Posted On: 02/11/2016 5:21:58 PM
Post# of 72447
and this is the relevant cite / FN 8 from the last filing
8
Based on the obvious deficiencies (including improper venue), Defendants notified Plaintiff that the complaints were frivolous, were filed without complying with Rule 11’s due diligence obligations, and should be dismissed. Plaintiff declined either to withdraw the complaint, or to undertake efforts with any reasonable diligence to file a properly -supported and -pleaded complaint, within Rule 11’s safe harbor period. Defendants hereby reserve their right to pursue sanctions pursuant to Rule 11’s traditional method, as well as pursuant to the mandatory review process under the PSLRA, which attaches to “any complaint” filed in the matter. 15 U.S.C. §78u-4(c)(1)&
2)
8
Based on the obvious deficiencies (including improper venue), Defendants notified Plaintiff that the complaints were frivolous, were filed without complying with Rule 11’s due diligence obligations, and should be dismissed. Plaintiff declined either to withdraw the complaint, or to undertake efforts with any reasonable diligence to file a properly -supported and -pleaded complaint, within Rule 11’s safe harbor period. Defendants hereby reserve their right to pursue sanctions pursuant to Rule 11’s traditional method, as well as pursuant to the mandatory review process under the PSLRA, which attaches to “any complaint” filed in the matter. 15 U.S.C. §78u-4(c)(1)&
2) 
(2)
(0)
