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Civil Rights: Jobs | Texas Eastern
Brief
FIFTH BRIEF filed Limited purpose urgent preservation, notice, evidence mapping. No merits finding requested allegations remain subject to verification. Dallas nexus records, witnesses, logistics, communications, court activity, and preservation issues. CSAM handling no material attached or circulated; only hashes, logs, metadata, and lawful child-protection channels. Relief requested preserve records, prevent spoliation, coordinate with competent authorities. by Alkiviades Andrew David, IV. (David, Alkiviades)
FOURTH BRIEF filed laintiff's Fourth Supplemental Addendum materially improves the personal-jurisdiction presentation by focusing on specific jurisdiction rather than general jurisdiction and by identifying multiple Texas-centered contacts allegedly related to the claims. The strongest allegations concern: Texas-directed commercial activity by Comcast-related entities; The Dallas-based Dr. Cracks enterprise; The planned Dallas telehealth rollout; Texas witnesses, records, customers, and damages; and Plaintiff's request for targeted jurisdictional discovery. The filing adequately invokes the "arise out of or relate to" framework discussed in Ford Motor Co. v. Montana Eighth Judicial District Court and identifies multiple alleged Texas contacts connected to the asserted injuries. However, many factual assertions remain untested and may require evidentiary support. The Court may wish to determine whether the allegations are sufficiently non-conclusory to establish a prima facie showing of personal jurisdiction and whether limited jurisdictional discovery would assist resolution of any Rule 12(b)(2) motion. Particular attention may be warranted regarding: The relationship between FilmOn and SwissxTV; The Dallas telehealth and Footbuddys rollout plans; The connection between the alleged advertising/verification conduct and Texas-based damages; The nature of Comcast Ventures' involvement, if any, with the challenged conduct; and The existence of Texas-specific records, witnesses, contracts, sponsorships, or business opportunities. At the pleading stage, dismissal may be premature if material jurisdictional facts are alleged to exist but remain primarily within Defendants' possession. by Alkiviades Andrew David, IV. (David, Alkiviades)
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