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Here is an excellent and comprehensive listing of what to do when you are facing a 619 Motion to Dismiss, complete with case law.
Motions to Dismiss are typically filed right after the Defendant receives the complaint and the Defendant has to Answer the Complaint or otherwise plead.
Generally, if your Defendant does not file a Motion to Dismiss, it is generally waived. However, the Defendant can still file a Motion for Judgment on the Pleadings and/or A Summary Judgment Motion, so make sure your Complaint is on solid grounds.
Reblogged this on Justice for Everyone Blog.