed in the building but you claim there was nothing there, based on what IH told you. To think that IH could discern anything from an IR reading of the building walls is really pathetic. Jed. "If that were the case, the waste heat would be easily

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread a.ashfield
he sensors or the instrumentation reading them. That does not mean that was what happened either. On 7/3/2016 10:45 AM, Jones Beene wrote: RE: [Vo]:Another motion filed in Rossi suit *From:*Jed Rothwell Someone pointed out to me that at such low temperatures, you would probably use the hot flu

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread Jed Rothwell
Jones Beene wrote: > Basically, in the center of the “reactor shelter” is a box labeled “water > reservoir” which has 2 inlets and 2 outlets. > > Inlet 1, top = tap water from municipal line > > Inlet 2, bot = return from steam condensers > > Outlet 1, top = water to first

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread Jed Rothwell
a.ashfield wrote: As far as I know, nobody has any idea what was in the customer's equipment. > Nothing was in there. I.H. and others used various methods to look for heat from the customer site. They found no trace of it. There was no equipment using a detectable level

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread a.ashfield
As far as I know, nobody has any idea what was in the customer's equipment. Presumably it started as steam and the condensate was later returned to the 1 MW plant at varying temperatures. The implication is that the customer's side was less than 60C. On 7/3/2016 9:38 AM, Jed Rothwell wrote:

RE: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread Jones Beene
From: Jed Rothwell Someone pointed out to me that at such low temperatures, you would probably use the hot fluid to heat the equipment directly before returning it, rather than going through a heat exchanger. - Jed Didn’t you see the post on NBF from GoatGuy - which nails the easy way to

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread Jed Rothwell
a.ashfield wrote: Jed, "Correction: With a counterflow heat exchanger, the cold fluid will > be an average temperature somewhere between 104 and 60 deg C." > What cold fluid are you talking about? > The warm fluid and cold fluid in the heat exchanger. Someone pointed

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread a.ashfield
Jed, "Correction: With a counterflow heat exchanger, the cold fluid will be an average temperature somewhere between 104 and 60 deg C." What cold fluid are you talking about? I thought we were told the return temperature to the 1 MW plant varied but was typically ~60C. Because it varied it

Re: [Vo]:Another motion filed in Rossi suit

2016-07-03 Thread a.ashfield
The steam pressure would be closer to 2 psig at 104. What you discount is that the temperature would have been higher if the pressure needed to be higher. It is not unreasonable to assume 2 psi was all that was needed with the outlet pipe size used. Remember that Rossi used a stethoscope

Re: [Vo]:Another motion filed in Rossi suit

2016-07-02 Thread Jed Rothwell
I wrote: > The fluid leaving Rossi's reactor room was just above 100 deg C. Returning > it was at 60 deg C. That is what Rossi told Lewan. The reservoir remained > level so it was the same water looping around. So if there was any process > heat in the next room, it came from a heat exchanger

Re: [Vo]:Another motion filed in Rossi suit

2016-07-02 Thread Jed Rothwell
a.ashfield wrote: > Jed. "The fluid leaving Rossi's reactor room was just above 100 deg C. " > Other sources say the temperature was ~104C in which case it would > probably be steam. > Not if there is any pressure. Which I am sure there was. 104 deg C = 219 deg F. 3

Re: [Vo]:Another motion filed in Rossi suit

2016-07-02 Thread a.ashfield
Jed. "I.H. did find a customer, but Rossi rejected that customer in favor of a fake company that he and his lawyer owned." Reference please. Jed. "The fluid leaving Rossi's reactor room was just above 100 deg C. " Other sources say the temperature was ~104C in which case it would probably

Re: [Vo]:Another motion filed in Rossi suit

2016-07-02 Thread Axil Axil
Section 16.9 of the licence agreement allows for a party to suspended the agreement if any provision of the agreement is violated by the other party. On Fri, Jul 1, 2016 at 5:12 PM, Bob Higgins wrote: > I am not a lawyer. However, I believe at this moment Rossi has a

Re: [Vo]:Another motion filed in Rossi suit

2016-07-02 Thread Jed Rothwell
a.ashfield wrote: > Whatever the heat use by the customer, the arrangement was only made > because IH had failed to provide the customer for over a year that they > said they would. > I.H. did find a customer, but Rossi rejected that customer in favor of a fake company

RE: [Vo]:Another motion filed in Rossi suit

2016-07-02 Thread Bob Cook
for appropriate likes to troll comments posted in recognition to the orchestrated other-troll comments. Bob Cook From: Russ George<mailto:russ.geo...@gmail.com> Sent: Saturday, July 2, 2016 8:27 AM To: vortex-l@eskimo.com<mailto:vortex-l@eskimo.com> Subject: RE: [Vo]:Another motion filed i

RE: [Vo]:Another motion filed in Rossi suit

2016-07-02 Thread Russ George
To: vortex-l@eskimo.com Subject: Re: [Vo]:Another motion filed in Rossi suit Jones Beene, You make several assumptions that are far from proven. Whatever the heat use by the customer, the arrangement was only made because IH had failed to provide the customer for over a year that they said

Re: [Vo]:Another motion filed in Rossi suit

2016-07-02 Thread a.ashfield
RE: [Vo]:Another motion filed in Rossi suit *From:*Bob Higgins It is interesting and self-destructive that Rossi appears to have unilaterally declared that the license sold to IH is null and void. Having accepted money for that license, he is in a legally binding contract. Yet Rossi seems int

RE: [Vo]:Another motion filed in Rossi suit

2016-07-02 Thread Jones Beene
From: Bob Higgins It is interesting and self-destructive that Rossi appears to have unilaterally declared that the license sold to IH is null and void. Having accepted money for that license, he is in a legally binding contract. Yet Rossi seems intent to market that license to others as

RE: [Vo]:Another motion filed in Rossi suit

2016-07-01 Thread Bob Cook
tps://go.microsoft.com/fwlink/?LinkId=550986> for Windows 10 From: a.ashfield<mailto:a.ashfi...@verizon.net> Sent: Friday, July 1, 2016 4:14 PM To: vortex-l@eskimo.com<mailto:vortex-l@eskimo.com> Subject: Re: [Vo]:Another motion filed in Rossi suit Bob, So you say, but it is not that si

Re: [Vo]:Another motion filed in Rossi suit

2016-07-01 Thread a.ashfield
Another explanation is that this will give him to get one of more commercial reactors operating before the trial. Rossi says he is having at least one 1MW plant being built in America at present. On 7/1/2016 7:47 PM, Eric Walker wrote: On Fri, Jul 1, 2016 at 5:31 PM, Bob Higgins

Re: [Vo]:Another motion filed in Rossi suit

2016-07-01 Thread a.ashfield
Bob, So you say, but it is not that simple. The contract and the license are only valid if both parties follow the agreement. Right now Rossi has done so as reported by the ERV. IH have not as they have not paid up. It is not IH taking Rossi to court for failure to comply and IH don't own

Re: [Vo]:Another motion filed in Rossi suit

2016-07-01 Thread Jack Cole
Bob Higgens wrote: "I am not a lawyer. However, I believe at this moment Rossi has a duly executed license agreement with IH. He cannot unilaterally cancel that after money has changed hands. Pragmatically he could not even give the $11.5M back and take back his license unless IH accepted that

Re: [Vo]:Another motion filed in Rossi suit

2016-07-01 Thread Eric Walker
On Fri, Jul 1, 2016 at 5:31 PM, Bob Higgins wrote: Rossi seems happy with the 400+ days to trial, which I cannot understand. > One possible explanation: Rossi is acting on a self-destructive impulse. Eric

Re: [Vo]:Another motion filed in Rossi suit

2016-07-01 Thread Bob Higgins
Of course, Rossi may have a case. Also, he may not have a case. This would be for the courts to decide. No matter what, Rossi cannot unilaterally nullify the license. He would have to sue in civil courts to have the license contract dissolved for cause. Until the court says otherwise, the

Re: [Vo]:Another motion filed in Rossi suit

2016-07-01 Thread a.ashfield
Bob, He has a case if IH have not fulfilled their side of the contract and paid him for a successful trial of the 1 MW plant. On 7/1/2016 5:12 PM, Bob Higgins wrote: I am not a lawyer. However, I believe at this moment Rossi has a duly executed license agreement with IH. He cannot

Re: [Vo]:Another motion filed in Rossi suit

2016-07-01 Thread a.ashfield
Bob, The other side of the argument is this. Rossi would not agree to the deal for just ~$11 million and was counting on the $89 million. The terms were set out for the trial in two agreements (that Ampernergo didn't sign was a red herring). The terms were the success of the trial would be

Re: [Vo]:Another motion filed in Rossi suit

2016-07-01 Thread Bob Higgins
I am not a lawyer. However, I believe at this moment Rossi has a duly executed license agreement with IH. He cannot unilaterally cancel that after money has changed hands. Pragmatically he could not even give the $11.5M back and take back his license unless IH accepted that deal with other

Re: [Vo]:Another motion filed in Rossi suit

2016-07-01 Thread Craig Haynie
No way Rossi's actions are fraud, from reselling the licensing, (unless he has a known faulty product). The best IH can hope for is a null contract; not the rights to the IP. On 07/01/2016 03:59 PM, Bob Higgins wrote: It is interesting and self-destructive that Rossi appears to have

Re: [Vo]:Another motion filed in Rossi suit

2016-07-01 Thread Lennart Thornros
Bob, You could be right. However, the situation is far from that simple. There is no way IH can claim right to licence if they do not prevail in getting out of Rossi's lawsuit. Just now they are in a very bad situation with the license. That is my believe that is why they do not come right out

Re: [Vo]:Another motion filed in Rossi suit

2016-07-01 Thread Bob Higgins
It is interesting and self-destructive that Rossi appears to have unilaterally declared that the license sold to IH is null and void. Having accepted money for that license, he is in a legally binding contract. Yet Rossi seems intent to market that license to others as though he had no other

Re: [Vo]:Another motion filed in Rossi suit

2016-07-01 Thread Jed Rothwell
a.ashfield wrote: Jed, > IH have two problems. > 1. They did not display good faith and keep their side of the agreement > when they failed to pay Rossi $89 million. > Good faith?!? Are you joking? Rossi's reactor does not work. It does not produce any excess heat. They

RE: [Vo]:Another motion filed in Rossi suit

2016-07-01 Thread Chris Zell
...@verizon.net] Sent: Friday, July 01, 2016 9:12 AM To: vortex-l@eskimo.com Subject: Re: [Vo]:Another motion filed in Rossi suit Jed, IH have two problems. 1. They did not display good faith and keep their side of the agreement when they failed to pay Rossi $89 million. 2. It is not clear

Re: [Vo]:Another motion filed in Rossi suit

2016-07-01 Thread a.ashfield
Jed, IH have two problems. 1. They did not display good faith and keep their side of the agreement when they failed to pay Rossi $89 million. 2. It is not clear if the agreement with Rossi covered the later development of the QuarkX. On 6/30/2016 9:22 PM, Jed Rothwell wrote: a.ashfield

Re: [Vo]:Another motion filed in Rossi suit

2016-06-30 Thread Jed Rothwell
a.ashfield wrote: > Contrary to Jed's comments, I expect there will be commercial plants > running by the time this reaches court. > If that happens, Rossi will lose. He will have to provide I.H. with the IP as originally agreed. - Jed

Re: [Vo]:Another motion filed in Rossi suit

2016-06-30 Thread Jack Cole
Yes, but sadly people are jumping the gun in interpreting this. Seems like probably just something that they have to do should the judge rule it will go to trial. But, I don't know that either. Best to wait to hear from the judge. On Thu, Jun 30, 2016 at 6:34 PM Jones Beene

RE: [Vo]:Another motion filed in Rossi suit

2016-06-30 Thread Jones Beene
Sorry but this document is not a ruling on the motion to dismiss. If there has been such an ruling, where is it? It is doubtful that the motion to dismiss has been heard, since it was only filed recently. This document does not imply that the motion has been heard. -Original

RE: [Vo]:Another motion filed in Rossi suit

2016-06-30 Thread a.ashfield
Ooops I made a Freudian slip. I thought the trial would probably be delayed and typed 2018 instead of 2017

RE: [Vo]:Another motion filed in Rossi suit

2016-06-30 Thread a.ashfield
The motion to dismiss has been rejected. Rossi v. Darden will go to a trial by jury starting on Sept 18th 2018 http://www.sifferkoll.se/sifferkoll/wp-content/uploads/2016/06/Rossi_et_al_v_Darden_et_al__flsdce-16-21199__0020.1.pdf Contrary to Jed's comments, I expect there will be commercial

RE: [Vo]:Another motion filed in Rossi suit

2016-06-28 Thread Jones Beene
Rossi’s past legal problems in Italy are probably not admissible in this case, that is true… although otherwise inadmissible evidence which shows a “pattern of conduct” can be admissible for that purpose… but that is not what I am talking about. Let’s focus on a dismissal of the complaint. The

Re: [Vo]:Another motion filed in Rossi suit

2016-06-28 Thread Jed Rothwell
Jones Beene wrote: > It should not surprise anyone who has followed the Rossi saga over the > years to learn that Gary Wright or Mary Yugo, etc. etc. could have fully > informed the Court of the Petrodragon details and the failed Army > contracts, etc. It is almost a

RE: [Vo]:Another motion filed in Rossi suit

2016-06-28 Thread Jones Beene
From: Jed Rothwell * Whether the gadget works or not is a matter of fact that must be established by expert testimony. Perhaps, but will it get that far? Rossi’s claim could be dismissed on the issue of lack of signatures for the second amendment, or actually any of the 3 arguments in

Re: [Vo]:Another motion filed in Rossi suit

2016-06-28 Thread Jed Rothwell
a.ashfield wrote: >- not enough signatures, so a working MW reactor doesn’t matter. It >came too late. > > I.H. claims it does not work. If it worked, they would pay $89 million. Regardless of whether it actually works or not, Sifforkoll should not misrepresent

RE: [Vo]:Another motion filed in Rossi suit

2016-06-28 Thread a.ashfield
It seems this is a second effort by IH/Cherokee to dismiss Rossi's charges. Sifferkoll comments as follows. Rossi_et_al_v_Darden_et_al__flsdce-16-21199__0019.0 It seems

Re: [Vo]:Another motion filed in Rossi suit

2016-06-28 Thread H LV
Argument Clinic - Monty Python's The Flying Circus https://www.youtube.com/watch?v=kQFKtI6gn9Y ​Harry​ On Tue, Jun 28, 2016 at 5:17 PM, Jed Rothwell wrote: > a.ashfield wrote: > > Is this not the old response of IH to Rossi's charge? Rossi has

Re: [Vo]:Another motion filed in Rossi suit

2016-06-28 Thread Jed Rothwell
a.ashfield wrote: Is this not the old response of IH to Rossi's charge? Rossi has already > replied to it. > See > http://www.e-catworld.com/2016/06/28/rossi-responds-to-ihs-motion-to-dismiss-in-court-case/ > > I do not think so. This document was entered yesterday,

RE: [Vo]:Another motion filed in Rossi suit

2016-06-28 Thread a.ashfield
Is this not the old response of IH to Rossi's charge? Rossi has already replied to it. See http://www.e-catworld.com/2016/06/28/rossi-responds-to-ihs-motion-to-dismiss-in-court-case/

RE: [Vo]:Another motion filed in Rossi suit

2016-06-28 Thread Chris Zell
Sounds like the E-cat patent may be rejected ( see end of document) – independent of this. I am just reporting this. Don't ask me what it means. I have no clue. "Defendants' reply in support of motion to dismiss"

[Vo]:Another motion filed in Rossi suit

2016-06-28 Thread Jed Rothwell
I am just reporting this. Don't ask me what it means. I have no clue. "Defendants' reply in support of motion to dismiss" https://www.lenr-forum.com/forum/index.php/Attachment/678-D-E-19-Reply-In-Support-of-Motion-to-Dismiss-pdf/