DEFENDANT DEAN FLIPPO’S REPLY MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO DISMISS AMENDED COMPLAINT PURSUANT TO FRCP 12(b)(6), STACY LININGER, Plaintiff, v. RONALD PFLEGER, CITY OF CARMEL, DEAN FLIPPO, District Attorney of Monterey County California, and DOES 1-50, Defendants. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

ABSTRACT: On February 27, 2018, Charles J. McKee, County Counsel, Attorney for Defendant DEAN FLIPPO, submitted DEFENDANT DEAN FLIPPO’S REPLY MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO DISMISS AMENDED COMPLAINT PURSUANT TO FRCP 12(b)(6), STACY LININGER, Plaintiff, v. RONALD PFLEGER, CITY OF CARMEL, DEAN FLIPPO, District Attorney of Monterey County California, and DOES 1-50, Defendants. Case No. 5:17-CV-03385-SVK, UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA. CONCLUSION Because there is no real and immediate threat of future injury to Plaintiff, because Plaintiff does not have standing to assert the rights of unidentified individuals who have yet to be  charged with any crime, and because the requested relief would entail abrogation of key principles of comity and federalism, Defendant Dean Flippo respectfully requests that the Court dismiss the Amended Complaint without leave to amend as to Mr. Flippo and his subordinates. The DEFENDANT DEAN FLIPPO’S REPLY MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO DISMISS AMENDED COMPLAINT PURSUANT TO FRCP 12(b)(6) document copy is embedded.

Lininger Defendant Dean Flippo’s Reply 44 02-27-18 by L. A. Paterson on Scribd

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA
STACY LININGER, Plaintiff, vs. RONALD PFLEGER, CITY OF CARMEL, DEAN FLIPPO, District Attorney of Monterey County California, and DOES 1-50, Defendants.
CASE NO. 5:17-cv-03385-SVK
DEFENDANT DEAN FLIPPO’S REPLY MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO DISMISS AMENDED COMPLAINT PURSUANT TO FRCP 12(b)(6)