MEMORANDUM OF LAW IN REPLY

On May 12, 2023 a case was filed by A. M. A Minor, Barbara Mapps Individually And As Executrix Of The Estate Of Katherine Massey, Diona Patterson Individually And As Administrator Of The Estate Of Heyward Patterson et al. represented by Dymond, Seth A, Elmore, John V., Marks, Harris Lee, and Rome, Leigh Gabrielle, against 4Chan Community Support, Llc, 4Chan, Llc, Alphabet, Inc. et al. represented by Allen, Scott S., Banas, Mitchell J, Brady, Daniel Joseph et al. in the jurisdiction of Erie County. Judge Paula L Feroleto presiding.

                        
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FILED: ERIE COUNTY CLERK 10/31/2023 10:33 AM INDEX NO. 805896/2023 NYSCEF DOC. NO. 338 RECEIVED NYSCEF: 10/31/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ERIE Diona Patterson, individually and as Administrator of the ESTATE OF HEYWARD Index No. 805896/2023 PATTERSON; J.P., a minor; Barbara Mapps, Individually and as Executrix of the ESTATE OF KATHERINE MASSEY; Shawanda Rogers, Individually and as Administrator of the ESTATE OF ANDRE MACKNIEL; A.M., a minor; and LATISHA ROGERS, Plaintiffs, v. META PLATFORMS, Inc., formerly known as FACEBOOK, INC.; SNAP, INC.; ALPHABET, INC.; GOOGLE, LLC; YOUTUBE, LLC; DISCORD, INC.; REDDIT, INC.; AMAZON.COM, INC.; 4CHAN, LLC; 4CHAN …

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