Looks like Rusty is about to get declawed and his balls clipped.
I wonder if they're considering a vexlit finding from the federal court or a state court in Nevada. One version of this is the pre-filing injunction, requiring the vexlit attach a copy of the order to any filing, requiring pre-filing review of in forma pauperis filings (which courts should really be doing anyway), or even putting up a bond for a potential fee award when they lose their frivolous lawsuit. Or a court can craft its own injunctive remedy using anything within its jurisdiction.
If they do it in federal court according to the rules/court's inherent powers/etc., they can make it applicable to all federal courts in the country.
Russ's arguments are patently frivolous, and while I rarely try to outright predict outcomes, I think it is a virtual inevitability the MtC gets granted. The judge would have to be on crack not to grant it.
I also like how about half the document is lengthy string cites to cases uniformly saying "grant these motions nearly always." That's why I think at least those are from a brief bank with some Shepardizing to get more recent cases from the Ninth Circuit to make it clear this has been for years and is currently good law.
It was also a good catch to notice Russhole maliciously adding Fremantle to try to weasel out of the agreement, and why that doesn't fly either.
And the correspondence, holy shit, Russ is an insufferable cunt with delusions of adequacy.
Michael Avenatti went to prison for shit like this. It's pretty unlikely they'll do that to an even shitty vexlit like Russ, though.
I'll note that Lens doesn't have any ratings on Avvo or Martindale Hubbell despite having practiced for 17 years, much of it litigation, but if I were to review these filings, I would say they're rock solid.