Reply to Blake Lively- Jason Baldoni and NYT

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[quote=Anonymous]Yesterday Jones also filed her Reply to Able's MTD her counterclaims:  https://storage.courtlistener.com/recap/gov.uscourts.nysd.635782/gov.uscourts.nysd.635782.61.0.pdf

This Reply also encourages Judge Liman to dismiss with prejudice, explaining amendment would just be futile and cause further delay:  "Leave to amend “should generally be denied in instances of futility, undue delay, bad faith or dilatory motive, repeated failure to cure deficiencies by amendments previously allowed, or undue prejudice.” United States ex rel. Ladas v. Exelis, Inc., 824 F.3d 16, 28 (2d Cir. 2016). Abel has already amended her counterclaims once, after Jonesworks first moved to dismiss them. That amendment did not correct the pleadings to address the motion to dismiss, but made wholesale changes, dropping six claims and adding five new ones that are equally if not more faulty. [b]This Court should not permit Abel to continue wildly amending her pleadings in scattershot fashion with no articulated factual or legal grounding, in search of a theory.[/b]"
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