On August 13, 2018 the Federal civil docket (District of South Carolina) for the D. George Sweigert v. Jason Goodman lawsuit showed 2 new entries: #11, Response in Opposition and #12, a Motion to Strike. These docket entries contain several documents representing D. George Sweigert’s response to Jason Goodman’s Memorandum In Support of Motion to Dismiss (Document 9).
These documents can be read in the PDF’s below. There is some duplication in these files, so don’t be dissuaded by their seeming length:
Tracking the Leopard Meroz Comments: Below are screen shots of Jason Goodman’s Memorandum for easy reference, when comparing the response by the Plaintiff.
A brief review of Jason Goodman’s Memorandum in Support of Motion To Dismiss, filed on the court docket August 3, 2018, reveals an extreme disregard for the seriousness of the very detailed, and evidence based RICO complaint set forth by plaintiff D. George Sweigert. This memorandum is very short in length, in great part because it does not address the complaint in detail but rather creates under the “Facts” heading, a substitute storyline, which is not evidence based.
There are a number of spelling errors, font size changes, and a deviation from the basic legal style formatting of the heading which should note the plaintiff’s name as it appears in the original complaint. In addition to this lack of carefulness in representing himself as pro se, Jason Goodman appears to display willful ignorance of the basic features of a RICO lawsuit, which can be easily discovered by a layman on the internet, and were also described in great detail in the Plaintiff’s complaint.
In response to the curious storyline submitted by the Defendant, several documents were filed by the Plaintiff to address the numerous factual and legal deficiencies of this Memorandum.
Plaintiff’s Reply to Defendant’s Motion To Dismiss: This 9 page document reiterates “the underlying controversy which this litigation rests” by a two page summary of the Port of Charleston incident, as it relates to the Defendant’s actions. This is followed by Law and Argument, which explains the Plaintiff’s Standing as a Private Attorney General under RICO doctrine, underlining the fact that this is a public interest lawsuit.
The Plaintiff also addresses Jason Goodman’s attempt to dismiss this lawsuit without having described the elements of what Goodman believes are the “critical deficiency with the plaintiff’s complaint”. The “Defendant’s proposition is that the Court dismiss this action based on wild accusation of some conspiracy involving the undersigned”. In addition, this Reply notes, “Apparently the Defendant expects this Court to conduct his legal research by a legal review of the totality of the Amended Complaint (Entry 5, 06/29/2018) while simultaneously providing no legal support for the proposition that the Plaintiff has failed to state an actionable claim”.
On page 8, the Plaintiff states, “The Defendant’s so-called “motion” is silent on all the matters that are required in such motions. In fact, the pleading, (MEMORANDUM (Entry 9-1, 08/03/2018)) is little more than a Post-It Note type of response. A fair reading of the Defendant’s “motion” gives no inkling as to what legal standards are relied upon by Goodman.” The Plaintiff requests that the Court deny the Defendant’s “motion”.
Plaintiff’s FRCP Rule 12(f) Motion To Strike Defendant’s Memorandum In Support of Motion To Dismiss (Entry 9-1, 08/03/2018): The Plaintiff observes that the Defendant’s Memorandum is “an obvious attempt to transfer his liability for the closure of the Port of Charleston onto the plaintiff. Goodman has had to rely on his complete reckless disregard for the truth to accomplish this stunning fraud on the court.”
In conjunction with this document, the Plaintiff has also filed the following documents.
Brief in Support of Plaintiff’s FRCP Rule 12 (f) Motion to Strike Defendant’s Memorandum in Support of Motion to Dismiss (Doc. 9-1,08/03/2018)
Plaintiff’s First Declaration
Third Request for Judicial Notice