Fox Reply Brief Oh gosh, guys, if the ladies from FfJ weren't causing enough problems for Woody and his clients, the latter are also stuck with dealing with Fox News. Looks like Woody got plenty of problems dealing with REAL lawyers who have no problem telling him he's wrong or misinformed, etc. Currently, the matter before the court is a request for change of venue, from Georgia to Colorado. Fox's reply memorandum (linked above) is informative and puts Woody in his place. Fox points out that just because plaintiff's think they have friends in their former domicile of GA who may testify on their behalf (as to damages), it is a "limited perspective" and doesn't take into account that Fox's witnesses are critical non-party witnesses (Boulder law enforcement). They go on to state that no witnesses, "except for plaintiffs' friends and counsel" would find it convenient to try the case in GA. Further, "plaintiffs' further attempt to counter Fox's comprehensive list of material liability witnesses with a bloated list of of alleged damage witnesses is unpersuasive...As such, Fox's list of liability witnesses should be given substantially more weight than plaintiffs' string of damage witnesses." I enjoyed reading how Fox put it to Wood. For example, "...plaintiffs incorrectly contend that Fox has presented a "laundry list" of witnesses offering "cumulative" and "irrelevant" testimony. (Sound familiar?) "Far from being a laundry list, Fox has offered a targeted list of only those individuals material to this action." "In contrast, plaintiffs presented numerous individuals -- offering redundant and limited testimony -- in an obvious attempt to inflate their list of necessary GA witnesses." Fox continues its lambasting of the Ramseys: "Plaintiffs have ignored, mischaractized or casually dismissed several factors of paramount importance to an interest of of justice analysis. First, plaintiff's try to discount the significance of the pertinent documents located in CO." And..."plaintiffs' counsel has once again factually inserted himself into this case by declaring that he has visited plaintiffs former home and that it has undergone "significant changes". Even if some changes were made, plaintiffs do not allege that the general layout or points of egress or ingress of the home has changed... ." "Finally, plainitffs' have completely mischaracterized the First Amendment implications in this matter." (Here, the Ramseys/Wood mischaracterize the case of Calder v Jones as referring to change in venue. Fox notes, "Even a cursory reading (of Calder) reveals they refer to personal jurisdiction." Here's the one I like best: "Faced with overwhelming evidence supporting transfer, plaintiffs resort to a baseless suggestion that they cannot get a fair trial in CO...However, plaintiffs assertion, based purely on conjecture, should be rejected." Oh bummer, I have to stop for now...time to pick up my Belle from the vet hospital. Will catch up with you all latah!