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IN THE UNITED STATES DISTRICT COURT
KAREN DUDNIKOV, a/k/a TABBERONE, v.
Major League Baseball Properties, a New York Corporation PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE DECLARATORY JUDGMENT
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PLEASE TAKE NOTICE THAT, upon the accompanying memorandum of
law, in support of Plaintiff's Motion for Summary Judgment, the Statement of Facts
pursuant to Local Rule 7.1, and Appendix of supporting documents and
declarations, Plaintiffs hereby move, pursuant to Rule 56(a) of the Federal Rules
of Civil Procedure, for Summary Judgment, or in the alternative, pursuant to Rule
57) of the Federal Rules of Civil Procedure, Declaratory Judgment, on grounds
that there is no genuine issue as to any material fact and defendant is entitled to a
judgment as a matter of law and injunctive relief, court costs, and any other relief
the court may deem appropriate.
Dated June 26, 2003 |
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Respectively submitted,
_________________________________ pro se Plaintiffs |