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« to state a claim upon which relief can be granted. IN THE DISTRICT COURT OF THE UNITED STATES FOR THE DISTRICT OF RHODE ISLAND JOHN J. STARADUMSKY, Plaintiff C. A. 88-0589 (RI Docket) C. 88-2000D (NH Docket) . VS. RONALD REAGAN, et al, Defendants eet et ee et Oe eet Set FEDERAL AND INDIVIDUAL ° DEFENDANTS' MOTION TO DISMISS Now comes the federal and individual defendants, | through their counsel, the United States Attorney for the District of Rhode Island, and respectfully move pursuant to Rules 8(a)(2) and 12(a)(1) and (6) of the Federal Rules of Civil Procedure that the above-captioned action be dismissed with prejudice for failure to set forth a claim and failure 2 —————— ee Said defendants are enumerated as defendants 1-18; 22; 51-55 and 61 in the Complaint. Also included in this motion are any other federal defendants who have not been so enumerated but included in the Complaint. 2 defendants by this motion do not waive any defense pursuant to Fed. R. Civ. P. 12(h). In the event this motion is denied, defendants specifically reserve the right to assert any and all defenses available to them. These defenses include, without limitation, lack of personal jurisdiction and insufficiency of process and service of process; lack of subject matter jurisdiction; failure to exhaust the appropriate administrative remedies; failure to state a claim upon which relief can be granted; statute of limitations; absolute and qualified immunity; and improper venue. 177-2? & - ae de mine - lee rea ames oe + ttn nee