Allergan PLC, Et Al.: Notice of Voluntary Dismissal with Prejudice

Total Page:16

File Type:pdf, Size:1020Kb

Allergan PLC, Et Al.: Notice of Voluntary Dismissal with Prejudice Case 3:17-cv-00312-WHO Document 83 Filed 02/22/19 Page 1 of 2 1 Submitting Counsel on Signature Page 2 3 4 5 6 7 8 IN THE UNITED STATES DISTRICT COURT 9 FOR THE NORTHERN DISTRICT OF CALIFORNIA 10 SAN FRANCISCO DIVISION 11 12 Case No. 17-cv-00312-WHO 13 FEDERAL TRADE COMMISSION, 14 Plaintiff, 15 v. NOTICE OF VOLUNTARY DISMISSAL WITH PREJUDICE 16 ALLERGAN PLC, et al., 17 Defendants. 18 19 20 21 22 23 24 25 26 27 28 Case 3:17-cv-00312-WHO Document 83 Filed 02/22/19 Page 2 of 2 1 On February 21, 2019, Judge Goldberg in the Eastern District of Pennsylvania entered a 2 Stipulated Revised Order for Permanent Injunction and Equitable Monetary Relief in the case 3 styled Federal Trade Commission v. Cephalon, Inc., No. 08-cv-2141 (E.D. Pa.). A copy of the 4 Stipulated Revised Order for Permanent Injunction and Equitable Monetary Relief (“Permanent 5 Injunction”) is attached as Exhibit A. 6 As of August 2, 2016 Watson Laboratories, Inc. (“Watson”) is a wholly-owned indirect 7 subsidiary of Teva Pharmaceutical Industries, Ltd. (“Teva”). 8 Under the Permanent Injunction, Teva and its subsidiaries, including Watson, are prohibited 9 from entering into any agreements similar to the agreement challenged in this case. (Permanent 10 Injunction § I.) The scope of this prohibition is consistent with the relief the FTC seeks in this 11 case. See Complaint, Prayer for Relief, filed Jan. 23, 2017 (Dkt. 1). Entry of the Permanent 12 Injunction, therefore, adequately addresses any anticompetitive conduct at issue in this case. 13 Therefore, pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), Plaintiff Federal 14 Trade Commission hereby voluntarily dismisses the above-captioned matter with prejudice. No 15 defendant has filed an answer or motion for summary judgment in this case. 16 17 Dated: February 22, 2019 18 Respectfully submitted by: 19 FEDERAL TRADE COMMISSION 20 21 /s/ Markus H. Meier Markus H. Meier 22 600 Pennsylvania Avenue, N.W. Washington, DC 20580 23 Tel.: (202) 326-2756 Fax: (202) 326-3384 24 [email protected] 25 Attorney for Plaintiff Federal Trade Commission 26 27 28 .
Recommended publications
  • GLOSSARY of LEGAL TERMS Ad Damnum
    GLOSSARY OF LEGAL TERMS Ad damnum: The technical name of the clause in the complaint that contains a statement by the plaintiff of the amount of the damages he/she is claiming. Additur: The opposite of Remittitur. An increase in an award by the Judge done in the Court's discretion if he or she feel the Jury's judgment is inadequate. Adjudicate: To settle in the exercise of judicial authority; to determine finality. Admissions: Confessions, concessions, or voluntary acknowledgment made by a party of the existence of certain facts. Affiant: The person who makes and subscribes an affidavit. Affidavit: Sworn statement of a witness, which is verified by a Notary Public. Affirmative Defense: A defense that must be specifically pled by the defendant to be asserted at trial. If such a defense is not raised in the answer, it is waived. An example of an affirmative defense is contributory negligence, assumption of the risk, etc. Appellant: The party who takes an appeal from one court or jurisdiction to another in the interest of setting aside or reversing the judgment. Appellee: The party in a case against whom an appeal is taken, that is, the party who has an interest adverse to setting aside or reversing the judgment (some times called the respondent). Arbitration: Alternative dispute resolution in which the case is decided by an arbitrator or panel of arbitrators, usually experienced attorneys, former judges, or administrative law judges. The case is decided after an informal hearing. Arbitration is almost always binding. Assumption of the Risk: This is an affirmative defense.
    [Show full text]
  • Federal Procedure: Dismissing a Single Party in Multiparty Litigation— Check Your Jurisdiction! by Megan Basham Davis
    October 7, 2020 Volume 19, Issue 40 A Message from the President: DRI Nominating Committee Appointments This Week’s Feature And The Defense Wins DRI Cares Upcoming Seminars A Message from DRI News DRIKids Upcoming Webinars the President In Memoriam DRI Pets Quote of the Week DRI Voices This Week’s Feature Federal Procedure: Dismissing a Single Party in Multiparty Litigation— Check Your Jurisdiction! By Megan Basham Davis In multiparty lawsuits, situations can arise where dismissal of a single party—either on the plaintiff or defendant side—is sought. For example, a plaintiff in a multi-plaintiff suit may tire of the litigation. Or a spouse divorcing a plaintiff during the course of litigation may wish to dismiss his or her loss of consortium claim and exit the litigation. A plaintiff may settle with a single defendant, or it might become clear that discovery simply does not bear out a claim against one of the defendants. Seeking to dismiss a single party voluntarily while leaving the remainder of the lawsuit intact can present a procedural issue in certain federal jurisdictions. MORE Back to Contents This Week’s Feature Federal Procedure: Dismissing a Single Party in Multiparty Litigation—Check Your Jurisdiction! By Megan Basham Davis In multiparty lawsuits, situations can arise v. Bank of Am., N.A., 304 F.R.D. 691, 693 (D. Utah 2015) where dismissal of a single party—either on (collecting cases). The majority rule permits a plaintiff “to the plaintiff or defendant side—is sought. For dismiss fewer than all of the named defendants” because it example, a plaintiff in a multi-plaintiff suit may “is consistent with… Rule 41(a)(1),” which was “designed to tire of the litigation.
    [Show full text]
  • Fourth District Court of Appeals: 4D17-2141 15 Judicial
    Filing # 74015120 E-Filed 06/25/2018 08:48:03 AM IN THE SUPREME COURT OF FLORIDA Case No. SC18-398 Lower Tribunal No(s).: Fourth District Court of Appeals: 4D17-2141 15th Judicial Civil Circuit: 2016 CA 009672 ALISON RAMPERSAD and LINDA J. WHITLOCK, Petitioners, vs. COCO WOOD LAKES ASSOCIATION, INC. Respondent. PETITION FOR DISCRETIONARY REVIEW OF A DECISION OF THE DISTRICT COURT OF APPEAL OF FLORIDA, FOURTH DISTRICT PETITIONERS’ AMENDED BRIEF ON JURISDICTION STRICKENPetitioners Represented Propria Persona Filer: Linda J. Whitlock, pro se RECEIVED, 06/25/2018 08:48:29 AM, Clerk, Supreme Court 14630 Hideaway Lake Lane Delray Beach, Florida 33484 TABLE OF CONTENTS TABLE OF CONTENTS…………………………………………………. i TABLE OF CITATIONS…………………………………………. ii - x PREFACE / INTRODUCTION .................................................................. 1 JURISDICTIONAL STATEMENT............................................................ 5 STATEMENT OF THE CASE AND FACTS ........................................... 7 SUMMARY OF THE ARGUMENT ......................................................... 8 CONCLUSION ..........................................................................................10 CERTIFICATE OF SERVICE ................................................................. 10 CERTIFICATE OF COMPLIANCE ........................................................ 10 STRICKEN Case No. SC2018-398 Amended Jurisdictional Brief Page [ i ] TABLE OF CITATIONS AND AUTHORITIES Supreme Court Cases: Board of City Commissioners of Madison City. v. Grice 438
    [Show full text]
  • 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
    RICHARD R. WIEBE (SBN 121156) 1 425 California Street, Suite 2025 2 San Francisco, CA 94104 Telephone: (415) 433-3200 3 Facsimile: (415) 433-6382 4 THOMAS E. MOORE III (SBN 115107) 5 TOMLINSON ZISKO MOROSOLI & MASER LLP 200 Page Mill Road, Second Floor 6 Palo Alto, CA 94306 Telephone: (650) 325-8666 7 Facsimile: (650) 324-1808 8 ARTHUR V. PLANK (SBN 072265) 9 ALLONN E. LEVY (SBN 187251) HOPKINS & CARLEY LLC 10 70 S. First Street 11 San Jose, CA 95113 Telephone: (408) 286-9800 12 Facsimile: (408) 998-4790 13 CINDY A. COHN (SBN 145997) 14 ELECTRONIC FRONTIER FOUNDATION 454 Shotwell Street 15 San Francisco CA 94110 16 Telephone: (415) 436-9333 Facsimile: (415) 436-9993 17 Attorneys for Defendant ANDREW BUNNER 18 SUPERIOR COURT OF THE STATE OF CALIFORNIA 19 COUNTY OF SANTA CLARA 20 DVD COPY CONTROL Case No. CV - 786804 21 ASSOCIATION, INC., DATE: May 11, 2004 22 Plaintiff, TIME: 9:00 a.m. v. DEPT.: 2 23 HONORABLE WILLIAM J. ELFVING ANDREW THOMAS 24 MCLAUGHLIN; ANDREW DEFENDANT ANDREW BUNNER'S 25 BUNNER; et al., NOTICE OF MOTION AND MOTION TO Defendants. VACATE PLANTIFF 26 DVD COPY CONTROL ASSOC., INC.’S VOLUNTARY DISMISSAL, AND 27 MEMORANDUM IN SUPPORT THEREOF 28 DEF BUNNER'S NOTICE OF MOTION & MOTION TO VACATE PLAINTIFF’S 1 NOTICE OF MOTION AND MOTION TO VACATE PLAINTIFF DVD COPY 2 CONTROL ASSOCIATION, INC.’S VOLUNTARY DISMISSAL OF THE ACTION 3 TO: PLAINTIFF DVD COPY CONTROL ASSOCIATION, INC.: 4 PLEASE TAKE NOTICE that on May 11, 2004, at 9:00 a.m.
    [Show full text]
  • Voluntary Dismissals - from Shield to Sword by the Convergence of Improvident Actions, 21 J
    UIC Law Review Volume 21 Issue 3 Article 5 Spring 1988 Voluntary Dismissals - From Shield to Sword by the Convergence of Improvident Actions, 21 J. Marshall L. Rev. 549 (1988) James T. Ferrini Richard R. Winter Follow this and additional works at: https://repository.law.uic.edu/lawreview Part of the Civil Law Commons, Civil Procedure Commons, Litigation Commons, and the State and Local Government Law Commons Recommended Citation James T. Ferrini & Richard R. Winter, Voluntary Dismissals - From Shield to Sword by the Convergence of Improvident Actions, 21 J. Marshall L. Rev. 549 (1988) https://repository.law.uic.edu/lawreview/vol21/iss3/5 This Article is brought to you for free and open access by UIC Law Open Access Repository. It has been accepted for inclusion in UIC Law Review by an authorized administrator of UIC Law Open Access Repository. For more information, please contact [email protected]. VOLUNTARY DISMISSALS-FROM SHIELD TO SWORD BY THE CONVERGENCE OF IMPROVIDENT ACTIONS JAMES T. FERRINI* AND RICHARD R. WINTER** PREFATORY NOTE This article suggests an appropriate legislative response to sev- eral recent Illinois Appellate Court decisions that have examined the right of voluntary dismissal and found it inviolable-notwithstand- ing that it was exercised transparently to evade previously entered discovery sanctions or pending defense motions. The proposals set forth in this article are made after consideration of the common law and statutory developments of the plaintiff's right to voluntarily dis- miss his case and to refile. This historical review suggests that the sources of this "absolute" right are recent and improvident events.
    [Show full text]
  • In the United States District Court for the Southern District of Ohio Western Division
    Case: 3:04-cv-00007-WHR Doc #: 137 Filed: 09/26/05 Page: 1 of 11 PAGEID #: <pageID> IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION CROWN EQUIPMENT CORPORATION, : Plaintiff, : Case No. 3:04cv007 vs. : JUDGE WALTER HERBERT RICE FLORIDA LIFT SYSTEMS, INC., : Defendant. : DECISION AND ENTRY OVERRULING, AS MOOT, PLAINTIFF’S MOTIONS TO STRIKE DEFENDANT’S REPLY (DOC. #118); DECISION AND ENTRY OVERRULING, AS MOOT, PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S NOTICE OF VOLUNTARY DISMISSAL (DOC. #121); DECISION AND ENTRY OVERRULING, AS MOOT, PLAINTIFF’S MOTION FOR RECONSIDERATION (DOC. #123); DECISION AND ENTRY OVERRULING, WITHOUT PREJUDICE, PLAINTIFF’S RENEWED MOTION FOR SUMMARY JUDGMENT (DOC. #126); DECISION AND ENTRY OVERRULING, AS MOOT, PLAINTIFF’S MOTION FOR LEAVE TO FILE A SUPPLEMENTAL MEMORANDUM (Doc. #127); DECISION AND ENTRY OVERRULING, AS MOOT, DEFENDANT’S MOTION FOR EXTENSION OF TIME (DOC. #129); DECISION AND ENTRY SUSTAINING DEFENDANT’S MOTION FOR LEAVE TO FILE SURREPLY (DOC. #132); FURTHER PROCEDURES ESTABLISHED When this litigation was initiated, Defendant was a distributor of lift trucks manufactured by Plaintiff. The parties’ relationship had been governed by a distributorship agreement, which contained a provision requiring that they resolve all disputes arising out their distributorship relationship through arbitration. Plaintiff Case: 3:04-cv-00007-WHR Doc #: 137 Filed: 09/26/05 Page: 2 of 11 PAGEID #: <pageID> brought this litigation seeking an order compelling the Defendant to arbitrate its claims arising out of its (Plaintiff’s) decision to terminate that relationship. The Defendant set forth a Counterclaim. which contains a number of claims which allege that the Plaintiff’s decision to terminate the distributorship agreement violated state and federal law.
    [Show full text]
  • Sample Pleading Template (Federal Court)
    Case 4:19-cv-01231-JSW Document 4-1 Filed 03/07/19 Page 2 of 30 1 Marísa Díaz, CSB No. 293072 E-mail: [email protected] 2 Christopher Ho, CSB No. 129845 3 E-mail: [email protected] LEGAL AID AT WORK 4 180 Montgomery Street, Suite 600 San Francisco, California 94104 5 Telephone: 415.864.8848 6 Facsimile: 415.593.0096 7 Beth W. Mora, CSB No. 208859 E-mail: [email protected] 8 MORA EMPLOYMENT LAW, APC 9 18 Crow Canyon Court, Suite 205 San Ramon, California 94583 10 Telephone: 925.820.8949 Facsimile: 925.820.0278 11 12 Attorneys for Plaintiff-Intervenor Ayesha Faiz 13 14 IN THE UNITED STATES DISTRICT COURT 15 FOR THE NORTHERN DISTRICT OF CALIFORNIA 16 17 Case No. 4:19-cv-01231 18 U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, 19 Plaintiff, [PROPOSED] COMPLAINT IN 20 INTERVENTION FOR VIOLATIONS OF: 21 AYESHA FAIZ, 22 (1) TITLE VII OF THE CIVIL RIGHTS ACT Plaintiff-Intervenor, OF 1964; 23 (2) 42 U.S.C. § 1981; v. (3) CALIFORNIA FAIR EMPLOYMENT AND 24 FIDELITY HOME ENERGY, INC., a HOUSING ACT; 25 California Corporation; and DOES 1-50, (4) STATE TORT LAW; (5) CALIFORNIA LABOR CODE 26 Defendants. JURY TRIAL DEMANDED 27 28 29 30 {00569825.DOCX} Case No. 4:19-cv-01231 31 [PROPOSED] COMPLAINT IN INTERVENTION 32 Case 4:19-cv-01231-JSW Document 4-1 Filed 03/07/19 Page 3 of 30 1 INTRODUCTION 2 1. This is an action for relief from violations by Defendant Fidelity Home Energy, 3 Inc.
    [Show full text]
  • Illinois Civil Practice Guide
    Practice Series Illinois Civil Practice Guide Andrew W. Vail Colleen G. DeRosa © 2012 JENNER & BLOCK LLP ALL RIGHTS RESERVED www.jenner.com ABOUT JENNER & BLOCK Founded in 1914, Jenner & Block is a national law firm of approximately 450 attorneys. Our Firm has been widely recognized for producing outstanding results in corporate transactions and securing significant litigation victories from the trial level through the United States Supreme Court. Companies and individuals around the world trust Jenner & Block with their most sensitive and consequential matters. Our clients range from the top ranks of the Fortune 500, large privately held corporations and financial services institutions to emerging companies, family-run businesses and individuals. OFFICES 353 North Clark Street 633 West Fifth Street, Suite 3500 Chicago, Illinois 60654-3456 Los Angeles, California 90071 Firm: 312 222-9350 Firm: 213 239-5100 Fax: 312 527-0484 Fax: 213 239-5199 919 Third Avenue, 37th Floor 1099 New York Avenue, N.W., Suite 900 New York, New York 10022-3908 Washington, D.C. 20001-900 Firm: 212 891-1600 Firm: 202 639-6000 Fax: 212 891-1699 Fax: 202 639-6066 © 2012 Jenner & Block LLP. This publication is not intended to provide legal advice but to provide general information on legal matters. Transmission is not intended to create and receipt does not establish an attorney- client relationship. Readers should seek specific legal advice before taking any action with respect to matters mentioned in this publication. The attorney responsible for this publication is Andrew W. Vail. ATTORNEY ADVERTISING 1 AUTHOR INFORMATION Andrew W. Vail is a partner in Jenner & Block’s Litigation Department and a member of the Firm’s Complex Commercial and Antitrust Litigation Practice Groups.
    [Show full text]
  • UNITED STATES DISTRICT COURT SOUTHERN DISTRICT of FLORIDA CASE NO.: 1:19-Cv-23650-GAYLES/OTAZO-REYES MARIA ELENA PEREZ, Plaintif
    Case 1:19-cv-23650-DPG Document 73 Entered on FLSD Docket 08/21/2020 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 1:19-cv-23650-GAYLES/OTAZO-REYES MARIA ELENA PEREZ, Plaintiff, v. MIDLAND NATIONAL LIFE INSURANCE COMPANY, Defendant. _______________________________________/ MIDLAND NATIONAL LIFE INSURANCE COMPANY, Counter and Third-Party Plaintiff, v. MARIA ELENA PEREZ (I), Counter-Defendant and Cross-Claimant, and MARIA ELENA PEREZ (II), Third-Party Defendant and Cross-Defendant on Crossclaim of Maria Elena Perez (I). _______________________________________/ ORDER THIS CAUSE comes before the Court on Third-Party Defendant and Cross-Defendant Maria Elena Perez’s Motion to Dismiss Plaintiff/Counter-Defendant and Cross-Claimant’s Amended Cross Claim for Failure to State a Cause of Action Upon Which Relief Can be Granted Case 1:19-cv-23650-DPG Document 73 Entered on FLSD Docket 08/21/2020 Page 2 of 8 (the “Motion”) [ECF No. 57]. The Court has reviewed the Motion and the record and is otherwise fully advised. For the reasons that follow, the Motion is granted. BACKGROUND1 This action stems from an ongoing family dispute over the proceeds of two life insurance policies purchased from Midland National Life Insurance Company (“Midland”) that insured the life of the decedent, Rolando A. Perez (the “Decedent”). Maria Elena Perez (“Perez I”), the Decedent’s widow, and Maria Elena Perez (“Perez II”), the Decedent and Perez I’s daughter, each claim to be the true beneficiary of the two life insurance policies. I. Factual Background On November 21, 1999, Midland issued a life insurance policy insuring the Decedent’s life for $97,000.00 (No.
    [Show full text]
  • The Perils of Voluntarily Dismissing Without Prejudice: "Beware What You Dream For"
    THE PERILS OF VOLUNTARILY DISMISSING WITHOUT PREJUDICE: "BEWARE WHAT YOU DREAM FOR" AN OVERVIEW ALAN R. BORLACK BAILEY BORLACK NADELHOFFER LLC 135 SOUTH LASALLE STREET #3950 CHICAGO IL 60603 (312) 629-2700 [email protected] 4-27-15 ABOUT THE SPEAKER Alan R. Borlack is a partner in Bailey Borlack Nadelhoffer LLC. A graduate of Harvard Law School, Alan started at Mayer Brown & Platt and has concentrated in complex commercial litigation ever since. He has handled virtually every kind of commercial litigation case, many involving sophisticated issues and sizeable amounts at stake, including actions involving antitrust, securities fraud, consumer fraud, intellectual property, shareholder, derivative, statutory and constitutional issues, covenants not to compete, injunctions, and specific performance. He has handled many appeals and been before the Illinois Supreme Court on five occasions. He has spoken on litigation topics at many seminars. Alan is co-Vice Chair of the Chicago Bar Association Civil Practice Committee and is also Chair of the CBA Animal Law Committee where he gives voice to his personal passion for protecting companion animals and wildlife. Alan suggests that for those of you who have too much time on their hands and want to know more, including a recitation of some of his more memorable cases, go to his firm's website at http://www.bbn-law.com. 2 SECTION 2-1009 PERMITS VOLUNTARY DISMISSAL AT ANY TIME BEFORE TRIAL UPON PAYMENT OF COSTS § 2-1009. Voluntary dismissal. (a) The plaintiff may, at any time before trial or hearing begins, upon notice to each party who has appeared or each such party's attorney, and upon payment of costs, dismiss his or her action or any part thereof as to any defendant, without prejudice, by order filed in the cause.
    [Show full text]
  • Miller V. Stewart: Voluntary Dismisssal by Less Than All Plaintiffs Under the Federal Rules
    Volume 73 Issue 1 Dickinson Law Review - Volume 73, 1968-1969 10-1-1968 Miller v. Stewart: Voluntary Dismisssal by Less Than All Plaintiffs Under the Federal Rules Thomas L. VanKirk Follow this and additional works at: https://ideas.dickinsonlaw.psu.edu/dlra Recommended Citation Thomas L. VanKirk, Miller v. Stewart: Voluntary Dismisssal by Less Than All Plaintiffs Under the Federal Rules, 73 DICK. L. REV. 150 (1968). Available at: https://ideas.dickinsonlaw.psu.edu/dlra/vol73/iss1/8 This Article is brought to you for free and open access by the Law Reviews at Dickinson Law IDEAS. It has been accepted for inclusion in Dickinson Law Review by an authorized editor of Dickinson Law IDEAS. For more information, please contact [email protected]. MILLER v. STEWART: VOLUNTARY DISMISSAL BY LESS THAN ALL PLAINTIFFS UNDER THE FEDERAL RULES OF CIVIL PROCEDURE In Miller v. Stewart,' the United States District Court for the Eastern District of Illinois held that the voluntary dismissal by some but less than all plaintiffs is permissible under Rule 41(a) of the Federal Rules of Civil Procedure. 2 This decision focuses atten- tion on the conflict in the federal courts as to whether 41(a) dealing with voluntary dismissal is applicable to voluntary dismissal by less than all plaintiffs, or whether Rule 21 concerning midjoinder of parties, or Rule 15(a) dealing with amendments is the proper tool to effect this type of dismissal. This Note will analyze the de- cision of the Stewart case and evaluate the soundness of the de- cision in light of Rules 41(a), 21, and 15(a) of the Federal Rules with a view towards determining which rule is most proper in cases where less than all plaintiffs wish to dismiss.
    [Show full text]
  • Practice Book 101
    Practice Book 101 April 2, 2019 6:00 p.m. – 8:00 p.m. CBA Law Center New Britain, CT CT Bar Institute Inc. CT: 2.0 CLE Credits (General) NY: 2.0 CLE Credits (AOP) No representation or warranty is made as to the accuracy of these materials. Readers should check primary sources where appropriate and use the traditional legal research techniques to make sure that the information has not been affected or changed by recent developments. Page 1 of 141 Lawyers’ Principles of Professionalism As a lawyer I must strive to make our system of justice work fairly and Where consistent with my client's interests, I will communicate with efficiently. In order to carry out that responsibility, not only will I comply opposing counsel in an effort to avoid litigation and to resolve litigation with the letter and spirit of the disciplinary standards applicable to all that has actually commenced; lawyers, but I will also conduct myself in accordance with the following Principles of Professionalism when dealing with my client, opposing I will withdraw voluntarily claims or defense when it becomes apparent parties, their counsel, the courts and the general public. that they do not have merit or are superfluous; Civility and courtesy are the hallmarks of professionalism and should not I will not file frivolous motions; be equated with weakness; I will endeavor to be courteous and civil, both in oral and in written I will make every effort to agree with other counsel, as early as possible, on communications; a voluntary exchange of information and on a plan for
    [Show full text]