Filed December 23, 2011
See Gov’t Br. 31-32 (citing Martin v. County of San Diego, 650 F. Supp. 2d 1094, 1108 (S.D. Cal. 2009) (noting that § 52.1(j) “explicitly provides that violence is a required element . . . where the [claim] is based purely upon a defendant’s statement” (emphasis added)); Doe By and Through Doe v. Petaluma City Sch.
Filed May 9, 2011
Sony also complains Mr. Flynn was aware of his “financial situation” in January 2011, and such information should have been included in his opposition to the order to show cause. The correct standard here under Federal Rule of Civil Procedure Rule 60 is reconsideration may be based upon “any … reason justifying relief from the operation of the judgment.” Martin v. County of San Diego, 650 F. Supp. 2d 1094, Case 3:09-cv-02109-AJB -RBB Document 69 Filed 05/09/11 Page 4 of 6 ______________________________________________________________________________ REPLY IN SUPPORT OF PLAINTIFF’S MOTION FOR RECONSIDERATION 09-cv-2109 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1111 (S.D. Cal. 2009). Contrary to Sony’s opposition, application for reconsideration may include new or different facts which “were not shown” upon the prior application.