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Plaintiff's Response to Motion to Dismiss Independent Contractor Fraud and Conspiracy Scheme Complaint
Case Topics: Breach of Contract, Fraud, Unjust Enrichment, Defamation, Conspiracy, Misappropriation, Tortious Interference with Prospective Economic Advantage
Grounds for Moving: There is another action pending between the parties for the same cause. Failure to attached a copy of written instruments or recite the relevant portions in the Complaint. Defendant was not required to take any action to contribute his entire interest in one entity in order to obtain profit interests in another. An unjust enrichment claim cannot include allegations of an express contract. Reasons for resigning serve as opinions and opinions cannot serve as the basis of a defamation claim.
Moving to Dismiss the Following Claims: Breach of Contract, Fraud, Unjust Enrichment, Defamation, Conspiracy, Misappropriation, Tortious Interference with Prospective Economic Advantage