TROUT POINT LODGE, LIMITED, a Nova Scotia Limited Company; VAUGHN PERRET and CHARLES LEARY, Plaintiff, Civil Action No.: 1:12-CV-90LG-JMR V
Case 1:12-cv-00090-LG-JMR Document 27 Filed 08/06/12 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI SOUTHERN DIVISION TROUT POINT LODGE, LIMITED, A Nova Scotia Limited Company; VAUGHN PERRET and CHARLES LEARY, Plaintiff, Civil Action No.: 1:12-CV-90LG-JMR v. DOUG K. HANDSHOE, Defendant. * * * * * * * * * * * * * SUPPLEMENTAL REPLY MEMORANDUM OF DEFENDANT, DOUGLAS K. HANDSHOE MAY IT PLEASE THE COURT: This Supplemental Memorandum is submitted by defendant, Douglas K. Handshoe (“Handshoe”), in reply to the Memorandum in Opposition to Motion for Summary Judgment, which was filed by the plaintiffs, Trout Point, Vaughn Perret, and Charles Leary (collectively, “Trout Point”). As previously discussed in defendant’s Reply Memorandum, the parties agreed that this dispute would focus on pure questions of law, rather than specific facts, and would be resolved solely on motions for summary judgment. Still, as pointed out in defendant’s Reply Memorandum, plaintiffs have focused a great deal of their arguments on facts. Because of plaintiffs’ harping on the facts, defendant feels compelled to provide the court with factual points as well. Thus, this supplemental memorandum will focus on revealing the factual bases for defendant’s allegedly defamatory statements. Case 1:12-cv-00090-LG-JMR Document 27 Filed 08/06/12 Page 2 of 10 Plaintiffs repeatedly point to the assertion that in the Canadian adjudication, they proved that the statements made about them were false. Specifically, they state in their Response to Memorandum in Support of Motion for Summary Judgment that plaintiffs have clearly demonstrated that the statements were false and defamatory.
[Show full text]