Effective Motion Summary Judgment

Motion to strike

DC Civil Branch Division

Under Rule *(f) of the Federal Rules of Civil Procedure, the Plaintiff moves to strike certain arguments presented by Samantha L. Brooks in her Reply in further support of DocuSign, Inc.'s motion to dismiss. Ms. Brooks' arguments fail to address crucial facts that undermine the validity of her assertions and misrepresent the full scope of the case. Firstly, it is imperative to note that the Plaintiff showed proof and cause that he, out of due diligence, notified DocuSign, Inc about the acts of Equifax, Inc’s former attorney. Mrs. Alexandra Brooks on October *, * and provided them with his aforementioned court case details, the restriction/lock on the W-* form, and the blank lines that Equifax, Inc failed to sign and date on the Settlement Agreement on August *, *. Despite these notifications, DocuSign, Inc failed to take appropriate action and Plaintiff case was dismissed on December *, *, which is in contravention of the standards set forth in Bell Atlantic Corp. v. Twombly, * U.S. * (*) and Ashcroft v. Iqbal, * U.S. * (*). These landmark cases establish the "plausibility standard" and require complaints to contain factual content that allows for a reasonable inference of liability. Furthermore, the Plaintiff's actions align with Neitzke v. Williams, * U.S. * (*), which defines a frivolous claim as lacking an arguable basis in law or fact. However, Mr. Long's actions in filing a fraud claim with DocuSign, Inc. regarding the unlawful actions of account holder Alexandra Brooks and Equifax, Inc. Before his hearing are neither inaccurate nor frivolous. On the contrary, they demonstrate a diligent effort to address the issues and seek resolutions. Moreover, the assertions made by DocuSign Inc’s attorney Samantha Brooks about the facts being inappropriate as she lacks firsthand knowledge of these events. Particularly, the attorney cannot speak on behalf of DocuSign, Inc’s employee Rodolfo, who filed the complaint for Mr. Long on October *, *. She cannot defend the acts of both Equifax, Inc & Alexandra Brooks who is an DocuSign, Inc account holder who created the settlement agreement from her DocuSign, Inc account and committed the actions all on August *, *. Last but not least, she is a not party in both of the aforementioned cases against Equifax, Inc. This renders her out-of-court statements regarding the matters and those statements are unreliable and inadmissible. Plaintiff asks the court to let the record show that these statements made about Mr. Long shall not enter into the record because it is all hearsay and they are being used to waive or evade their liability of being responsible for disregarding Plaintiff’s request and contradicting from what their Law Enforcement policy statement states. The Plaintiff has proven that he contacted DocuSign, Inc on October *, * and that first attempt was unsuccessful. As you can see the Plaintiff has provided a copy of the complaint document that has the details and that shows merit and his claim are not baseless. In light of these legal precedents and Mr. Long's efforts to address the matters, the court should mandate Plaintiff’s request to have DocuSign Inc. testify to their knowledge of the account holder's actions, producing the evidence of the W-* form restriction/lock in real time so the court can see the SSN compelling that took place on their platform on August *, * and compensate the Plaintiff for their actions. These demands are not frivolous but are grounded in legal standards and the Plaintiff's right to seek redress.

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The defendant received summons and didn’t return usps certified mail receipt back to me and they were granted extension to file an answer so they filed a motion to dismiss and I filed a Writ of Quo Warranto and a reply in further support arguing against motion to dismiss