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`Case 3:20-cv-02082-JAH-KSC Document 9 Filed 11/25/20 PageID.108 Page 1 of 2
`
`
`
`THOMAS E. MONTGOMERY, County Counsel
`County of San Diego
`By MELISSA M. HOLMES, Senior Deputy (SBN 220961)
` STEVEN P. INMAN, II, Senior Deputy (SBN 227748)
`1600 Pacific Highway, Room 355
`San Diego, California 92101-2469
`Telephone: (619) 531-5836
`Exempt From Filing Fees Per Gov’t Code §6103
`
`Attorneys for Defendants County of San Diego, Ricardo Andrade, Steve Bodine, Justin
`Moore, Christopher Perez and Dwayne Prickett
`
`
`
`
`UNITED STATES DISTRICT COURT
`
`SOUTHERN DISTRICT OF CALIFORNIA
`
`
`
`
`)
`AGRO DYNAMICS, LLC a Wyoming
`)
`Limited Liability Company,
`)
`
`)
`
`Plaintiff,
`)
`
`)
`
`v.
`)
`
`DRUG ENFORCEMENT
`)
`ADMINISTRATION, SAN DIEGO
`)
`
`COUNTY, and SPECIAL AGENTS PAUL )
`GELLES, ERIC BALL, KIERAN
`)
`GARCIA, MARSHA DAWE, ROSS VAN
`)
`NOSTRAND, AND JEREMY FEUZ;
`)
`FRANK HASKELL, ANDREW
`)
`AGUILAR, JASON STEIN, TIMOTHY
`)
`SMITH, MICHAEL ASTORGA,
`)
`CHRISTOPHER MORRIS, SGT. STEVE
`)
`BODINE, DET. JUSTIN MOORE, DET.
`)
`DWAYNE PRICKETT, DET.
`)
`CHRISTOPHER PEREZ, AND DET.
`)
`
`RICARDO ANDRADE; and DOES 1 to 50 )
`inclusive,
`)
`
`)
`
` Defendants.
`)
`
`
`
`
`
`
`
`Case No. 20-cv-2082-JAH (KSC)
`
`
`NOTICE OF MOTION AND MOTION
`TO DISMISS PLAINTIFF’S FIRST
`AMENDED COMPLAINT BY
`DEFENDANTS COUNTY OF SAN
`DIEGO, STEVE BODINE, JUSTIN
`MOORE, DWAYNE PRICKETT,
`CHRISTOPHER PEREZ, AND
`RICARDO ANDRADE
`
`Date: January 27, 2021
`Time: 10:30 a.m.
`Judge: Hon. John A. Houston
`Department: 13B
`
`NO ORAL ARGUMENT UNLESS
`REQUESTED BY COURT
`
`20-cv-2082-JAH (KSC)
`
`
`
`Case 3:20-cv-02082-JAH-KSC Document 9 Filed 11/25/20 PageID.109 Page 2 of 2
`
`
`
`PLEASE TAKE NOTICE that on January 27, 2021 at 10:30 a.m. or as soon as the
`matter may be heard in Courtroom 13B of the Honorable John A. Houston, United States
`District Judge, located at 333 West Broadway, San Diego, California 92101, Defendants
`County of San Diego, Steve Bodine, Justin Moore, Dwayne Prickett, Christopher Perez,
`and Ricardo Andrade will move to dismiss Plaintiff’s First Amended Complaint pursuant
`to Federal Rules of Civil Procedure, Rule 12(b)(6), on the grounds that the First
`Amended Complaint fails to state a valid claim.
`The motion will be based upon this notice, the accompanying memorandum of
`points and authorities, and upon all papers and pleadings on file in this action.
`DATED: November 25, 2020
`THOMAS E. MONTGOMERY, County Counsel
`
`
`By:
`
`STEVEN P. INMAN, II, Senior Deputy
`
`
`Attorneys for Defendants County of San Diego,
`Ricardo Andrade, Steve Bodine, Justin Moore,
`Christopher Perez and Dwayne Prickett
`
`
`
`
`
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`20-cv-2082-JAH (KSC)
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