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Lawsuit: St. Gabriel’s Marion Tries to Pull a Fast One

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Case 1:21-cv-00190-CMH-JFA Document 54 Filed 05/18/21 Page 1 of 2 PageID# 375

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA ERIC J. BONETTI

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Plaintiff,

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v.

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EPISCOPAL DIOCESE OF VIRGINIA, et al.

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Defendants. * *

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Civil Case No.: 1:21-cv-00190-CMH-JFA

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NOTICE OF DEFENDANTS’ JOINT MOTION TO DISMISS PLAINTIFF’S AMENDED COMPLAINT (Grace Episcopal Church, Episcopal Diocese of Virginia, Episcopal Diocese of Massachusetts and St. Gabriel’s Church) Please take notice that on Friday, May 21, 2021, at 10:00 o’clock a.m. or as soon thereafter as he may be heard, the Defendants Grace Episcopal Church, Episcopal Diocese of Virginia, Episcopal Diocese of Massachusetts and St. Gabriel’s Church, by counsel, will move for a dismiss of the Plaintiff’s Amended Complaint pursuant to the Motion filed (Docket Text No. 30) at which time you may be present if you so desire. Defendants move that this case should be heard jointly with the Motions to Dismiss and Memoranda to the Complaint and Amended Complaint filed by the other Defendants, namely Defendant Malm, and the Motion to Dismiss and Memorandum filed by the City of Alexandria and any other Defendants.

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Case 1:21-cv-00190-CMH-JFA Document 54 Filed 05/18/21 Page 2 of 2 PageID# 376

Respectfully submitted: / s / Matthew J. Youssef Craig D. Roswell, Esquire (VSB No.: 33901) Matthew J. Youssef, Esquire (VSB No.: 85339) NILES, BARTON & WILMER, LLP 111 S. Calvert Street, Suite 1400 Baltimore, Maryland 21202 (410) 783 – 6357 (410) 783 – 6452 facsimile cdroswell@nilesbarton.com mjyoussef@nilesbarton.com Counsel for Defendants, Grace Episcopal Church, Episcopal Diocese of Virginia, Episcopal Diocese of Massachusetts, and St. Gabriel’s Church CERTIFICATE OF SERVICE I HEREBY CERTIFY that on May 18th, 2021, a true and accurate copy of the foregoing was electronically filed with the Clerk of the Court using the CM/ECF system and a copy emailed and mailed to: Eric J. Bonetti 4129 Fountainside Lane #203 Fairfax, VA 22030 / s / Matthew J. Youssef Matthew J. Youssef 4842-7495-6010, v. 1

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