THIS PROJECT IS CANCELLED. PLEASE see the related contest. I need a document Grammar correct & Bluebook check a 7 abt. Page Document. I have already run it through grammarly and spell check so I am not paying for that. Grammerly is showing 59 alerts to I have to decide which to change that are obvious grammar errors and those that are just stylistic problems. I cannot allow the text to change entire paragraphs only one or two sentences can be completely rewritten. The finished product needs to be 99.99999% perfect. The document is in the files section and a video of me paging through what I already know from grammerly about the 59 current errors, so Please view that as well.
Attorney for Plaintiffs Polygraph School
of Science, Inc., and Linda Walker, M.S.
IN THE UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
Linda M. Walker, et al., )
Plaintiffs, ) Case No.: CV-6-6-PHX-GMS
vs. ) RESPONSE TO MOTION
) TO DISMISS
Armenian Polygraph Association, et al., )
Defendants. ) ORAL ARGUMENT
MOTION FOR LEAVE TO CONDUCT JURISDICTIONAL DISCOVERY AND TO
STAY RESPONSE TO MOTION TO DISMISS
In response to Armenian Polygraph Association’s (“APA”) Motion to Dismiss (Doc. 96) (the “Motion”), Ms. Linda Walker (“Director”) notes that the Motion to Dismiss is moot as the Amended Complaint, filed as a Matter of Course, is the operative complaint. (Doc. 92). Ms. Walker, by counsel, filed the Amended Complaint as a matter of course on October 8, 2011. No objection to its filing was made by any defendant until too late on October 24, 2011. In the alternative, Plaintiff, moves for leave to conduct jurisdictional discovery and to stay a substantive response to the Motion to Dismiss until discovery is completed. Discovery will demonstrate APA has sufficient minimum contacts with Arizona and the exercise of jurisdiction is fair and reasonable. By this pleading this Plaintiff also files its Response to Defendants’ Motion to Preclude Plaintiff from Filing.
The APA purports to be a District of Columbia non-profit corporation whose headquarters and principal place of business are located in Chattanooga, Tennessee. They have voluntarily undertaken to serve and engage in the self-appointed policing of the profession and promulgating of instructional standards of polygraph in the United States. The APA purports to maintain professional standards and claims to enforce such standards through application of the rules memorialized in its Manual of Accreditation. And let there be no doubt as to the significance of the APA’s actual and possible contacts with this forum. The APA website touts “Serving the cause of truth with integrity, objectivity and fairness to all persons.” All persons.
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