Filing and service are complete. I accepted an extension request. I amended to simplify the case a bit and adjust damages to more appropriate areas.
You might have had a damages as found appropriate or damages as proved. Pity you wasted your amendment as right. But, I'm not reading this in the office so, maybe tomorrow to the core of your question.
The motions are motive/intent which should be admissible from what I've seen, as well as reputation on my part, plus spread of damage evidence relating to the case.
You are motioning over evidence about motive/intent or that your reputation is important? Wow, I'd have to read it all for a real opinion. But, and I say this with trepidation as it seems you are intelligent and have done some study, huh?
You are not going to win a defamation case on summary judgment. Any defamation case. I suppose if we were to theorize, we could find something. As I sit here a moment dreaming, I can't quite get there. But, usually in such dreaming I have knowledgeable friends where all have had some adult beverages to the point can break free of...reality.
Let's face it, as a legal matter, your problems are far greater than reputation. Damages is a HUGE (Think The Donald) problem. It's just that we are not there yet. Not even close to there. The only issue on that point is if the other side will settle rather than deal with you.
For your work in the "case", pretend there is no way on God's Green Earth, you will win in a summary judgment.
I am wanting to not be too aggressive specifically for sanction reasons I'm not really in a hurry any longer so it's not something that's going to kill me sitting through I just don't want to seem inactive as I am far from it.
From what little I know, think long. You should certainly not be accused of a failure to prosecute the case. Other than that, you just follow the rules for a case. Don't blow a statute. Don't ignore a court deadline.
The damage done has pretty much finished me off but I don't need any depositions and literally have somewhere around 3 thousand evidence shots (yea its nuts, guarantee you haven't seen anything like this in any case). I believe the case is pretty solid but I'm up against a pretty pro lawyer (some fortune 100 work) so that probably isn't good. I've studied quite a bit but can't find any good examples of this particular situation.
You've given no real facts (nor do I think it right to give them) for an opinion. If you feel you don't need an depositions (Or other discovery sworn to.) in a defamation case has me believe you are nutbar factor 7. Again, with enough adult beverages and knowledgeable friends and time, you might be able to prove things up without testimony. I think not. I think not even a little tiny bit. I started to write why, but it became a huge determination of time even in thinking about it.
If you have a "pretty pro lawyer" who does fortune 100 work opposed to you, your only thought should be to actually get to fact finding where the facts matter.
Your post is very disappointing to any chance of a win. How much do you feel you were hurt? How much time do you have to remedy it?
I'm not sure you were compensibly hurt in the first place from what you have said. I am less sure you will win. I am certain you will not win as a matter of law.
Last Clear Chance and duty of care however look like they are significantly on my side as I've had no interest in being involved with any of the issues at hand which has been used as a profit mechanism at my expense.
For defamation? Probably not. Maybe, depending on the state, if you were in a car accident.