Well-Pleaded Complaints

@timorous.cishet.net

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The Lady With The Hammer. Lawyer, Jersey City Enjoyer. 🏳️‍⚧️ Signal: @tornando.27

a fluffy maine coon cat’s face. his tongue is sticking out a bit and one eye is half closed, making him look like a winky face emoji. it is silly. he is a silly boy
Plaintiffs here ask the Court to enter the following permanent injunction: The Court permanently ENJOINS Defendants and their officers, agents servants, employees, and attorneys, including those at the Office of Inspector General (HHS-OIG), from initiating enforcement action, enforcing, implementing, giving intent to, or relying, in whole or in part, on the Kennedy Declaration or any materially similar policy which supersedes or purports to supersede the professionally recognized standards of care for gender-affirming care that exist in the Plaintiff States-against any provider in the Plaintiff States.
Ronald Dworkin wearing a polo and sunglasses on a sailboat, having a great time
Don Draper meditates, smiling ever so slightly. he is almost beatific
A sign from the City of Jersey City outside the Justice Brennan Court House (Hudson County Superior Court)
a fluffy middle-aged tabby cat sitting on a blue and cream checked comforter. behind him there is a little cloud of mist coming from an invisible humidifier. the cat’s eyes are closed as though he is taking the vapors, for his health
a tabby cat lying down on a coffee table looking alert. the cat is a very fluffy maine coon.
Ed, a tuxedo cat, sitting on top of a couch cushion, looking smug because he killed a bird
a young woman’s torso. she is wearing a yellow dress, a red wool shirt, a brown belt, and a brown coat. on her chest is a red, white, and blue sticker saying “I VOTED”
A $57.50 per month donation to the Community Food Bank of New Jersey
Kevin Tighe as Roy More in “One Battle After Another”
Dmitry, a fluffy tabby cat, has his front paws on a windowsill. He’s taking in the fresh air and giving me side eye with a slightly aggrieved expression
Galina Ustvolskaya, a/k/a The Woman With A Hammer, source of this user’s profile pic, with a lazer eyes edit.
dead-eyes wojak, dreading what follows
Judge Michael S. Nachmanoff (a heavyset tan-skinned white man in a blue suit and glasses) with red glowing lazer eyes
In fact, it is uncontested that there is no direct evidence in the record specifying that Appellant transmitted the Gift Letter to her mortgage lender from the District of Maryland. The district court itself stated, "the Government's evidence to establish venue in this District is certainly circumstantial." J.A. 303. And that circumstantial evidence could go either way. For example, the Government adduced no direct evidence as to where Appellant was after she received the draft gift letter on February 9. Nor did the Government adduce any direct evidence as to where Appellant was when she transmitted the Gift Letter to her broker in Florida, or even when that transmission occurred. The February 10, 2021 mortgage application packet did reference the Gift Letter, but it was conspicuously absent from the application packet. Further, the evidence presented at trial indicated that Appellant signed the Gift Letter on February 10, but then traveled to Florida on February 16 for her closing. And United Wholesale Mortgage did not approve Appellant's loan until February 17. On these facts, a rational factfinder could infer that Appellant sent the Gift Letter from her home in Baltimore. But it could also reasonably conclude that there was insufficient evidence to determine that fact, one way or the other.
Of particular relevance to this appeal, in Sterling we held that "[a]cts which are merely 'preparatory' to the underlying offense and its essential conduct... cannot provide a basis for venue." Id. (quoting United States v. Ramirez, 420 F.3d 134, 144 (2d Cir. 2005) (finding that for purposes of mail fraud, venue lies where an individual actually misuses the mails, and not where an individual only devises a scheme to defraud)). That is, preparatory conduct does not satisfy the first step of the venue inquiry because it is not the type of essential conduct that is required for the establishment of venue. The controlling authority to discern the line between essential conduct and mere preparatory conduct for § 1014 is our decision in Reass v. United States, 99 F.2d 752 (4th Cir. 1938). In Reass, we reversed a defendant's conviction for violating 12 U.S.C. § 1441(a) (1932 ed.), the predecessor to § 1014. See United States v. Wells, 519 U.S. 482, 492 (1997) (discussing the history of § 1014). At the time, § 1441(a), criminalized knowingly making a false statement "for the purpose of influencing in any way the action of a Federal Home Loan Bank upon any application for loan." Reass, 99 F.2d at 752. In Reass, the defendant was convicted by a jury in the Northern District of West Virginia for preparing, filling out, and signing a fraudulent loan application, and then submitting it in person to a federal bank in Pittsburgh, Pennsylvania. Id. at 753.
Rachel’s kitchen. A white block of lo bak go (turnip cake) sits on a green plate. There’s a cast iron pan where two slices of lo bak go are frying.
Karin Immergut lazer eyes jpeg
U.S. District Judge Karin J. Immergut of the District of Oregon. She’s a white woman with shoulder-length straight hair wearing her robes, stud earrings, and a chunky black necklace. There’s a U.S. flag in the background. I’ve edited in “laser eyes” (that is, lens flares).
A political mailer supporting James Solomon’s campaign for mayor of Jersey City. It reads: JAMES SOLOMON TOOK ON GREEDY DEVELOPERS. AND WON. AS MAYOR, HE'LL DELIVER REAL HOUSING WE CAN AFFORD. Too many Jersey City families are being priced out of their neighborhoods. As a Councilman, James fought for a historic law that protected tenants from illegal evictions, and stood up to developers and corrupt politicians. As Mayor, he'll do even more: • Make developers pay their fair share • Build more housing we can afford • With rents under $1,000 • With homeownership for frontline workers • Cap rent hikes • Stabilize property taxes NO JERSEY CITY DEVELOPER MONEY. NEVER, EVER. VOTE BY TUESDAY 11/4
a tuxedo cat resting. half of his body is on my folded-up knees. his claws are poking out from his front paw, mid-biscuit knead. it’s adorable
a fluffy tabby cat lying curled up on his back in a rocking chair, eyes closed, looking absolutely zonked out
(f) SUSPENSION OF ENTRY OR IMPOSITION OF RESTRICTIONS BY PRESIDENT Whenever the President finds that the entry of any aliens or of any class of aliens into the United States would be detrimental to the interests of the United States, he may by proclamation, and for such period as he shall deem necessary, suspend the entry of all aliens or any class of aliens as immigrants or nonimmigrants, or impose on the entry of aliens any restrictions he may deem to be appropriate. …
“Even assuming that each allegation in the complaint is true (of course, that is for a jury to decide and is not pertinent here; this order suggests nothing about the truth of the allegations or the validity of the claims but addresses only the manner of the presentation of the allegations in the complaint); even assuming that at trial the plaintiff offers evidence supporting every allegation in the complaint and that the evidence is accepted by the jury as fact; and even assuming that after finally "melting" the defendants' alleged "iceberg of falsehoods" the plaintiff prevails for each reason alleged in the complaint — even assuming all of that — a complaint remains an improper and impermissible place for the tedious and burdensome aggregation of pro- spective evidence, for the rehearsal of tendentious arguments, or for the protracted recitation and explanation of legal authority putatively supporting the pleader's claim for relief. As every lawyer knows (or is presumed to know), a complaint is not a public forum for vituperation and invective — not a protected platform to rage against an adversary. A complaint is not a megaphone for public relations or a podium for a passionate oration at a political rally or the functional equivalent of the Hyde Park Speakers' Corner.”
“Therefore, to establish venue pursuant to Sterling, the jury here had to find that Appellant transmitted the Gift Letter to her Florida mortgage lender from the District of Maryland. Preparatory acts, such as preparing, filling out, or signing the Gift Letter do not suffice. Applying this framework, the district court's venue instruction to the jury was erroneously overbroad. By instructing the jury that "filt [wals sufficient to [establish venue] if any act in furtherance of the crime occurred within the District of Maryland," J.A. 2439, the district court permitted the jury to establish venue based on mere preparatory acts.”
a picture of Hannah Arendt with a speech bubble, as if she is saying the quoted text
≥ Reposted by Ellie Margolis Andrew Selbst @aselbst.bsky.social • 1m I really feel for Con Law profs. How are you supposed to teach anything based on principle? What exactly can you say about the Court ignoring 90-year old precedent with an opposite ruling on the shadow docket with no explanation? How can you do or teach any common law reasoning about Con Law now?
UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT Richmond, VA (9/9/2025 - 9/12/2025 Session) | Tuesday, September 9, 2025 25-1043 Suhail Al Shimari v. CACI Premier Technology, Inc. (Brinkema) JURISDICTION: Whether district court lacked subject matter jurisdiction over claims arising under the Alien Tort Statute.
wojak meme saying “yes”
The P.C. Richard & Son on Route 22 in Union County, New Jersey, which is in a building that looks like a big concrete steamship. there are a couple cars parked outside; the weather is gloomy and the clouds are shining
empty-eyed wojak, representing Rachel and Judge Sooknanan experiencing painful flashbacks to the J.G.G. case
Ronald Dworkin having a great time on a little sailboat, thinking about which principles best fit and justify existing doctrine
Ari Cohn @aricohn.com • 34m I dunno, when you start blaming OpenAl because unwell people did unwell people things, filing massive lawsuits, and waging ap press campaign, this seems the entirely predictable course correction. You wanted guardrails to ensure mentally ill people can't encounter harmful output, now you got it. Jon Christian @jonchristian.net • 2h NEW: After numerous tragedies, OpenAl says it's scanning users' conversations, escalating to human readers, and contacting law enforcement where necessary futurism.com/openai-scann...
a tuxedo cat sits on a lap. the tuxedo cat is named Ed and he looks pleased with himself.
& Reposted by Josh Chafetz Professa Murray @kalimurray.bsky.... • 3m CONGRESS WRITES THE STATUTES; CONGRESS CREATES THE AGENCIES; CONGRESS CAN USE "FOR CAUSE" REMOVAL. Josh Chafetz• @joshchafet... • 15m 1/2 Trump should absolutely not be able to fire Lisa Cook. But this is because he should not be able to fire anyone with statutory tenure protections.
a fluffy tabby cat with green eyes fills the frame. his tongue is bleppin’, his pupils are narrow, and his ear tufts are shining in the sun
there are two cats sitting on a bed. one is a fluffy tabby and the other is a fuzzy tuxedo. their backs are touching each other, adorably. you can see a packet of paper under the paws of the tabby. trust me it is all very cute
there is a cat sitting on a bed, eyes closed, supremely pleased with himself. the cat is a fluffy tabby with long whiskers and big ears. there is a white woman’s hand on his back, which forms a pleasant contrast with his dark back fur.
Mr. Ed (a tuxedo cat with a black muzzle and white mittens) is sitting on my lap, looking unamused
iMessage: “It also won't stop showing me furry anime drawings on the discover feed!!!!! I CANNOT GET RID OF THEM”
a tabby cat, sticking the little tiny end of his tongue out of his mouth, bleppin’. the cat is a very fluffy maine coon and he looks dumb as heck
a tuxedo cat sitting on a green bed. his tail is near the camera and his head is turned around to look. he has gorgeous green eyes
a tuxedo cat with white mittens is sitting on a dining room table, staring into the distance. it’s very cute.
A tree-lined city street. The sunset csts a beautiful pink glow onto two glass-and-sandstone skyscrapers. A bus stop, its curved metal roof painted forest green, is visible at the bottom of the frame.
Ed, a tuxedo tomcat with a bald patch on his front elbow, lounges on a gray bedsheet and looks towards the camera wit one eye closed, like he is winking
A virtual certificate with text "Celebrating 10M users on Bluesky, #167,677, Well-Pleaded Complaints ‪@timorous.cishet.net‬, joined on Jun 28, 2023"
a tuxedo cat is charmingly asleep on a black contractor bag full of clothes that is lying in a very full car. you can see Rachel driving just out of frame.
my neighbor, who is a fuzzy little gray tabby cat, is sitting on a dirt lawn with her eyes closed. it is night and she is photographed with a flash.
A tweet by Richard Hanania: “What is the relationship between poor people and their tattoos? Like if you asked them would they have a deep and meaningful story about each one or would they shrug their shoulders and shrink away in embarrassment? Do they use them as conversation starters?”