Plaintiff's Opposition to the Federal Defendants' Motion to Dismiss (Doc 73)
60-page opposition to the Federal Defendants' motion to dismiss (ECF No. 69): Article III standing (concrete injury, traceability, redressability; the generalized-grievance bar and the "patently insubstantial" attack); sovereign immunity bars none of the claims actually asserted; the service and Rule 8 arguments; Bivens governs only a fraction of the claims; the Speech or Debate Clause and qualified immunity (Chairman Carr); the immunity doctrine the Government invokes fails at its modern apex and at its foundation (Floyd v. Barker, Star Chamber, 1607); the with-prejudice request is unsupported.
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