The Attorney’s Client (the “Ultimate Client”), a company, was alleged to have conspired with various other market players in a commercial bribery scheme to rig bids. It was alleged by the plaintiff that a
multibillion-dollar market was impacted by the bid-rigging and commercial bribery conspiracy. The complaint had quite a few defendants named in it. The court, therein, allowed the so named defendants to file a joint Memorandum of Law in Support of their Motion and individual Motions, if the individual defendants so require. The Client was in favor of filing both, the joint Memorandum of Law and an individual Memorandum of Law. The drafting of the individual Memorandum of Law in Support of Motion to Dismiss was a formidable task as the Motion had to be not more than 8 pages, an 8-page Motion Brief of a 65-page complaint.

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