Title PRE-ANSWER MOTION TO DISMISS, Valor Bennett v. Anna Paulina .pdf ✅

PRE ANSWER MOTION TO DISMISS CR-4 DISTRICT OF COLUMBIA (FORM CO-01) (Rev. 2023) Civil Action No. Document 01 Filed 07/24/2024 Page 1 PageID #:1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 1 2 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Valor Bennett Plaintiff v. Anna Paulina Defendant Case No. 1:25-cv-0004 Presiding Judge: The Honorable Jake Robinson MOTION TO DISMISS MOTION TO DISMISS COMES NOW Defendant Anna Paulina, by and through undersigned counsel, and respectfully moves this Honorable Court to dismiss Plaintiff’s Complaint in its entirety pursuant to Rules 12(b)(1), 12(b)(6), and 21 of the Federal Rules of Civil Procedure. In support of this Motion, Defendant states as follows: In support of this Motion, Defendant states the following: Plaintiff Valor Bennett has filed a complaint that is legally and procedurally deficient on several grounds, including: 1. The impermissible joinder of multiple unrelated parties in a single action; 2. The failure to state a claim upon which relief can be granted; 3. Apparent lack of legal capacity or competence by the Plaintiff to pursue the claims presented; 4. Various procedural irregularities and prejudicial conduct undermining the fairness of the proceeding. For these reasons, dismissal is warranted. II. ARGUMENT