Podcasts about dismiss

Investigative journalists and co-hosts of True Sunlight Podcast Mandy Matney and Liz Farrell and attorney Eric Bland discuss the heinous details contained in court documents about what suspended South Carolina Representative RJ May has been accused of doing and why it was important for the U.S. Attorney's Office to get so graphic.  Over the course of five days in 2024, RJ May is accused of sharing 220 different child-sex abuse videos — including videos of babies being raped, bestiality with children and sex acts between toddlers and grown women and men. He shared those videos 479 times with other “like-minded pedophiles,” according to court records.  Even more stunning is that while the FBI conducted its investigation, RJ May remained a lawmaker and even got re-elected — despite the powers that be allegedly being aware of the nature of that investigation. RJ May's case should serve as a wake-up call for everyone.  Also on the show, Michael Colucci's retrial is this week. Mandy, Liz and Eric talk about the incredible accusations made in the motion to dismiss that Colucci's team filed Friday, accusing SLED and South Carolina Attorney General Alan Wilson's Office of sitting on “conclusive evidence” that Michael's wife, Sara-Lynn Colucci — whom Michael is accused of killing — had plans to hang herself.  ☕ Cups Up! ⚖️ Episode References “Will RJ May be expelled from SC House? Here's what would need to happen” - The State, June 13, 2025 Mandy's FB post on RJ May's federal indictment “Retrial begins for Summerville jeweler charged with murder in wife's 2015 death” - ABC 4 News, Updated June 16, 2025 The Colucci Case Spotify Playlist Premium Resources Robert May - June 12, 2025 - Federal Brief Supporting Detention⁠ ⁠Michael Colucci's Motion to Dismiss for Government Misconduct - June 13, 2025 Soundbites On Colucci - A Recap Episode Stay Tuned, Stay Pesky and Stay in the Sunlight...☀️ ⁠⁠⁠⁠⁠⁠⁠Premium Members⁠⁠⁠⁠⁠⁠⁠ also get access to episode videos, case files, live trial coverage and exclusive live experiences with our hosts. ⁠⁠⁠⁠⁠⁠⁠CLICK HERE⁠⁠⁠⁠⁠⁠⁠ to learn more and join with Promo Code "COJ25" for your first month free! ⁠⁠⁠⁠⁠⁠⁠https://bit.ly/3BdUtOE⁠⁠⁠⁠⁠⁠⁠. Check out Luna Shark Merch With a Mission shop at ⁠⁠⁠⁠⁠⁠⁠lunasharkmerch.com/⁠⁠⁠⁠⁠⁠⁠ What We're Buying... ⁠⁠⁠⁠⁠⁠⁠Quince⁠⁠⁠⁠⁠⁠⁠ - Give yourself the luxury you deserve with Quince! Go to ⁠⁠⁠⁠⁠⁠⁠Quince.com/COJ⁠⁠⁠⁠⁠⁠⁠ for free shipping on your order and 365-day returns Here's a link to some of our favorite things: ⁠⁠⁠⁠⁠⁠⁠https://amzn.to/4cJ0eVn⁠⁠⁠⁠⁠⁠⁠ Find us on social media: ⁠⁠⁠⁠⁠⁠⁠bsky.app/profile/mandy-matney.com⁠⁠⁠⁠⁠⁠⁠   |   ⁠⁠⁠⁠⁠⁠⁠bsky.app/profile/elizfarrell.com⁠⁠⁠⁠⁠⁠⁠   |   ⁠⁠⁠⁠⁠⁠⁠bsky.app/profile/theericbland.bsky.social⁠⁠⁠⁠⁠⁠⁠ ⁠⁠⁠⁠⁠⁠⁠Twitter.com/mandymatney⁠⁠⁠⁠⁠⁠⁠ | ⁠⁠⁠⁠⁠⁠⁠Twitter.com/elizfarrell⁠⁠⁠⁠⁠⁠⁠ | ⁠⁠⁠⁠⁠⁠⁠Twitter.com/theericbland⁠⁠⁠⁠⁠⁠⁠ ⁠⁠⁠⁠⁠⁠⁠https://www.facebook.com/cupofjustice/⁠⁠⁠⁠⁠⁠⁠ |  ⁠⁠⁠⁠⁠⁠⁠https://www.instagram.com/cojpod/⁠⁠⁠⁠⁠⁠⁠ ⁠⁠⁠⁠⁠⁠⁠YouTube⁠⁠⁠⁠⁠⁠⁠  | ⁠⁠⁠⁠⁠⁠⁠TIKTOK⁠⁠⁠⁠⁠⁠⁠ ⁠⁠⁠⁠⁠⁠⁠SUNscribe⁠⁠⁠⁠⁠⁠⁠ to our⁠⁠⁠⁠⁠⁠⁠ free email list⁠⁠⁠⁠⁠⁠⁠ to get alerts on bonus episodes, calls to action, new shows and updates. ⁠⁠⁠⁠⁠⁠⁠CLICK HERE⁠⁠⁠⁠⁠⁠⁠ to learn more:⁠⁠⁠⁠⁠⁠⁠ https://bit.ly/3KBM⁠⁠⁠⁠⁠⁠⁠ *** Alert: If you ever notice audio errors in the pod, email ⁠⁠⁠⁠⁠⁠⁠info@lunasharkmedia.com ⁠⁠⁠⁠⁠⁠⁠and we'll send fun merch to the first listener that finds something that needs to be adjusted! *** *The views expressed on the Cup of Justice episodes do not constitute legal advice. Listeners desiring legal advice for any particular legal matter are urged to consult an attorney of their choosing who can provide legal advice based upon a full understanding of the facts and circumstances of their claim. The views expressed on the Cup of Justice episodes also do not express the views or opinions of Bland Richter, LLP, or its attorneys. Learn more about your ad choices. Visit podcastchoices.com/adchoices

​Jane Doe, the woman who accused Jay-Z of raping her in 2000 when she was 13 years old, has filed a motion to dismiss the defamation lawsuit that the rapper filed against her. Jay-Z's lawsuit, filed in March 2025, alleges that Doe and her attorneys knowingly made false and malicious claims in an attempt to extort him, resulting in reputational harm and financial losses exceeding $20 million. In her motion, filed on April 22, Doe argues that her allegations, made in court documents and media interviews, are protected under California law and cannot form the basis for a defamation claim. She also contends that Jay-Z's claims of malicious prosecution, abuse of process, and civil conspiracy lack legal merit and factual support.to contact me:bobbycapucci@protonmail.comsource:Jay-Z's Rape Accuser Files Motion to Dismiss His Defamation Lawsuit Against HerBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

Federal Court Rejects Deere's Motion to Dismiss FTC Right-to-Repair Lawsuit

Today is Thursday, June 12, 2025. The Brainerd Dispatch Minute is a product of Forum Communications Co. and is brought to you by reporters at the Brainerd Dispatch. Find more news throughout the day at BrainerdDispatch.com.

In the Reply Memorandum of Law supporting Sean Combs' motion to dismiss the amended complaint in Thalia Graves v. Sean Combs and Joseph Sherman, Combs' legal team reiterates that the plaintiff's claims are both legally and factually insufficient. They argue that the amended complaint relies on conclusory allegations without concrete evidence of Combs' direct involvement in the alleged misconduct. The reply further contends that the complaint improperly attempts to attribute liability to Combs through speculative inferences about his association with co-defendant Joseph Sherman, rather than demonstrating specific acts or intent required under the applicable legal standards.Additionally, Combs' attorneys assert that many of the claims are time-barred and fall outside the statute of limitations. The reply memorandum emphasizes that the plaintiff's attempt to revive these claims through generalized references to a purported ongoing pattern of misconduct is legally untenable. They also argue that the complaint fails to meet the heightened pleading standards required for claims of intentional infliction of emotional distress and other tort-based allegations. On these grounds, the defense urges the court to dismiss the amended complaint in its entirety, with prejudice.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.630450.87.0.pdf

On today's episode of The Wholesome Fertility Podcast, I am joined by Hannah Davis (@rooted.with.hannah), a Registered Dietitian and certified meditation teacher who specialises in women's health, hormones, and autoimmune conditions. After being diagnosed with Hashimoto's while navigating early motherhood, Hannah shifted her clinical nutrition practice to focus on uncovering the deeper root causes of symptoms like fatigue, cycle irregularities, and PCOS. We dive into how nervous system dysregulation often underlies hormonal imbalances and why functional testing, mineral status, and emotional safety are crucial for true healing. From decoding PCOS types to understanding thyroid antibodies and the connection between trauma and calcium retention, Hannah offers a deeply integrative and compassionate lens for supporting women on their fertility and healing journeys. This conversation is packed with practical tools and fresh insights—don't miss it! Key Takeaways: PCOS is not just about ovarian cysts—it's a metabolic and inflammatory condition with many root causes. Nervous system regulation is foundational for hormone balance, digestion, and fertility. Functional lab testing (like Dutch and HTMA) reveals hidden patterns traditional labs may miss. Excess calcium in tissues may indicate trauma or over-supplementation with Vitamin D. Diet, stress, sleep, and gut health all influence autoimmune and hormonal symptoms. Guest Bio: Hannah Davis, RD (@rooted.with.hannah) is a Registered Dietitian and certified meditation teacher with advanced training in functional nutrition, lab testing, and spiritual psychology. She specialises in supporting women with hormonal imbalances, autoimmune conditions like Hashimoto's, and chronic fatigue through an integrative approach that blends clinical science with deep nourishment and nervous system healing. After navigating her own health challenges postpartum, Hannah now helps women reclaim their energy, resilience, and sense of safety through 1:1 coaching and group programs at Pivot Nutrition Coaching. She's especially passionate about working with mothers, self-healers, and cycle-breakers who are ready to feel like themselves again. Links and Resources: Follow Hannah on Instagram Visit the Pivot Nutrition Coaching website Book Mentioned: The Body Keeps the Score by Bessel van der Kolk   For more information about Michelle, visit www.michelleoravitz.com  To learn more about ancient wisdom and fertility, you can get Michelle's book at: https://www.michelleoravitz.com/thewayoffertility  The Wholesome Fertility facebook group is where you can find free resources and support: https://www.facebook.com/groups/2149554308396504/  Instagram: @thewholesomelotusfertility Facebook: https://www.facebook.com/thewholesomelotus/  Disclaimer: The information shared on this podcast is for educational and informational purposes only and is not intended as medical advice. Please consult with your healthcare provider before making any changes to your health or fertility care. ------------- Transcript: # Audio: TWF 340- Hannah [00:00:00] [00:01:00] Welcome to the Wholesome Fertility Podcast. I'm Michelle, a fertility acupuncturist here to provide you with resources on how to create a wholesome approach to your fertility journey. **Michelle:** Welcome to the podcast, Hannah.  **Hannah:** thanks for having me. **Michelle:** So I'm very excited to have you on. We're gonna be talking about a lot of really cool topics, but before we get started, I always like to start out with kind of like an origin story and learn how you got into the work that you're doing.  **Hannah:** Yeah. I am a registered dietician. I've been mainly practicing medical nutrition therapy for the last 10 years in a more clinical setting. And you know, and then [00:02:00] I became a mom. I have two. One's almost eight, you gotta say almost eight. And the other one's, and the other one's nine. So they're really, they're really young and I, you know, working at the hospital part-time and I started noticing. **Hannah:** My own symptoms of, of things that just felt like off. And simultaneously I was also becoming more interested in learning about more integrative functional nutrition. And so that really led me down. It, it started off as, oh. A way for me to kind of figure out what was going on with me, because of course, like so many of my, the clients I work with now you know, you go to the doctors, you ask for some labs to be done and they just say, oh, you're absolutely fine. **Hannah:** You might just be stressed. You're stressed out, you're a young mom. Of course it's normal to feel exhausted all of the time and stuff like that. So, I just was like really interested [00:03:00] in doing more digging and so I, we got some training in advanced lab testing and more like integrative functional nutrition. **Hannah:** And so. From there I was able to figure out what's going on with me, and I, I actually have an autoimmune condition. It's called Hashimotos. And so that really affects, you know, your, your energy levels, your, your gut health, your immune system obviously is involved. So I, it was so incredibly validating and it really excited me. **Hannah:** I was like, I feel. If I can figure out a way to use advanced lab testing and combine that with my. More of my more clinical, you know, expertise and combine that together to really like, help women feel empowered about how to support their health and, and how they feel and their showing up in their lives every [00:04:00] day. **Hannah:** And so it just really, really excited me. So that's kind of what got me started with that. And then I, I pivoted towards, towards that about three years ago started my own virtual practice working more in like the women's health space. So like hormones, gut health, autoimmune conditions. **Hannah:** And then I, as I was doing more of that work, I was like, okay, there's. I'm seeing a common theme here. These women at their root, cause a lot of the time is nervous system dysregulation. And I got really. Tired of just saying over and over again. You know, you need to manage your stress a little bit better. **Hannah:** I wanted to be able to give them so much more than that. And obviously I knew that from my own journey. I really had to integrate that. And so, but I wanted to like, figure out how to help my, my clients integrate that. So then I became a certified meditation [00:05:00] teacher. And spent a year studying spiritual psychology, which is like a blend of Eastern ritual and practices with western psychology. **Hannah:** That, yeah. Yeah, yeah. So now I really like to supplement my, programs with giving my clients tools on how to regulate their nervous systems as well. And so, we'll, you know, you know, it's more of like life coaching almost. And then maybe we'll integrate some, some things like, meditation or breath work together. **Hannah:** It really just depends on what the, how the client wants to be supported. So  **Michelle:** Awesome.  **Hannah:** Yeah.  **Michelle:** You know it's interesting 'cause I  **Hannah:** Yeah. **Michelle:** an episode on. Nervous system. Really the vagal tone and  **Hannah:** Yes. **Michelle:** there's a link with a weaker vagal tone and things like endometriosis or  **Michelle:** PCOS, and I thought that was just fascinating. [00:06:00]  **Michelle:** So, yeah, I'd love to really kind of dig deep on all of these things. So just for people listening and they're kind of like hearing nervous system for the first time. 'cause well maybe they've listened to my podcast, maybe not when I talked about the nervous system. But what should people, like, explain the nervous system, explain how the nervous system ties into certain conditions. **Hannah:** I mean, that's a very, like, that's pretty broad because it's like, you know, it really depends on what. **Michelle:** the nervous system like tie into certain conditions?  **Hannah:** I don't know what condition it doesn't, honestly. Uh, the more, the more I get like deep in the weeds with this, so, you know, a lot of my clients we, you know, so I am typically working with people with autoimmune conditions and hormone. I balances gut health, that kind of stuff. And I, you know, I would say the nervous system impacts all of those areas [00:07:00] because ideally, especially when we're talking about women's health and like hormones, things like that we really just want to create safety in the body, right? **Hannah:** So that we can. Manufacture hormones and ovulate naturally and things like that. So, and then, you know, inflammation's another, another piece of that. It really just, it's a great way to, like, it just connects to everything right. **Michelle:** Yeah, well the vagus nerve is incredibly important when it comes to gut health. the stronger the vagal tone, the better the vagus nerve, the better. It's able to lower inflammation in the body.  **Hannah:** Mm-hmm. Mm-hmm. **Michelle:** fascinating and interesting. And so what are some of the things that you do suggest for people. they wanna regulate their nervous system and support that aspect.  **Hannah:** So First of all, I think it's important to just figure out what are the systems for that client? What are [00:08:00] the systems that are working for them and what's not? And really get really honest about that. And then, you know, it could be something like starting a. **Hannah:** Very doable meditation practice or some breath work like before, before meals, right? Getting into rest and digest me activating that vagus nerve so that we can digest our food properly. So it really just depends on what is feels a lot most aligned for the client and, and is doable for them. But also I think another big piece of this, which is not really talked about often is eating for blood sugar balance. **Hannah:** Because even like blood sugar swings throughout the day can cause fluctuations in your mood and your anxiety and cravings and all, all of, and even inflammation as well. So  **Michelle:** that  **Hannah:** like a whole body [00:09:00] approach. Mm-hmm. **Michelle:** It's such a good point. And I remember like looking into this and researching like just really the gut brain connection and. And it's interesting 'cause you can see it really go both ways. So if you have imbalanced gut microbiome that can ima impact your brain and your mood and your state and your emotions. **Michelle:** And it actually is linked with certain emotional um, imbalances or like mental disorders. It's really fascinating. And then they found. On the flip side that people who meditated for many years, like Tibetan monks, they had a really vast microbiome that was a lot more enriched and had a lot more diversity. **Michelle:** So it's really fascinating how you really can literally get it at both ends or either end.  **Hannah:** yeah. Like I tell my clients all the time, if you're breathing into your shoulders, the majority of the time it's gonna signal, [00:10:00] or that's gonna signal to the brain that you're in fight or flight. So it's gonna send all the blood to your extremities. It's not gonna be sending the blood to, you know, your, your GI track and your, you know, your organs there. **Hannah:** And so. it's gonna be a lot harder to digest your foods, whereas if you are really taking these deep breaths into your belly, it's sending all the blood there. And that's, that's a, and I mean, I often get skipped, you know, people are just like, no, just gimme a, just gimme a meal plan. I wanna feel better. **Hannah:** I wanna lose weight, or I wanna, you know, but it's like, you really gotta think about not just what you're eating, but how you're eating, like what your nervous system state is. You know, when you're, when you're eating food.  **Michelle:** That's so true. It's  **Hannah:** Mm-hmm. **Michelle:** true. And it was funny 'cause I was reading about that and it was one of the things to do is just stand. This is why they say like, don't drive and eat at the same time. Because when you're driving naturally, you're gonna be in a little bit more of a fight or flight or kind of ready for anything and. Also just to kind of throw it out [00:11:00] there, it's not bad to be in that state, in that sympathetic state. It's part of life. It's just that sometimes you need that and then sometimes you need the other. But what you're saying is so true, like it's actually like becoming mindful of getting yourself into that state and maybe  **Michelle:** doing those exercises to get yourself in more parasympathetic state, which is more of  **Michelle:** the rest and digest, so that you're priming your body when you do eat. To digest better. So I think  **Hannah:** Yeah. Of course, and, you know, if you're digesting better, you're absorbing nutrients better, which is gonna impact your energy levels, your mood, your hormones, everything. So yeah, there really, I feel like the more I get into it, the, more I see that there really isn't an aspect of our health, our med, our metabolic health, everything that is not touched by, your nervous system. **Michelle:** Yeah, it's really fascinating. I like, the more I dig into this, the more I'm just like so [00:12:00] amazed at how Willy, you know, it's the nervous system is kind of like this wiring of like. Information.  **Michelle:** It's almost like information that kind of signals to your body, all kinds of different states, but especially that safety. **Michelle:** I agree with you. You know, when you, when you feel safe, you can be more creative. And what does that mean really in the body fertility and it also regeneration growth.  **Michelle:** So yeah, it's pretty cool,  **Hannah:** Yeah. And I mean, hormones, that's how hormones work too. They're just chemical messengers in your body. **Michelle:** right? and so talk about PCOS, 'cause I know that you work with P-C-O-S-A lot just to cover. 'cause I think of people don't really understand it fully because it is you know, there's so many different types of PCOS and people get confused and sometimes people show PCOS symptoms, but then some doctors, and we don't know if they're just not like looking. Thoroughly into it. Dismiss it. Oh, that's not PCOS. So  **Hannah:** Right.  **Michelle:** that and just kind of, **Hannah:** Yeah.  **Michelle:** [00:13:00] it is,  **Hannah:** Okay, well, we'll just start what, like, so what is PCOS? So PCOS stands for polycystic ovarian syndrome. So a lot of people get confused by that right off the bat. They think, oh, so that mean I have cysts on my ovaries. Does that mean that I have it? So it's actually not a physical ovarian condition, like of the presence of cyst, but it's rather a hormonal condition and it's a, what I like to call a spectrum condition. **Hannah:** You know, 'cause there's different varieties and there's different root causes. It's important to understand, first of all what kind of PCOS you have and what the root causes are which is why we, we use functional lab testing in practice. But but yeah, I think a lot of women often it's like a long confusing road full of mixed messages of like just lose weight advice,  **Michelle:** Yeah,  **Hannah:** [00:14:00] you know. **Michelle:** really thin. PCOS patients, so that's where it can get so confusing for  **Hannah:** Right, right, right. And so, A-P-C-O-S isn't in an ovarian condition, you know, what exactly is going on? I mean, in a nutshell, it's basically, blood sugar issues plus inflammation, plus genetic susceptibility, which is going to lead to the ovaries to begin to produce large amounts of androgens. **Hannah:** So, you know, and I say genetic susceptibility because, you know, just because you have like insulin sensi or insulin resistance or diabetes, that doesn't mean you automatically are gonna get PCOS. Some people just have really sensitive ovaries right. And so they're, they're going to develop the, the condition, so I like to talk to my clients about well first of all, we start by running some tests [00:15:00] to find out, you know, what what their root causes are. And then we're gonna really go deep with, you know, working on the blood sugar issues with the inflammation, real food strategies lifestyle interventions, things like that. **Michelle:** One of the things that I find is pretty common just in my own practice, is that. **Michelle:** there's a huge link of gut imbalance  **Michelle:** or, you know, gut microbiome  **Michelle:** imbalance and inflammation, you know, that is part of the contributor to the inflammation and can really impact PCOS conditions.  **Hannah:** Yeah. Because you know, if we, if that inflammation in the gut is going unchecked you know, that's also gonna drive that insulin resistance even more.  **Michelle:** Yeah.  **Michelle:** what are some of the tests that you do for PCOS? Functional  **Hannah:** Well, yeah. Well, first of all, I, I like to start with a Dutch test. It's a, have you heard of [00:16:00] Dutch? The Uhhuh? Yeah. Oh, you do? Okay. Yeah. So I would run a Dutch you know, so that we,  **Michelle:** out just for people  **Hannah:** yeah. Yes, **Michelle:** I've never heard of it before. So it's dried urine testing for comprehensive, or I forget  **Hannah:** it's a Dr. It's a. Yeah, yeah. Dried urine test for comprehensive hormones. I know I used to think, oh, it's of Dutch, like it's from the Dutch, like, you know, but it's just an abbreviation.  **Michelle:** right, right.  **Hannah:** But yes, it's a very unique way to look at hormones. 'cause traditionally before this test was available, you would have to rely on blood work for hormones. **Hannah:** And, you know, saliva for cortisol, which is okay, but it's just not great. So this test really helps us get a lot more specific, a lot more personalized, and helps us get some answers that would probably. Be left unanswered if we were just, you know, looking at, at blood work alone. So, you know, it's gonna tell us, you know, give us a snapshot [00:17:00] of all three sex hormones, estrogen, progesterone, testosterone. **Hannah:** It's gonna show us how they're being metabolized in the liver. And then what I really like is it looks at your cortisol awakening response. So someone is struggling with sleep, mood, energy levels. Things like that that could also be driving your symptoms and, and your inflammation as well. So I, mm-hmm. **Michelle:** cortisol is your friend in the morning.  **Hannah:** Yes. Yeah. Yeah. And then I like that it also has that organic acid test at the end there, which some of those other markers are gonna be important for looking at, for hormone production. So it's nice if they include that. So I, I like to do a Dutch, I also like to do HTMA testing, which stands for hair tissue mineral analysis. **Hannah:** Because, you know, you know, when we're looking at hormones it's, you know, we, we also wanna be, look thinking about minerals too because and not just like, our minerals through blood [00:18:00] work, but more on a cellular level. Like what is the body doing with those minerals? And how is your body utilizing them? **Hannah:** Are they even getting up into the cell? So, and we can, you know, you know, minerals, they impact hormones, which means they're gonna impact PCOS. So I like that one too. And it's like a little, it's a, it's a nice way to, I like it 'cause it's, it shows your body's like, it's like a blueprint. It shows you your stress pattern. **Hannah:** know how your body is using minerals after you've maybe gone through a season of. Really high stress and you know, the fertility journey too is so stressful on its own that I'm like, yeah, let's look at what your body does with all this stress and how we can really like, you know, deeply nourish your body and, you know, make it feel safe for ovulation. **Michelle:** Yeah, I know that there's a lot of minerals that you can't really test in blood and for example, magnesium. That's a **Hannah:** Mm-hmm. **Michelle:** one to test for. So does this test for magnesium as well, like all [00:19:00] minerals or,  **Hannah:** yeah, yeah. It looks at all of the minerals. Specifically the ones that I'm gonna be focusing on. The minerals that impact PCS would be magnesium, zinc, calcium, iron selenium iodine. So, you know, and in a nutshell, you know, these, these minerals. they can exacerbate insulin resistance, hormonal imbalances, oxidative stress, which is important for like egg quality, sperm quality, things like that. **Hannah:** So women, get your men to your partner.  **Michelle:** Yes.  **Michelle:** So, so this is a hair test.  **Hannah:** yeah, it's a hair. They're using just like a teaspoon amount of your hair to analyze the mineral content in your tissues. **Michelle:** Fascinating. I know they've done those for like heavy metals and, and just testing the  **Hannah:** Yeah, yeah,  **Michelle:** I haven't heard of the mineral testing yet.  **Hannah:** yeah. And this, yeah. And this test does include heavy metals and we look at, mm-hmm.  **Michelle:** heavy metals. Oh, [00:20:00] okay.  **Hannah:** Mm-hmm. Mm-hmm. **Michelle:** it's really high. Just like for people that don't have symptoms sometimes I almost feel like it's like high for everybody.  **Hannah:** The heavy metals. Yeah. Yeah. You know, and  **Michelle:** somebody who's not, who doesn't have like,  **Hannah:** yeah, and I mean, we we're exposed to heavy metals all of the time. It's, you know, it's, there's, it's kind of impossible to get around it, you know? It's in our food, our water, the soil, you know. And so my approach is, you know, we might see like an acute. **Hannah:** Exposure to the heavy metals. But what we wanna see is that you, you're able to detox and excrete those heavy metals safely. You know, that's why, you know, we have our detox organs, our liver, right? And so if I ever see those metals like pushing into the tissues, it's just a really good indication that, hey, your liver needs some. **Hannah:** Some attention, like we need to work on supporting that. And also working on not just our [00:21:00] detoxification organs, but our drainage pathways. So like our lymphatic system you know, making sure we're having daily bowel movements that we're sweating all of that. All of that stuff. Yeah.  **Michelle:** Yeah. **Michelle:** for sure. I think that that's key is really detoxifying, and I think that it, you had a good point. You mentioned the word safely because  **Michelle:** that can be an issue, like if you detoxify too harshly. I'm really big on that, especially when you're trying to conceive and you're actively trying, you definitely don't wanna do something that's so strong that it actually circulates more toxins in your bloodstream.  **Hannah:** That's right. Yeah. **Michelle:** So they have like binders, right? Or things  **Hannah:** Yeah, That is one approach for me. I rarely will do like a heavy metal detox with somebody. I will just wanna work with them on, you know, first the foundational things of, are we optimizing the gut health, the, you know, the liver function are we getting those drainage pathways [00:22:00] open? **Hannah:** Because your body should be able to do all that on its own if it's, you know, optimal. but I mean, if someone's already doing like a gut protocol or something with me, then yeah, they, they'll be taking like those types of supplements and then it'll, it'll still act on the heavy metals and things like that, as. **Michelle:** Interesting. So, what are some of the nutrient and lifestyle interventions specifically that you would do for PCOS? Or have you seen, because I, I do know that  **Hannah:** yeah.  **Michelle:** different types, so that could  **Hannah:** Yes.  **Michelle:** the type,  **Hannah:** Yes. Yeah. **Michelle:** the things that people should kind of like look out for, think about?  **Hannah:** Yeah. Yeah. So the first step is, is gonna be improving the quality of your food choices. So, you know, removing inflammatory oils, added sugars a lot of like processed, like ultra processed carbohydrates and, you know, with chemical and artificial additives. Things like that, you wanna replace them with whole real foods. **Hannah:** It's really that simple.  **Michelle:** Yeah. I [00:23:00] know,  **Hannah:** Yeah. Yeah. And then also, you know, the goal is to eat a sufficient amount of carbohydrates to promote ovulation, but while still focusing on those whole real. Food sources, like starchy veggies fruits and then unprocessed whole grains and legumes.  **Michelle:** So really from natural sources,  **Michelle:** complex car carbs. So it's not like simple carbs, not white, you know, avoid those like.  **Hannah:** Yeah. Right. So you, and you would want to make sure you're getting adequate amount of carbohydrates, but you know, if we're also dealing with insulin resistance, then we also need to be talking about you know, maintaining adequate calorie intake and just aiming for. Balance across all the macronutrients. **Hannah:** So, you know, we're pairing those carbohydrates with good quality sources of protein and healthy fats. And, if you're eating a more whole food carbs diet like. Your carbs are coming [00:24:00] from fruits like, and like root vegetables and things like that, then those foods are naturally gonna have more fiber in them, which is also gonna help with things like insulin resistance. **Hannah:** And then I would also be focusing on gut nourishing foods, like, bone broth probiotics from fermented foods, cultured. Products. And then lots of prebiotic fibers. So it also just making sure you're eating a wide range of, plant fibers. Like we're not just eating the same, spinach every day. **Hannah:** You know, let's really mix that up. Maybe like arugula, kale, you know. So that would be the where, where I would start with foods strategies. And then for lifestyle I would be really focusing on exercise. This is a really crucial tool in repairing insulin sensitivity and managing blood sugar levels. **Hannah:** So first I would just focus on increasing your daily movement. So, you know, maybe try tracking your steps. And then maybe you would wanna consider adding in some resistance [00:25:00] training and some short hit style workouts. Since those really show the most metabolic improvements. In general I would avoid, I would avoid like, really long duration cardio on a regular baseball basis, since that's like very stressful on the body. **Hannah:** So exercise is number one. Stress management is key. I know we've already kind of touched on that a little bit. You know, that's a big piece of hormonal. Balance balance since the, your adrenal health, you know, has the ability to impact the function of your sex hormones. I would just evaluate the sources of your stress. **Hannah:** You know, I like to think of it like a bucket, like a stress bucket, and we have all these different inputs pouring in. Some of those things we can't really remove, but some things we can, you can control your nutrition and your sleep quality. You know, you can maybe work on energetic boundaries, right? **Hannah:** Maybe you wanna include things like meditation or [00:26:00] journaling, acupuncture, right? Those are all really nice ways to support yourself. And then sleep. Sleep is also like so major. That's when you know when you're, you can get good quality sleep at night. That's when your, your body's repairing tissue. **Hannah:** And it, it has a lot to do with your hormones, like in like your like your hunger hormones, those ones and then also like cortisol, melatonin, things like that. Everything that just keeps all of the systems working together smoothly. So, yep. Do you. **Michelle:** of sleep. There's a, there like a lot of times we'll increase sugar cravings 'cause you want that quick energy. So  **Hannah:** Yes, **Michelle:** that's one example of how that can impact  **Hannah:** exactly. Yeah. Yeah. If you have like one poor night of sleep, it increases your hunger hormone levels pretty significantly. So we'll see that that issue popping up time and time again. Yeah, so.[00:27:00]  **Michelle:** yeah. And I also have heard, in some  **Michelle:** of like go, literally pivot into autoimmune and how you can address that in the case of Hashimoto's? **Michelle:** 'cause it is so prevalent and a lot of people have it. The first thing that I say is, cut out gluten, corn, and dairy and soy if you can. Now, I always say if you can't do all of them, at least cut out the gluten entirely and talk to us about like what you've done and what you've found to be helpful. **Michelle:** 'cause it is something that if you catch early, you really can sh shift a lot just from diet alone.  **Hannah:** Oh, yes. Yeah, and I've helped. Hundreds of women with that. Exactly. Just you know, we [00:28:00] see, I've seen different stages of, Hashimoto's. You know, so if it's like, you know, stage one where we're seeing the presence of antibodies and maybe they have symptoms, maybe they don't. A lot of those women typically will present with like subclinical hypothyroidism. **Hannah:** So like their thyroid labs look fine. But they're like, I, feel tired all the time. I'm constipated. I can't lose weight, you know? So the first thing I would start with is kinda getting ahead of things with, 'cause the majority of your immune system is in your gut. So I would be doing a GI would run a stool sample, a GI map and see what's going on there. **Hannah:** Because there's different things that could be driving. That immune response. Yeah. It could be coming from things in the diet like gluten. And that test certainly will show us if you're having an immune response to gluten. So in those cases, I would have those clients cut, cut that out. And some people they, they don't, they don't run the test and they [00:29:00] cut out gluten, but they just feel better without it. **Michelle:** See that a lot.  **Hannah:** mm-hmm. I do too. Just kind of anecdotally. I was just gonna say that I think it is because of like, what, what they're spraying on our crops.  **Michelle:** Yeah, **Hannah:** Yep. know that it can impact hormones like big time, that's  **Hannah:** Mm-hmm.  **Michelle:** one for sure.  **Hannah:** Yeah. So, and then, you know, obviously if there's a inflammation or like leaky gut.  **Hannah:** You know, we're gonna wanna address that anyway because that could be driving that immune response and making your symptoms worse, making the antibodies levels worse, right? So I really wanna just get ahead of it with the gut number one. **Hannah:** And then I like to do mineral testing as well, since so many minerals, not only impact PCOS, but they impact your thyroid.  **Michelle:** That's a huge  **Hannah:** Yes, selenium. This is a common thing that I see. I'll see really high amounts of calcium in the [00:30:00] tissues. And that's gonna block your thyroid hormone from getting up into the cell. **Hannah:** So like maybe their thyroid panel looks great, but that, or they're already taking a thyroid medication, but they're, they feel like it's not doing anything for them. I'm like, look, you have a lot of calcium in your tissues. And so like, that's your thyroid hormone's not even getting up into the cell. So of course you wouldn't feel an impact there. **Hannah:** And that also is. **Michelle:** actually? What causes that? Calcification?  **Hannah:** So, I typically see that from over supplementing with vitamin D. So, that will pull the calcium out of the bone and teeth. And put it into the tissues. Yeah. A lot of people get put on vitamin D by their doctor, like maybe they had low levels at one point, and then their doctor never talked to them about weaning off of the vitamin D. **Hannah:** They just kept taking it.  **Michelle:** too high. Yeah.  **Hannah:** Yeah. Or they'll start them off like a really high dose, like I've seen like 50,000 units of, of vitamin. Yeah. [00:31:00] And they, and they just keep taking it like, then they're never told like, Hey, you're actually supposed to tapered off of that after a couple months. I've also seen an influx of people on vitamin D, zinc you know, ever since the pandemic. **Hannah:** So they just kept taking it and they don't know how that's impacted their. Mine. So, so yeah, that's one culprit. I, I'll see. The other thing that I notice, and this is pretty prevalent in the autoimmune community is, and I don't think it's talked about a lot, is significant trauma and certain types of trauma. **Hannah:** It, it's like we call when we see this pattern on an htm. It, we call it a calcium shell where the calcium and the magnesium levels are really high in the tissues. And then we are like really depleted in things like potassium and sodium and other secondary minerals. And it's kind of like the body's way of shielding itself from feeling [00:32:00] big, like feeling really big emotions. **Hannah:** So like a lot of these clients, I, I'll talk to them about this and they have such a flat effect, like with the then we start moving the calcium out of the tissues and then they become, they're, it's like they really need more emotional support throughout that process. It's very interesting. I'm about to actually do an HTMA on myself. **Hannah:** It's been a couple of years, but I've just gone, I'm grieving my mom right now and I, yeah, and it's just been a really rough couple of months. I've just been just going through the motions and kind of in that, like taking care of her, taking care of my girls. Like just everything that we've gone through leading up to this point. **Hannah:** And I'm like, I am so curious to know what's going on with my minerals right now. I would not be surprised if I was having calcium going into my tissues. 'cause I believe that's what was my pattern last [00:33:00] time I ran the test a few years ago. So.  **Michelle:** Oh, that's interesting.  **Hannah:** It's like, yeah, this is my, my unique pattern, you know, so I see that a lot with Hashimoto's and yeah, and, and it's interesting because that pattern, like the high calcium in the tissues and the low potassium, that's really really common with like thyroid stuff in general because, you know, first of all, that calcium's blocking the thyroid. **Hannah:** Hormone from getting up into the cell. It's also gonna be blocking insulin signaling. So there is gonna be a lot of blood sugar swings, and that's gonna be driving the inflammation, making that worse. And then the low potassium, well, you know, potassium is needed for thyroid function as well. So, I see that pattern a lot with that population and it's so fascinating. **Hannah:** And I would just say like, I wouldn't say it's like. It's more like anecdotal, right? Like and you probably see that too in your practice. Yeah. Yeah.  **Michelle:** For different things, not this [00:34:00] specifically, but Yeah. **Michelle:** I mean, you see a lot of that and that's, that matters just because studies are very expensive to have and you can't  **Hannah:** Mm-hmm. **Michelle:** rely just on studies. You have to really rely on data in general, like your own experience  **Hannah:** Oh, absolutely. **Michelle:** there's so much information that you can get just from that. And then, couple of things. One of the things is, I know that Zyme has been shown to really help, it's an enzyme, it's a pro oleic enzymes that break apart, like fibrous tissue. So I'm curious to  **Hannah:** Oh **Michelle:** if it would help with excess calcium or, you know, deposits because it, it works to break down  **Hannah:** yeah,  **Michelle:** really needed in the body.  **Hannah:** yeah. Yeah.  **Michelle:** up.  **Hannah:** Yeah. That is interesting. Yeah, because when we see, usually the calcium in the tissues is also associated with things like restless leg syndrome, kidney stones, gallstones, all that stuff, you know, because it's just calcification of the tissues. [00:35:00] Right. What I do is I'll get, if that person is, has actually been on vitamin D what I'll do is I'll say, okay, let's just pause on the vitamin D and then I'll get them on, a form of vitamin K two that will target that calcium in the tissues and, and bring it, redirect it back to the bones. So we'll do that for several months. And if that person's still concerned about their, their vitamin D levels and say, let's just get that checked, you know, and depending on where you're at with that, you, you either, you know, probably need supplementation time from time to time, or maybe just during the winter, right? **Hannah:** But it's not a long term. You know, supplement for you because of this pattern, this pattern that you typically have. **Michelle:** Another thing that I was gonna mention is, we were talking about like, antibodies.  **Michelle:** I remember, One of my patients mentioning she had like a, 'cause I was talking to an REI and I was gonna have him, I had him on the podcast and so she had some questions and she had a very low amount of [00:36:00] antibodies that are considered normal. And he said no, because the presence of any antibody, and that's what's crazy to me.  **Hannah:** Mm-hmm.  **Michelle:** normal in labs  **Hannah:** Yeah. Well, yeah. Yeah. The reference ranges for conventional labs or like in more like conventional healthcare settings. They're not, they're designed to show like if you have a chronic disease or not. Not necessarily if you're optimal. Right. Like thriving, you know? **Michelle:** have any, even if it's like minute, it means that there's an autoimmune, like  **Hannah:** Right. And.  **Michelle:** your thyroid.  **Hannah:** Yeah, and I mean, my first thought is like, and just because I've worked in that arena for so long, is I think it's just because they need to have a diagnose, a diagnosis for a chronic disease, number one, so that they can build insurance and blah, blah, blah.  **Michelle:** Yeah, yeah, yeah.  **Hannah:** So they typically can't treat you. They can't, they [00:37:00] technically can't treat you. **Hannah:** Like they don't really run on a, it's more of like a sick care model. It's not really, they can't really treat you for like prevention. Right. That's not like that that's not how insurance companies work. So, I think that that's, that's my theory on that. But, you know, but to, to answer your question, yes, I, I see, low levels that aren't considered Hashimoto's,  **Michelle:** Right?  **Hannah:** but I would label that early stages or stage one, and I would say, let's work, let's, let's order GI Map. **Hannah:** Let's look at what your minerals are doing like that impact your thyroid. Let's just, just start helping you feel better right away so that we can go into remission. I would much rather my client like, just go ahead and work on those things instead of waiting until it's like, you know, now we're seeing tissue damage, you know, and there's a lot of practices. **Hannah:** I don't,  **Michelle:** it if it's early enough, like, but if it's  **Hannah:** yeah.  **Michelle:** really like far gone,  **Hannah:** Yeah. It can, and I don't know if you've run [00:38:00] across this a lot in your practice or with your clients, but I've been told a lot of times that they weren't even able to request or see a specialist or an endocrinologist, I guess, until they were able to see tissue damage. And it's like, wouldn't you wanna just prevent the tissue damage? **Michelle:** crazy to me. Yeah.  **Hannah:** Mm-hmm. Yeah, so I'm, you know, I just like to get on it like right away, even if it's like, you know, your antibodies are like five, you know?  **Michelle:** yeah, yeah, yeah, yeah. Really low, but still,  **Hannah:** Yeah. Really low. Yeah. It's worth working on. Yeah. **Michelle:** I had actually just recently, I had a case where her TSH was like five and she's young, she's in her twenties. And I'm  **Hannah:** Mm-hmm.  **Michelle:** not normal.  **Hannah:** Mm-hmm. **Michelle:** just a little abnormal. **Michelle:** But that's not a little abnormal for try somebody trying to conceive.  **Hannah:** Yeah.  **Michelle:** and under. So if you  **Hannah:** Mm-hmm. **Michelle:** the thing. If you go to a general doctor or even an ob, they are a little more general in women's health.  **Hannah:** Yeah. **Michelle:** they're not going [00:39:00] to look at it the same way as an REI is gonna look at it, which is a reproductive endocrinologist and they're gonna  **Hannah:** Right.  **Michelle:** it a completely different perspective.  **Michelle:** Yeah, so it's, so those things I think a lot of people just don't realize and they're going in and they get the wrong information or they don't get like the full information and many years go by and it's kind of like, you know, that's why it's so important to really get ahead of it. **Hannah:** Yeah, absolutely. I think you're, you're worthy of feeling better, you know, if, does it have to be something that's chronic or.  **Michelle:** Right.  **Hannah:** Like full on disease state before just feeling better. **Michelle:** Yeah, for sure. So for people who, you know, are curious and wanna learn more about what you do,  **Michelle:** um, what are some of the things that you offer online? Where can people find you? I.  **Hannah:** So for people who are wanting to work one-on-one with me or maybe just start off with [00:40:00] a consultation or some have some labs done you can find me at through Pivot Nutrition Coaching. So the website is pivot nutrition coaching com. And then if, for my social media, I'm on Instagram with Hannah. **Michelle:** Awesome. I'll have all the notes anyway. If anybody like is curious or wants to know exactly how it's written out or find the link, you can find those on the episode notes. So Hannah, thank you so much for coming on today. It was a great conversation. I love really digging deep on just what goes on with these conditions that so many people hear about that are trying to conceive, but they don't really understand it. **Michelle:** And I think. There's so much power and knowledge and understanding and kind of like going beneath the surface. So I think this is one of the things that I like to do on the show is really to educate people on like really what's going on. So you've really shared some great, valuable information, so thank you so much, Hannah.[00:41:00]  **Hannah:** Thank you so much for having me and I, I think that this is such an important, important conversation to have and a valuable platform, so it's really an honor to be here. And hope we can chat again soon. **Michelle:** Thank you.         

Jay-Z's legal team has filed a motion to dismiss a lawsuit accusing the rapper of rape, arguing that the case is based on allegations tainted by "severe" legal misconduct. The accuser, who claims the incident occurred decades ago, gave a public interview that Jay-Z's lawyers contend violates legal norms, potentially prejudicing the case. They argue that the interview and the accuser's public statements were orchestrated to garner publicity and improperly influence the court proceedings. Additionally, Jay-Z's legal team insists that the claims are not only unsubstantiated but also barred by the statute of limitations, rendering the lawsuit legally deficient.The motion highlights the inconsistencies and credibility issues in the accuser's narrative, alleging that her actions undermine the integrity of the legal process. Jay-Z's attorneys also stress that the public nature of her interview disregards legal protocols designed to ensure a fair trial. They maintain that the lawsuit is baseless and represents an abuse of the judicial system, urging the court to dismiss the case promptly. (commercial at 9:29)to contact me:bobbycapucci@protonmail.comsource:Jay-Z's lawyers ask to dismiss rape lawsuit after accuser's interview amid 'severe' legal misconduct | Daily Mail Online

In the Reply Memorandum of Law supporting Sean Combs' motion to dismiss the amended complaint in Thalia Graves v. Sean Combs and Joseph Sherman, Combs' legal team reiterates that the plaintiff's claims are both legally and factually insufficient. They argue that the amended complaint relies on conclusory allegations without concrete evidence of Combs' direct involvement in the alleged misconduct. The reply further contends that the complaint improperly attempts to attribute liability to Combs through speculative inferences about his association with co-defendant Joseph Sherman, rather than demonstrating specific acts or intent required under the applicable legal standards.Additionally, Combs' attorneys assert that many of the claims are time-barred and fall outside the statute of limitations. The reply memorandum emphasizes that the plaintiff's attempt to revive these claims through generalized references to a purported ongoing pattern of misconduct is legally untenable. They also argue that the complaint fails to meet the heightened pleading standards required for claims of intentional infliction of emotional distress and other tort-based allegations. On these grounds, the defense urges the court to dismiss the amended complaint in its entirety, with prejudice.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.630450.87.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-moscow-murders-and-more--5852883/support.

Did Blake Lively's publicist get a reporter to lie under oath? Let's discuss. Plus, new TikTok video details what Blake's like out in public. Call Her Daddy's Alex Cooper has a new documentary out, as she accuses her former coach of harassment. Meghan Markle's baby bump debacle continues, as Candiace Dillard Bassett weighs in! Nancy and Stephanie Sidley from Twin Talk ⁠(www.youtube.com/@sidleytwins4823) ⁠ are here to dish!    Improve your mind and energy with RECHARGE from The Wellness Company! Visit http://www.twc.health/nofilter and use code NOFILTER for 15% Off + Free Shipping on ever order.   Keep your eagle eyes looking sharp. Go to http://www.paireyewear.com and use code NOFILTER for 15% off your first pair.    Get your tour tickets to see No Filter with Zack Peter LIVE: https://www.x1entertainment.com/zackpeter    Shop New Merch now: https://merchlabs.com/collections/zack-peter?srsltid=AfmBOoqqnV3kfsOYPubFFxCQdpCuGjVgssGIXZRXHcLPH9t4GjiKoaio   Book a personalized message on Cameo: https://v.cameo.com/e/QxWQhpd1TIb   Listen to The Pop Report: https://podcasts.apple.com/us/podcast/the-pop-report/id1746150111   Watch Disaster Daters: https://open.spotify.com/show/3L4GLnKwz9Uy5dT8Ey1VPi   Join the Zack Pack Community to get access to perks: https://www.youtube.com/channel/UCs3Zs51YaK-xw2U5ypi5eqg/join   Couldn't get enough? Follow @justplainzack or @nofilterwithzack

In the Reply Memorandum of Law supporting Sean Combs' motion to dismiss the amended complaint in Thalia Graves v. Sean Combs and Joseph Sherman, Combs' legal team reiterates that the plaintiff's claims are both legally and factually insufficient. They argue that the amended complaint relies on conclusory allegations without concrete evidence of Combs' direct involvement in the alleged misconduct. The reply further contends that the complaint improperly attempts to attribute liability to Combs through speculative inferences about his association with co-defendant Joseph Sherman, rather than demonstrating specific acts or intent required under the applicable legal standards.Additionally, Combs' attorneys assert that many of the claims are time-barred and fall outside the statute of limitations. The reply memorandum emphasizes that the plaintiff's attempt to revive these claims through generalized references to a purported ongoing pattern of misconduct is legally untenable. They also argue that the complaint fails to meet the heightened pleading standards required for claims of intentional infliction of emotional distress and other tort-based allegations. On these grounds, the defense urges the court to dismiss the amended complaint in its entirety, with prejudice.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.630450.87.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

OK.  You still with me?  Yes, it has been a while.  We don't even know.... We catch up with the last year!  You can fast forward.  Or not. Ever dismissed an entire family for the behavior of a single member?  Dismiss the ONE?  Or is it grounds to dismiss EVERYONE?  Can you hate TOO many people? Petty cash.  Do you still use that?  Why/why not?   Shout out to The Stanley Institute, Implant Pathways, Beever Dental Lab, Chucri Chemali, IDS, Smile Line Europe, Smile Line USA

A memorandum in support of a request for dismissal of a complaint is a legal document submitted to a court that outlines the reasons why a complaint should be dismissed. This type of memorandum is typically prepared by the defendant or their legal counsel and presented to the court as part of the pre-trial proceedings.In this document, the defendant usually provides legal arguments and evidence to support their request for dismissal. This could include demonstrating that the complaint fails to state a valid legal claim, that there is a lack of jurisdiction, or that there are other legal grounds for dismissal.The memorandum serves as a persuasive tool for the court, aiming to convince the judge that the complaint does not have merit and should not proceed to trial. It is important for the memorandum to be well-researched, clearly written, and supported by relevant legal precedent.In this episode we begin our look at the UMG memorandum in support of dismissing the complaint filed against them by Rodney Jones.   (commercial at 7:27)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.616406.41.0.pdf (courtlistener.com)

A memorandum in support of a request for dismissal of a complaint is a legal document submitted to a court that outlines the reasons why a complaint should be dismissed. This type of memorandum is typically prepared by the defendant or their legal counsel and presented to the court as part of the pre-trial proceedings.In this document, the defendant usually provides legal arguments and evidence to support their request for dismissal. This could include demonstrating that the complaint fails to state a valid legal claim, that there is a lack of jurisdiction, or that there are other legal grounds for dismissal.The memorandum serves as a persuasive tool for the court, aiming to convince the judge that the complaint does not have merit and should not proceed to trial. It is important for the memorandum to be well-researched, clearly written, and supported by relevant legal precedent.In this episode we begin our look at the UMG memorandum in support of dismissing the complaint filed against them by Rodney Jones.   (commercial at 7:27)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.616406.41.0.pdf (courtlistener.com)

In this filing, plaintiff Anthony Tate submits a Memorandum of Law opposing Defendants' Motion to Dismiss in the civil case against Sean Combs and his affiliated corporate entities, including Daddy's House Recordings, Combs Global, and various Bad Boy Entertainment subsidiaries. Tate argues that his complaint sufficiently states claims for relief and that dismissal is unwarranted at this stage. The opposition contends that the complaint provides detailed factual allegations that meet the pleading standards required under Federal Rule of Civil Procedure 12(b)(6), addressing each of the Defendants' arguments for dismissal. Tate emphasizes that the alleged conduct—spanning personal misconduct by Combs and organizational liability through the named corporate entities—is sufficiently documented to move forward to discovery.Furthermore, the memorandum asserts that the corporate defendants should not be dismissed merely because Combs is a named individual defendant; instead, Tate argues that the corporate entities were allegedly used to facilitate or conceal the unlawful acts in question. The opposition also challenges any argument that certain claims are time-barred, asserting that various legal doctrines—including equitable tolling and the discovery rule—preserve the plaintiff's ability to pursue those claims. Ultimately, Tate urges the Court to deny the Motion to Dismiss in full and allow the case to proceed, arguing that the defendants' motion relies heavily on factual disputes inappropriate for resolution at the motion-to-dismiss stage.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.632026.46.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

A memorandum in support of a request for dismissal of a complaint is a legal document submitted to a court that outlines the reasons why a complaint should be dismissed. This type of memorandum is typically prepared by the defendant or their legal counsel and presented to the court as part of the pre-trial proceedings.In this document, the defendant usually provides legal arguments and evidence to support their request for dismissal. This could include demonstrating that the complaint fails to state a valid legal claim, that there is a lack of jurisdiction, or that there are other legal grounds for dismissal.The memorandum serves as a persuasive tool for the court, aiming to convince the judge that the complaint does not have merit and should not proceed to trial. It is important for the memorandum to be well-researched, clearly written, and supported by relevant legal precedent.In this episode we begin our look at the UMG memorandum in support of dismissing the complaint filed against them by Rodney Jones.   (commercial at 7:27)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.616406.41.0.pdf (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-moscow-murders-and-more--5852883/support.

A memorandum in support of a request for dismissal of a complaint is a legal document submitted to a court that outlines the reasons why a complaint should be dismissed. This type of memorandum is typically prepared by the defendant or their legal counsel and presented to the court as part of the pre-trial proceedings.In this document, the defendant usually provides legal arguments and evidence to support their request for dismissal. This could include demonstrating that the complaint fails to state a valid legal claim, that there is a lack of jurisdiction, or that there are other legal grounds for dismissal.The memorandum serves as a persuasive tool for the court, aiming to convince the judge that the complaint does not have merit and should not proceed to trial. It is important for the memorandum to be well-researched, clearly written, and supported by relevant legal precedent.In this episode we begin our look at the UMG memorandum in support of dismissing the complaint filed against them by Rodney Jones.   (commercial at 7:27)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.616406.41.0.pdf (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-moscow-murders-and-more--5852883/support.

A memorandum in support of a request for dismissal of a complaint is a legal document submitted to a court that outlines the reasons why a complaint should be dismissed. This type of memorandum is typically prepared by the defendant or their legal counsel and presented to the court as part of the pre-trial proceedings.In this document, the defendant usually provides legal arguments and evidence to support their request for dismissal. This could include demonstrating that the complaint fails to state a valid legal claim, that there is a lack of jurisdiction, or that there are other legal grounds for dismissal.The memorandum serves as a persuasive tool for the court, aiming to convince the judge that the complaint does not have merit and should not proceed to trial. It is important for the memorandum to be well-researched, clearly written, and supported by relevant legal precedent.In this episode we begin our look at the UMG memorandum in support of dismissing the complaint filed against them by Rodney Jones.   (commercial at 7:27)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.616406.41.0.pdf (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

A memorandum in support of a request for dismissal of a complaint is a legal document submitted to a court that outlines the reasons why a complaint should be dismissed. This type of memorandum is typically prepared by the defendant or their legal counsel and presented to the court as part of the pre-trial proceedings.In this document, the defendant usually provides legal arguments and evidence to support their request for dismissal. This could include demonstrating that the complaint fails to state a valid legal claim, that there is a lack of jurisdiction, or that there are other legal grounds for dismissal.The memorandum serves as a persuasive tool for the court, aiming to convince the judge that the complaint does not have merit and should not proceed to trial. It is important for the memorandum to be well-researched, clearly written, and supported by relevant legal precedent.In this episode we begin our look at the UMG memorandum in support of dismissing the complaint filed against them by Rodney Jones.   (commercial at 7:27)to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.616406.41.0.pdf (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

In his ruling, U.S. District Judge Lewis A. Kaplan denied Sean Combs' motion to dismiss the civil lawsuit filed by Anthony Tate, allowing the case to proceed. The lawsuit alleges that Combs sexually assaulted Tate in the 1990s when Tate was a minor. Combs' legal team had argued for dismissal on several grounds, including statute of limitations and insufficiency of the claims under relevant law. However, Judge Kaplan concluded that the complaint plausibly alleged conduct falling within the scope of the New York Adult Survivors Act, which temporarily revives claims of sexual misconduct that would otherwise be time-barred. The judge emphasized that the law's purpose was to give survivors of sexual abuse a chance to seek justice regardless of when the alleged abuse occurred.Additionally, Judge Kaplan found that Tate's allegations were specific enough to survive a motion to dismiss. He rejected arguments that the claims were too vague or lacked the necessary legal basis, ruling that the complaint provided sufficient detail to warrant further proceedings. The court did not make any determinations about the truth of the allegations but affirmed that Tate's claims met the legal threshold to move forward. As a result, the case against Combs will proceed into the discovery phase, where both sides will gather evidence before any potential trial or settlement.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.632026.48.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-moscow-murders-and-more--5852883/support.

In the case of John Doe v. Sean Combs et al. (No. 1:24-cv-07973-RA), the plaintiff opposes the Combs Defendants' motion to dismiss, asserting that the complaint sufficiently alleges claims of sexual assault, battery, and related misconduct. The plaintiff argues that the detailed allegations meet the legal standards required to proceed, emphasizing that the complaint provides specific instances of the defendants' alleged wrongful conduct. Furthermore, the plaintiff contends that the motion to dismiss should be denied because the claims are not barred by any applicable statutes of limitations, and the complaint adequately states claims upon which relief can be granted.The plaintiff also addresses the defendants' arguments regarding the sufficiency of the pleadings and the applicability of certain defenses, maintaining that these issues are more appropriately addressed at later stages of the litigation, such as summary judgment or trial. By highlighting the factual allegations and legal theories presented in the complaint, the plaintiff seeks to demonstrate that the case merits further judicial proceedings and should not be dismissed at this preliminary stage.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.630242.68.0.pdf

In the case of John Doe v. Sean Combs et al. (No. 1:24-cv-07973-RA), the plaintiff opposes the Combs Defendants' motion to dismiss, asserting that the complaint sufficiently alleges claims of sexual assault, battery, and related misconduct. The plaintiff argues that the detailed allegations meet the legal standards required to proceed, emphasizing that the complaint provides specific instances of the defendants' alleged wrongful conduct. Furthermore, the plaintiff contends that the motion to dismiss should be denied because the claims are not barred by any applicable statutes of limitations, and the complaint adequately states claims upon which relief can be granted.The plaintiff also addresses the defendants' arguments regarding the sufficiency of the pleadings and the applicability of certain defenses, maintaining that these issues are more appropriately addressed at later stages of the litigation, such as summary judgment or trial. By highlighting the factual allegations and legal theories presented in the complaint, the plaintiff seeks to demonstrate that the case merits further judicial proceedings and should not be dismissed at this preliminary stage.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.630242.68.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

In the case of John Doe v. Sean Combs et al. (No. 1:24-cv-07973-RA), the plaintiff opposes the Combs Defendants' motion to dismiss, asserting that the complaint sufficiently alleges claims of sexual assault, battery, and related misconduct. The plaintiff argues that the detailed allegations meet the legal standards required to proceed, emphasizing that the complaint provides specific instances of the defendants' alleged wrongful conduct. Furthermore, the plaintiff contends that the motion to dismiss should be denied because the claims are not barred by any applicable statutes of limitations, and the complaint adequately states claims upon which relief can be granted.The plaintiff also addresses the defendants' arguments regarding the sufficiency of the pleadings and the applicability of certain defenses, maintaining that these issues are more appropriately addressed at later stages of the litigation, such as summary judgment or trial. By highlighting the factual allegations and legal theories presented in the complaint, the plaintiff seeks to demonstrate that the case merits further judicial proceedings and should not be dismissed at this preliminary stage.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.630242.68.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-moscow-murders-and-more--5852883/support.

Hey, Heal Squad! We're bringing back a powerful two-part conversation with Anthony William, otherwise known as the Medical Medium! Trust us, it's just as relevant today as it was when we first aired it. In Part 1, Anthony opens up about the misunderstood root causes of so many chronic health issues, from anxiety and fatigue to autoimmune conditions and mystery symptoms doctors often dismiss. He explains why heavy metals, viral load, and liver congestion may be silently impacting your brain, skin, energy, and even your relationships. Anthony also dives into how foods like celery juice, wild blueberries, and lemon water are more than just trends…they're powerful tools to cleanse, rebuild, and restore your body from the inside out. If you've ever felt unheard, misdiagnosed, or stuck in survival mode, this episode is for you. Tune in to start getting answers and real solutions that empower you to take your healing into your own hands.  HEALERS & HEAL-LINERS:  Toxic overload isn't just food-related. Fragrances, heavy metals, and environmental pollution are silent contributors to chronic illness, and most people don't even know they're being exposed. Fish oil isn't always a friend. While often seen as a health staple, Anthony challenges its benefits and warns about hidden dangers most doctors won't tell you about. Your bloodwork may not be telling the full story. Common testing practices could disrupt your body more than help it. Anthony explains how to protect your health when giving blood samples. -- HEAL SQUAD SOCIALS IG: https://www.instagram.com/healsquad/ TikTok: https://www.tiktok.com/@healsquadxmaria HEAL SQUAD RESOURCES: Heal Squad Website:https://www.healsquad.com/ Heal Squad x Patreon: https://www.patreon.com/HealSquad/membership Maria Menounos Website: https://www.mariamenounos.com My Curated Macy's Page: Shop My Macy's Storefront Prenuvo: Prenuvo.com/MARIA for $300 off Delete Me: https://bit.ly/43rkHwi   code: SQUAD EMR-Tek Red Light: https://emr-tek.com/discount/Maria30 for 30% off Airbnb: https://www.airbnb.com/  Join In-Person Heal Retreat Waitlist! https://mariamenounos.myflodesk.com/heal-retreat-waitlist THE MEDICAL MEDIUM RESOURCES: Instagram: https://www.instagram.com/medicalmedium/?hl=en  Website: https://www.medicalmedium.com/  Find Anthony's books (& some of my other favorites!) here: https://shopmy.us/collections/106835 ABOUT MARIA MENOUNOS: Emmy Award-winning journalist, TV personality, actress, 2x NYT best-selling author, former pro-wrestler and brain tumor survivor, Maria Menounos' passion is to see others heal and to get better in all areas of life. ABOUT HEAL SQUAD x MARIA MENOUNOS: A daily digital talk-show that brings you the world's leading healers, experts, and celebrities to share groundbreaking secrets and tips to getting better in all areas of life. DISCLAIMER: This Podcast and all related content (published or distributed by or on behalf of Maria Menounos or http://Mariamenounos.com and http://healsquad.com) is for informational purposes only and may include information that is general in nature and that is not specific to you. Any information or opinions provided by guest experts or hosts featured within website or on Company's Podcast are their own; not those of Maria Menounos or the Company. Accordingly, Maria Menounos and the Company cannot be responsible for any results or consequences or actions you may take based on such information or opinions. This podcast is presented for exploratory purposes only. Published content is not intended to be used for preventing, diagnosing, or treating a specific illness. If you have, or suspect you may have, a health-care emergency, please contact a qualified health care professional for treatment.

HEADLINES: 'Resolution' to dismiss impeachment trial hit | June 5, 2025Subscribe to The Manila Times Channel - https://tmt.ph/YTSubscribe Visit our website at https://www.manilatimes.net Follow us: Facebook - https://tmt.ph/facebook Instagram - https://tmt.ph/instagram Twitter - https://tmt.ph/twitter DailyMotion - https://tmt.ph/dailymotion Subscribe to our Digital Edition - https://tmt.ph/digital Check out our Podcasts: Spotify - https://tmt.ph/spotify Apple Podcasts - https://tmt.ph/applepodcasts Amazon Music - https://tmt.ph/amazonmusic Deezer: https://tmt.ph/deezer Stitcher: https://tmt.ph/stitcherTune In: https://tmt.ph/tunein #TheManilaTimes#KeepUpWithTheTimes Hosted on Acast. See acast.com/privacy for more information.

In this filing, the plaintiff—identified as John Doe—opposes the defendants' motion to dismiss his civil lawsuit against Sean Combs and a series of related business entities. Doe's opposition argues that the complaint sufficiently alleges multiple counts of sex trafficking, battery, assault, and intentional infliction of emotional distress under both federal and state law. The document asserts that the claims are not time-barred under the Trafficking Victims Protection Act (TVPA) or New York's Adult Survivors Act, and that the plaintiff has presented enough factual detail to meet the pleading standards required by federal court. He alleges that Combs used his vast network of companies and affiliates to facilitate, cover up, and enable repeated acts of sexual abuse and psychological coercion.Doe also challenges the defense's attempts to downplay Combs' alleged role in the abuse by arguing that his status as a corporate executive does not shield him from personal liability. The opposition brief emphasizes that Combs maintained direct control over the events in question, and that his affiliated entities—ranging from Bad Boy Entertainment to Combs Global—were tools used to recruit, exploit, and silence victims. The plaintiff's legal team contends that discovery should proceed so the full extent of Combs' alleged criminal enterprise can be examined through the civil process.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.630243.62.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

In this filing, the plaintiff—identified as John Doe—opposes the defendants' motion to dismiss his civil lawsuit against Sean Combs and a series of related business entities. Doe's opposition argues that the complaint sufficiently alleges multiple counts of sex trafficking, battery, assault, and intentional infliction of emotional distress under both federal and state law. The document asserts that the claims are not time-barred under the Trafficking Victims Protection Act (TVPA) or New York's Adult Survivors Act, and that the plaintiff has presented enough factual detail to meet the pleading standards required by federal court. He alleges that Combs used his vast network of companies and affiliates to facilitate, cover up, and enable repeated acts of sexual abuse and psychological coercion.Doe also challenges the defense's attempts to downplay Combs' alleged role in the abuse by arguing that his status as a corporate executive does not shield him from personal liability. The opposition brief emphasizes that Combs maintained direct control over the events in question, and that his affiliated entities—ranging from Bad Boy Entertainment to Combs Global—were tools used to recruit, exploit, and silence victims. The plaintiff's legal team contends that discovery should proceed so the full extent of Combs' alleged criminal enterprise can be examined through the civil process.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.630243.62.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-moscow-murders-and-more--5852883/support.

In his ruling, U.S. District Judge Lewis A. Kaplan denied Sean Combs' motion to dismiss the civil lawsuit filed by Anthony Tate, allowing the case to proceed. The lawsuit alleges that Combs sexually assaulted Tate in the 1990s when Tate was a minor. Combs' legal team had argued for dismissal on several grounds, including statute of limitations and insufficiency of the claims under relevant law. However, Judge Kaplan concluded that the complaint plausibly alleged conduct falling within the scope of the New York Adult Survivors Act, which temporarily revives claims of sexual misconduct that would otherwise be time-barred. The judge emphasized that the law's purpose was to give survivors of sexual abuse a chance to seek justice regardless of when the alleged abuse occurred.Additionally, Judge Kaplan found that Tate's allegations were specific enough to survive a motion to dismiss. He rejected arguments that the claims were too vague or lacked the necessary legal basis, ruling that the complaint provided sufficient detail to warrant further proceedings. The court did not make any determinations about the truth of the allegations but affirmed that Tate's claims met the legal threshold to move forward. As a result, the case against Combs will proceed into the discovery phase, where both sides will gather evidence before any potential trial or settlement.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.632026.48.0.pdf

In Case No. 1:24-cv-07975-AT, Defendant Shawn Carter, professionally known as Jay-Z, has filed a Memorandum of Law supporting his motion to dismiss the Plaintiff's First Amended Complaint. Carter argues that the Plaintiff's allegations lack sufficient legal basis and fail to meet the necessary pleading standards required to proceed with the case. He contends that the complaint does not present concrete facts to substantiate the claims made against him, rendering the lawsuit legally deficient.Furthermore, Carter emphasizes that the Plaintiff's complaint is not only baseless but also frivolous, warranting dismissal under Federal Rule of Civil Procedure 11. He asserts that the allegations are unfounded and appear to be an attempt to misuse the legal system, potentially causing unwarranted harm to his reputation. Carter's memorandum seeks both the dismissal of the complaint and the imposition of sanctions against the Plaintiff for filing a meritless lawsuit.to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - Motion to Dismiss FAC (SDNY) (15549242_8) (004).docx

In Case No. 1:24-cv-07975-AT, Defendant Shawn Carter, professionally known as Jay-Z, has filed a Memorandum of Law supporting his motion to dismiss the Plaintiff's First Amended Complaint. Carter argues that the Plaintiff's allegations lack sufficient legal basis and fail to meet the necessary pleading standards required to proceed with the case. He contends that the complaint does not present concrete facts to substantiate the claims made against him, rendering the lawsuit legally deficient.Furthermore, Carter emphasizes that the Plaintiff's complaint is not only baseless but also frivolous, warranting dismissal under Federal Rule of Civil Procedure 11. He asserts that the allegations are unfounded and appear to be an attempt to misuse the legal system, potentially causing unwarranted harm to his reputation. Carter's memorandum seeks both the dismissal of the complaint and the imposition of sanctions against the Plaintiff for filing a meritless lawsuit.to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - Motion to Dismiss FAC (SDNY) (15549242_8) (004).docx

In Case No. 1:24-cv-07975-AT, Defendant Shawn Carter, professionally known as Jay-Z, has filed a Memorandum of Law supporting his motion to dismiss the Plaintiff's First Amended Complaint. Carter argues that the Plaintiff's allegations lack sufficient legal basis and fail to meet the necessary pleading standards required to proceed with the case. He contends that the complaint does not present concrete facts to substantiate the claims made against him, rendering the lawsuit legally deficient.Furthermore, Carter emphasizes that the Plaintiff's complaint is not only baseless but also frivolous, warranting dismissal under Federal Rule of Civil Procedure 11. He asserts that the allegations are unfounded and appear to be an attempt to misuse the legal system, potentially causing unwarranted harm to his reputation. Carter's memorandum seeks both the dismissal of the complaint and the imposition of sanctions against the Plaintiff for filing a meritless lawsuit.to contact me:bobbycapucci@protonmail.comsource:Microsoft Word - Motion to Dismiss FAC (SDNY) (15549242_8) (004).docx

Diddy has fired back at Joi Dickerson Neal and her allegations against him and in this episode, we are going to get a look at what Diddy had to say.   A "Memorandum of Law in Support of Defendants' Partial Motion to Dismiss the Complaint" is a legal document filed by defendants in a lawsuit. Let's break down what each component means:Memorandum of Law: This is a written legal document that presents arguments and supporting authorities (such as statutes, regulations, and case law) in support of a specific legal position. It is used to persuade the court to rule in favor of the party presenting the memorandum.Defendants' Partial Motion to Dismiss: A motion to dismiss is a request made by one party in a lawsuit to terminate the case before it goes to trial. In this case, the defendants are asking the court to dismiss only certain parts of the complaint filed against them. This motion is "partial" because it seeks dismissal of only some claims or allegations, rather than the entire complaint.The Complaint: This refers to the initial document filed by the plaintiff(s) in a lawsuit, which outlines the claims and allegations against the defendant(s). The defendants' motion to dismiss is a response to the complaint, arguing that some or all of the claims in the complaint should be dismissed for various reasons, such as failure to state a legal claim, lack of jurisdiction, or other deficiencies in the complaint.So, the "Memorandum of Law in Support of Defendants' Partial Motion to Dismiss the Complaint" would be a document prepared by the defendants' legal team that lays out the legal arguments and authorities supporting their request to dismiss certain parts of the complaint. It would likely include analysis of relevant case law, statutes, and legal principles to demonstrate why the court should grant their motion to dismiss.(commercial at 10:34)to contact me:bobbycapucci@protonmail.comsource:diddy-motion.pdf (documentcloud.org)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

Diddy has fired back at Joi Dickerson Neal and her allegations against him and in this episode, we are going to get a look at what Diddy had to say.   A "Memorandum of Law in Support of Defendants' Partial Motion to Dismiss the Complaint" is a legal document filed by defendants in a lawsuit. Let's break down what each component means:Memorandum of Law: This is a written legal document that presents arguments and supporting authorities (such as statutes, regulations, and case law) in support of a specific legal position. It is used to persuade the court to rule in favor of the party presenting the memorandum.Defendants' Partial Motion to Dismiss: A motion to dismiss is a request made by one party in a lawsuit to terminate the case before it goes to trial. In this case, the defendants are asking the court to dismiss only certain parts of the complaint filed against them. This motion is "partial" because it seeks dismissal of only some claims or allegations, rather than the entire complaint.The Complaint: This refers to the initial document filed by the plaintiff(s) in a lawsuit, which outlines the claims and allegations against the defendant(s). The defendants' motion to dismiss is a response to the complaint, arguing that some or all of the claims in the complaint should be dismissed for various reasons, such as failure to state a legal claim, lack of jurisdiction, or other deficiencies in the complaint.So, the "Memorandum of Law in Support of Defendants' Partial Motion to Dismiss the Complaint" would be a document prepared by the defendants' legal team that lays out the legal arguments and authorities supporting their request to dismiss certain parts of the complaint. It would likely include analysis of relevant case law, statutes, and legal principles to demonstrate why the court should grant their motion to dismiss.(commercial at 10:34)to contact me:bobbycapucci@protonmail.comsource:diddy-motion.pdf (documentcloud.org)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

The Chrisleys are coming home! Donald Trump just announced plans to pardon Todd and Julie Chrisley. Plus, Blake Lively files yet another letter to the judge, compelling her to be dismissed from Justin Baldoni's lawsuit.   Bring on the good vibes and treat yourself to Soul today! Head to www.GetSoul.com and use the code NOFILTER for 30% off!   Get your tour tickets to see No Filter with Zack Peter LIVE: https://www.x1entertainment.com/zackpeter    Shop New Merch now: https://merchlabs.com/collections/zack-peter?srsltid=AfmBOoqqnV3kfsOYPubFFxCQdpCuGjVgssGIXZRXHcLPH9t4GjiKoaio   Book a personalized message on Cameo: https://v.cameo.com/e/QxWQhpd1TIb   Listen to The Pop Report: https://podcasts.apple.com/us/podcast/the-pop-report/id1746150111   Watch Disaster Daters: https://open.spotify.com/show/3L4GLnKwz9Uy5dT8Ey1VPi   Join the Zack Pack Community to get access to perks: https://www.youtube.com/channel/UCs3Zs51YaK-xw2U5ypi5eqg/join   Couldn't get enough? Follow @justplainzack or @nofilterwithzack

In his ruling, U.S. District Judge Lewis A. Kaplan denied Sean Combs' motion to dismiss the civil lawsuit filed by Anthony Tate, allowing the case to proceed. The lawsuit alleges that Combs sexually assaulted Tate in the 1990s when Tate was a minor. Combs' legal team had argued for dismissal on several grounds, including statute of limitations and insufficiency of the claims under relevant law. However, Judge Kaplan concluded that the complaint plausibly alleged conduct falling within the scope of the New York Adult Survivors Act, which temporarily revives claims of sexual misconduct that would otherwise be time-barred. The judge emphasized that the law's purpose was to give survivors of sexual abuse a chance to seek justice regardless of when the alleged abuse occurred.Additionally, Judge Kaplan found that Tate's allegations were specific enough to survive a motion to dismiss. He rejected arguments that the claims were too vague or lacked the necessary legal basis, ruling that the complaint provided sufficient detail to warrant further proceedings. The court did not make any determinations about the truth of the allegations but affirmed that Tate's claims met the legal threshold to move forward. As a result, the case against Combs will proceed into the discovery phase, where both sides will gather evidence before any potential trial or settlement.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.632026.48.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

The Combs Defendants have notified the Court of their intent to file a motion to dismiss the Complaint filed by Plaintiff Dawn Richard under Rule 12(b)(6) of the Federal Rules of Civil Procedure. Richard's Complaint asserts 21 causes of action against more than two dozen defendants, alleging a wide-ranging sex trafficking conspiracy. However, the Combs Defendants argue that the claims are baseless, stating that even if the alleged facts were true (which they deny), they do not substantiate the claims made in the Complaint.The Defendants further contend that the claims are insufficiently pled, lack legal merit, and are barred due to being untimely by several years. Additionally, they highlight that contractual releases signed by the Plaintiff preclude these claims. The Defendants characterize the Complaint as an attempt to sensationalize what they describe as a straightforward commercial dispute.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628103.121.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

In a letter to Judge Buchwald, attorneys representing Sean Combs and his associated companies—Bad Boy Entertainment LLC, Bad Boy Entertainment Holdings, Inc., Sean John Clothing LLC, and Daddy's House Recordings, Inc.—requested a pre-motion conference to discuss their intent to file a motion to dismiss the Amended Complaint. They argue that the plaintiff's claim is preempted by New York State law and fails to establish a viable legal basis for holding the corporate entities liable, seeking dismissal under Federal Rule of Civil Procedure 12(b)(6).In a letter to the court, attorneys for Plaintiff Crystal McKinney oppose Defendants' request for a pre-motion conference regarding their anticipated Motion to Dismiss her Amended Complaint. The Defendants claim that the NYC Gender Motivated Violence Protection Act (GMVA) is preempted by state law; however, McKinney's attorneys argue that this argument has already been rejected by the Appellate Division. They contend that McKinney's Amended Complaint contains well-pled allegations of sexual assault, physical abuse, and/or forcible drugging, which meet the requirements of the GMVA, and therefore, the motion to dismiss should fail.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.621909.27.0.pdfsource:gov.uscourts.nysd.621909.26.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

​In Case No. 24-CV-08808-JAV, the defendants, including Sean Combs, have filed a Motion to Dismiss the complaint brought against them by the plaintiff, identified as Jane Doe. In their memorandum supporting this motion, the Combs defendants argue that the court lacks subject matter jurisdiction, asserting that the plaintiff has not demonstrated an "injury in fact" necessary for standing. They contend that the alleged injuries are speculative and not concrete or imminent, as required by legal standards.to contact me:bobbycapucci@protonmail.comsources:gov.uscourts.nysd.632024.32.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

​In Case No. 24-CV-08808-JAV, the defendants, including Sean Combs, have filed a Motion to Dismiss the complaint brought against them by the plaintiff, identified as Jane Doe. In their memorandum supporting this motion, the Combs defendants argue that the court lacks subject matter jurisdiction, asserting that the plaintiff has not demonstrated an "injury in fact" necessary for standing. They contend that the alleged injuries are speculative and not concrete or imminent, as required by legal standards.to contact me:bobbycapucci@protonmail.comsources:gov.uscourts.nysd.632024.32.0.pdf

In the memorandum supporting their consolidated motion to dismiss, the defendants in the case of Dawn Angelique Richard v. Sean Combs et al. argue that the plaintiff's claims are largely time-barred under New York's statutes of limitations. They contend that the state's shorter limitation periods should apply, rendering many of the plaintiff's causes of action untimely. Specifically, they assert that claims related to assault, battery, false imprisonment, intentional infliction of emotional distress, trafficking, forced labor, and various employment-related allegations fall outside the permissible time frames. The defendants also challenge the applicability of revival statutes, arguing that the Gender-Motivated Violence Law (GMVL) revival provision conflicts with existing laws like the Child Victims Act (CVA) and Adult Survivors Act (ASA), and thus cannot retroactively apply to the defendants.Additionally, the defendants argue that the plaintiff's claims against various entities associated with Sean Combs, such as the "Bad Boy" and "Combs" entities, rely on improper group pleadings without specific allegations against each entity. They assert that the GMVL claim fails because the law did not apply to certain defendants at the relevant times and that the plaintiff does not sufficiently allege a gender-motivated crime of violence. Furthermore, the defendants contend that the plaintiff fails to state valid claims for forced labor, sex trafficking, discrimination under the New York State Human Rights Law, right of publicity, and unjust enrichment. They argue that these claims are either inadequately pled or legally baseless, and in some cases, barred by applicable statutes of limitations.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628103.154.0.pdf

In the memorandum supporting their consolidated motion to dismiss, the defendants in the case of Dawn Angelique Richard v. Sean Combs et al. argue that the plaintiff's claims are largely time-barred under New York's statutes of limitations. They contend that the state's shorter limitation periods should apply, rendering many of the plaintiff's causes of action untimely. Specifically, they assert that claims related to assault, battery, false imprisonment, intentional infliction of emotional distress, trafficking, forced labor, and various employment-related allegations fall outside the permissible time frames. The defendants also challenge the applicability of revival statutes, arguing that the Gender-Motivated Violence Law (GMVL) revival provision conflicts with existing laws like the Child Victims Act (CVA) and Adult Survivors Act (ASA), and thus cannot retroactively apply to the defendants.Additionally, the defendants argue that the plaintiff's claims against various entities associated with Sean Combs, such as the "Bad Boy" and "Combs" entities, rely on improper group pleadings without specific allegations against each entity. They assert that the GMVL claim fails because the law did not apply to certain defendants at the relevant times and that the plaintiff does not sufficiently allege a gender-motivated crime of violence. Furthermore, the defendants contend that the plaintiff fails to state valid claims for forced labor, sex trafficking, discrimination under the New York State Human Rights Law, right of publicity, and unjust enrichment. They argue that these claims are either inadequately pled or legally baseless, and in some cases, barred by applicable statutes of limitations.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628103.154.0.pdf

In the memorandum supporting their consolidated motion to dismiss, the defendants in the case of Dawn Angelique Richard v. Sean Combs et al. argue that the plaintiff's claims are largely time-barred under New York's statutes of limitations. They contend that the state's shorter limitation periods should apply, rendering many of the plaintiff's causes of action untimely. Specifically, they assert that claims related to assault, battery, false imprisonment, intentional infliction of emotional distress, trafficking, forced labor, and various employment-related allegations fall outside the permissible time frames. The defendants also challenge the applicability of revival statutes, arguing that the Gender-Motivated Violence Law (GMVL) revival provision conflicts with existing laws like the Child Victims Act (CVA) and Adult Survivors Act (ASA), and thus cannot retroactively apply to the defendants.Additionally, the defendants argue that the plaintiff's claims against various entities associated with Sean Combs, such as the "Bad Boy" and "Combs" entities, rely on improper group pleadings without specific allegations against each entity. They assert that the GMVL claim fails because the law did not apply to certain defendants at the relevant times and that the plaintiff does not sufficiently allege a gender-motivated crime of violence. Furthermore, the defendants contend that the plaintiff fails to state valid claims for forced labor, sex trafficking, discrimination under the New York State Human Rights Law, right of publicity, and unjust enrichment. They argue that these claims are either inadequately pled or legally baseless, and in some cases, barred by applicable statutes of limitations.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628103.154.0.pdf

In the memorandum supporting their consolidated motion to dismiss, the defendants in the case of Dawn Angelique Richard v. Sean Combs et al. argue that the plaintiff's claims are largely time-barred under New York's statutes of limitations. They contend that the state's shorter limitation periods should apply, rendering many of the plaintiff's causes of action untimely. Specifically, they assert that claims related to assault, battery, false imprisonment, intentional infliction of emotional distress, trafficking, forced labor, and various employment-related allegations fall outside the permissible time frames. The defendants also challenge the applicability of revival statutes, arguing that the Gender-Motivated Violence Law (GMVL) revival provision conflicts with existing laws like the Child Victims Act (CVA) and Adult Survivors Act (ASA), and thus cannot retroactively apply to the defendants.Additionally, the defendants argue that the plaintiff's claims against various entities associated with Sean Combs, such as the "Bad Boy" and "Combs" entities, rely on improper group pleadings without specific allegations against each entity. They assert that the GMVL claim fails because the law did not apply to certain defendants at the relevant times and that the plaintiff does not sufficiently allege a gender-motivated crime of violence. Furthermore, the defendants contend that the plaintiff fails to state valid claims for forced labor, sex trafficking, discrimination under the New York State Human Rights Law, right of publicity, and unjust enrichment. They argue that these claims are either inadequately pled or legally baseless, and in some cases, barred by applicable statutes of limitations.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628103.154.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

In the memorandum supporting their consolidated motion to dismiss, the defendants in the case of Dawn Angelique Richard v. Sean Combs et al. argue that the plaintiff's claims are largely time-barred under New York's statutes of limitations. They contend that the state's shorter limitation periods should apply, rendering many of the plaintiff's causes of action untimely. Specifically, they assert that claims related to assault, battery, false imprisonment, intentional infliction of emotional distress, trafficking, forced labor, and various employment-related allegations fall outside the permissible time frames. The defendants also challenge the applicability of revival statutes, arguing that the Gender-Motivated Violence Law (GMVL) revival provision conflicts with existing laws like the Child Victims Act (CVA) and Adult Survivors Act (ASA), and thus cannot retroactively apply to the defendants.Additionally, the defendants argue that the plaintiff's claims against various entities associated with Sean Combs, such as the "Bad Boy" and "Combs" entities, rely on improper group pleadings without specific allegations against each entity. They assert that the GMVL claim fails because the law did not apply to certain defendants at the relevant times and that the plaintiff does not sufficiently allege a gender-motivated crime of violence. Furthermore, the defendants contend that the plaintiff fails to state valid claims for forced labor, sex trafficking, discrimination under the New York State Human Rights Law, right of publicity, and unjust enrichment. They argue that these claims are either inadequately pled or legally baseless, and in some cases, barred by applicable statutes of limitations.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628103.154.0.pdf

In the memorandum supporting their consolidated motion to dismiss, the defendants in the case of Dawn Angelique Richard v. Sean Combs et al. argue that the plaintiff's claims are largely time-barred under New York's statutes of limitations. They contend that the state's shorter limitation periods should apply, rendering many of the plaintiff's causes of action untimely. Specifically, they assert that claims related to assault, battery, false imprisonment, intentional infliction of emotional distress, trafficking, forced labor, and various employment-related allegations fall outside the permissible time frames. The defendants also challenge the applicability of revival statutes, arguing that the Gender-Motivated Violence Law (GMVL) revival provision conflicts with existing laws like the Child Victims Act (CVA) and Adult Survivors Act (ASA), and thus cannot retroactively apply to the defendants.Additionally, the defendants argue that the plaintiff's claims against various entities associated with Sean Combs, such as the "Bad Boy" and "Combs" entities, rely on improper group pleadings without specific allegations against each entity. They assert that the GMVL claim fails because the law did not apply to certain defendants at the relevant times and that the plaintiff does not sufficiently allege a gender-motivated crime of violence. Furthermore, the defendants contend that the plaintiff fails to state valid claims for forced labor, sex trafficking, discrimination under the New York State Human Rights Law, right of publicity, and unjust enrichment. They argue that these claims are either inadequately pled or legally baseless, and in some cases, barred by applicable statutes of limitations.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628103.154.0.pdf

In the memorandum supporting their consolidated motion to dismiss, the defendants in the case of Dawn Angelique Richard v. Sean Combs et al. argue that the plaintiff's claims are largely time-barred under New York's statutes of limitations. They contend that the state's shorter limitation periods should apply, rendering many of the plaintiff's causes of action untimely. Specifically, they assert that claims related to assault, battery, false imprisonment, intentional infliction of emotional distress, trafficking, forced labor, and various employment-related allegations fall outside the permissible time frames. The defendants also challenge the applicability of revival statutes, arguing that the Gender-Motivated Violence Law (GMVL) revival provision conflicts with existing laws like the Child Victims Act (CVA) and Adult Survivors Act (ASA), and thus cannot retroactively apply to the defendants.Additionally, the defendants argue that the plaintiff's claims against various entities associated with Sean Combs, such as the "Bad Boy" and "Combs" entities, rely on improper group pleadings without specific allegations against each entity. They assert that the GMVL claim fails because the law did not apply to certain defendants at the relevant times and that the plaintiff does not sufficiently allege a gender-motivated crime of violence. Furthermore, the defendants contend that the plaintiff fails to state valid claims for forced labor, sex trafficking, discrimination under the New York State Human Rights Law, right of publicity, and unjust enrichment. They argue that these claims are either inadequately pled or legally baseless, and in some cases, barred by applicable statutes of limitations.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628103.154.0.pdf

In the memorandum supporting their consolidated motion to dismiss, the defendants in the case of Dawn Angelique Richard v. Sean Combs et al. argue that the plaintiff's claims are largely time-barred under New York's statutes of limitations. They contend that the state's shorter limitation periods should apply, rendering many of the plaintiff's causes of action untimely. Specifically, they assert that claims related to assault, battery, false imprisonment, intentional infliction of emotional distress, trafficking, forced labor, and various employment-related allegations fall outside the permissible time frames. The defendants also challenge the applicability of revival statutes, arguing that the Gender-Motivated Violence Law (GMVL) revival provision conflicts with existing laws like the Child Victims Act (CVA) and Adult Survivors Act (ASA), and thus cannot retroactively apply to the defendants.Additionally, the defendants argue that the plaintiff's claims against various entities associated with Sean Combs, such as the "Bad Boy" and "Combs" entities, rely on improper group pleadings without specific allegations against each entity. They assert that the GMVL claim fails because the law did not apply to certain defendants at the relevant times and that the plaintiff does not sufficiently allege a gender-motivated crime of violence. Furthermore, the defendants contend that the plaintiff fails to state valid claims for forced labor, sex trafficking, discrimination under the New York State Human Rights Law, right of publicity, and unjust enrichment. They argue that these claims are either inadequately pled or legally baseless, and in some cases, barred by applicable statutes of limitations.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628103.154.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

In the memorandum supporting their consolidated motion to dismiss, the defendants in the case of Dawn Angelique Richard v. Sean Combs et al. argue that the plaintiff's claims are largely time-barred under New York's statutes of limitations. They contend that the state's shorter limitation periods should apply, rendering many of the plaintiff's causes of action untimely. Specifically, they assert that claims related to assault, battery, false imprisonment, intentional infliction of emotional distress, trafficking, forced labor, and various employment-related allegations fall outside the permissible time frames. The defendants also challenge the applicability of revival statutes, arguing that the Gender-Motivated Violence Law (GMVL) revival provision conflicts with existing laws like the Child Victims Act (CVA) and Adult Survivors Act (ASA), and thus cannot retroactively apply to the defendants.Additionally, the defendants argue that the plaintiff's claims against various entities associated with Sean Combs, such as the "Bad Boy" and "Combs" entities, rely on improper group pleadings without specific allegations against each entity. They assert that the GMVL claim fails because the law did not apply to certain defendants at the relevant times and that the plaintiff does not sufficiently allege a gender-motivated crime of violence. Furthermore, the defendants contend that the plaintiff fails to state valid claims for forced labor, sex trafficking, discrimination under the New York State Human Rights Law, right of publicity, and unjust enrichment. They argue that these claims are either inadequately pled or legally baseless, and in some cases, barred by applicable statutes of limitations.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628103.154.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

In the memorandum supporting their consolidated motion to dismiss, the defendants in the case of Dawn Angelique Richard v. Sean Combs et al. argue that the plaintiff's claims are largely time-barred under New York's statutes of limitations. They contend that the state's shorter limitation periods should apply, rendering many of the plaintiff's causes of action untimely. Specifically, they assert that claims related to assault, battery, false imprisonment, intentional infliction of emotional distress, trafficking, forced labor, and various employment-related allegations fall outside the permissible time frames. The defendants also challenge the applicability of revival statutes, arguing that the Gender-Motivated Violence Law (GMVL) revival provision conflicts with existing laws like the Child Victims Act (CVA) and Adult Survivors Act (ASA), and thus cannot retroactively apply to the defendants.Additionally, the defendants argue that the plaintiff's claims against various entities associated with Sean Combs, such as the "Bad Boy" and "Combs" entities, rely on improper group pleadings without specific allegations against each entity. They assert that the GMVL claim fails because the law did not apply to certain defendants at the relevant times and that the plaintiff does not sufficiently allege a gender-motivated crime of violence. Furthermore, the defendants contend that the plaintiff fails to state valid claims for forced labor, sex trafficking, discrimination under the New York State Human Rights Law, right of publicity, and unjust enrichment. They argue that these claims are either inadequately pled or legally baseless, and in some cases, barred by applicable statutes of limitations.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628103.154.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

In the memorandum supporting their consolidated motion to dismiss, the defendants in the case of Dawn Angelique Richard v. Sean Combs et al. argue that the plaintiff's claims are largely time-barred under New York's statutes of limitations. They contend that the state's shorter limitation periods should apply, rendering many of the plaintiff's causes of action untimely. Specifically, they assert that claims related to assault, battery, false imprisonment, intentional infliction of emotional distress, trafficking, forced labor, and various employment-related allegations fall outside the permissible time frames. The defendants also challenge the applicability of revival statutes, arguing that the Gender-Motivated Violence Law (GMVL) revival provision conflicts with existing laws like the Child Victims Act (CVA) and Adult Survivors Act (ASA), and thus cannot retroactively apply to the defendants.Additionally, the defendants argue that the plaintiff's claims against various entities associated with Sean Combs, such as the "Bad Boy" and "Combs" entities, rely on improper group pleadings without specific allegations against each entity. They assert that the GMVL claim fails because the law did not apply to certain defendants at the relevant times and that the plaintiff does not sufficiently allege a gender-motivated crime of violence. Furthermore, the defendants contend that the plaintiff fails to state valid claims for forced labor, sex trafficking, discrimination under the New York State Human Rights Law, right of publicity, and unjust enrichment. They argue that these claims are either inadequately pled or legally baseless, and in some cases, barred by applicable statutes of limitations.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628103.154.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

In the memorandum supporting their consolidated motion to dismiss, the defendants in the case of Dawn Angelique Richard v. Sean Combs et al. argue that the plaintiff's claims are largely time-barred under New York's statutes of limitations. They contend that the state's shorter limitation periods should apply, rendering many of the plaintiff's causes of action untimely. Specifically, they assert that claims related to assault, battery, false imprisonment, intentional infliction of emotional distress, trafficking, forced labor, and various employment-related allegations fall outside the permissible time frames. The defendants also challenge the applicability of revival statutes, arguing that the Gender-Motivated Violence Law (GMVL) revival provision conflicts with existing laws like the Child Victims Act (CVA) and Adult Survivors Act (ASA), and thus cannot retroactively apply to the defendants.Additionally, the defendants argue that the plaintiff's claims against various entities associated with Sean Combs, such as the "Bad Boy" and "Combs" entities, rely on improper group pleadings without specific allegations against each entity. They assert that the GMVL claim fails because the law did not apply to certain defendants at the relevant times and that the plaintiff does not sufficiently allege a gender-motivated crime of violence. Furthermore, the defendants contend that the plaintiff fails to state valid claims for forced labor, sex trafficking, discrimination under the New York State Human Rights Law, right of publicity, and unjust enrichment. They argue that these claims are either inadequately pled or legally baseless, and in some cases, barred by applicable statutes of limitations.to contact me:bobbycapucci@protonmail.comsource:gov.uscourts.nysd.628103.154.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.