The last ten days have seen defendant after defendant file motions for summary judgment saying that they themselves didn’t personally do anything to the plaintiffs so the case against them should be dropped. I wonder if this is related to the fact that the case wasn’t certified as a class action? Like maybe the defendants did stuff to other people who just don’t happen to be the plaintiffs?
In any case, yesterday night late Charlie and Frank Ferrara filed their motions and a bunch of supporting paper. It all looks really interesting but I don’t have time to do more than provide links to the documents in the Archive.Org collection of pleadings in the case. They are after the break, and here is a list of all of my posts on these motions for summary judgment so far:
- Angelo Ferrara, Jalian Johnston, Brant Blakeman
- Michael Papayans
- Sang Lee
- Jeff Kepley and the City of Palos Verdes Estates
Oh, one little thing more. In this Declaration of Tiffany Bacon in support of Charlie Ferrara’s motion, which has tons of excerpts from depositions, we find this stunning bit of lawyer humor when they’re asking Charlie Ferrara if he heard Jalian Johnston sexually harassing Diana Reed. Samantha Wolff is asking questions, Ms. Hurley is representing Charlie Ferrara:
Q. Do you recall whether or not Mr. Johnston was acting in a sexually suggestive manner at the time?
MS. HURLEY: Objection, calls for speculation, calls for expert opinion testimony, lacks foundation.
Calls for expert opinion testimony indeed, friends!
Also, don’t forget that the hearing for all of these defense motions for summary judgment is scheduled for August 21, 2017, at 10:00 a.m in James Otero’s courtroom 10C in the First Street Federal Courthouse.
- Charlie Ferrara’s motion for summary judgment
- Charlie Ferrara’s request for judicial notice of adjudicative facts
- Exhibits in support of Charlie Ferrara’s motion
- Proposed order for Charlie Ferrara’s motion
- Charlie Ferrara’s notice of lodging
- Memo of points and authorities for Charlie Ferrara’s motion
- Charlie Ferrara’s notice of proposed lodging
- Declaration of Tiffany Bacon in support of Charlie Ferrara’s motion — This is well worth looking at as it contains many, many deposition excerpts
- Frank Ferrara’s motion for summary judgment
- Frank Ferrara memo of points and authorities in support of motion
- Frank Ferrara notice of lodging of proposed judgment
- Frank Ferrara notice of lodging of statement of uncontroverted facts
- Statement of uncontroverted facts in support of Frank Ferrara’s motion
- Proposed judgment on Frank Ferrara’s motion
- Frank Ferrara’s request for judicial notice of adjudicative facts
- Exhibits in support of Frank Ferrara’s motion
- Declaration of Tiffany Bacon in support of Frank Ferrara’s motion — also worth looking through, especially for the depo excerpts
- Statement of uncontroverted facts and law in support of Charlie Ferrara’s motion
Image sources are: Angelo Ferrara and hyena and beach and the resulting mashup is ©2017 MichaelKohlhaas.Org. Part of the words in Angelo Ferrara’s mouth came from this Daily Breeze article and I made up the rest of them.