Hennepin County Government Center, downtown Minneapolis, Minnesota
Malicious Prosecution lawsuit
Gregerson v. Smith, Parker, et. al.

Answer of Defendants Morgan Smith & Smith & Raver LLP

malicious prosecution
-Smith's answer
-Kazaryan's answer
-motion to dismiss
-punitive damages
-summary judgment
petition for review

Morgan Smith is one of the defendants in the malicious prosecution lawsuit I filed May 28th, 2009, in Minnesota State court. His firm, Smith & Raver LLP, is also named as a defendant (based on vicarious liability). Smith was the attorney for the original corporation that sued me for defamation in 2005 with a forged sales agreement.

On June 22nd, 2009, Morgan Smith served me with an Answer to my Complaint for malicious prosecution. His Answer stated, in part, that Defendants Morgan Smith and Smith & Raver LLP lack knowledge to admit or deny the following paragraphs of the Complaint:

Smith appears to be claiming to not know whether the corporation's sales agreement used in the defamation lawsuit against me was forged.

Smith makes an affirmative defense that "Plaintiff's claim fails to state a claim for which relief can be granted." He also offers affirmative pleadings of fact, including that he (and Smith & Raver) "...relied upon the information, comportment, background, and physical evidence presented by clients [the corporation] in forming probable cause...".

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Disclaimer: This is a personal website expressing the opinions and observations of the author.
Website first posted: July 4th, 2009. This page last modified: 2009-07-17
The underlying defamation lawsuit -- Chris Gregerson (chris@cgstock.com)