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IN THE DISTRICT COURT OF THE UNITED STATES? [= Cy mye? FEES FOR THE DISTRICT OF RHODE ISLAND peor LOT AIA AN met UL S. DISTAICT COUR; CUSTRINT TT Neti et as wos pew slaw JOHN J. STARADUMSKY, Plaintiff VS. C. A. 88-0589 (RI Docket) C. 88-2000D (NH Docket) RONALD REAGAN, et al, Defendants Net ee ee ee ee ee ee 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 to state a claim upon which relief can be granted. ? t 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.