NEWS & EVENTS
Hit Me with Your Best Shot: An Employer’s Guide to COVID Vaccines and Other Pat Benatar Songs
POSTED FEBRUARY 4, 2021
As the nation rolls out COVID vaccines, there are many unsettled issues for employers. Can employers require employees to take vaccines? What are the potential liability risks involved? Tune in to this panel discussion that dissects the latest EEOC guidance…
VIEW ARTICLEUSLAW NETWORK releases COVID-19 Civil Immunity Chart
POSTED DECEMBER 15, 2020
USLAW NETWORK today releases a new multistate client resource that addresses civil immunity in relation to the ongoing COVID-19 crisis for every state and Washington D.C. Keely E. Duke of Duke Evett, PLLC in Boise, Idaho, served as the author…
VIEW ARTICLEUSLAW NETWORK releases COVID-19 Statutes of Limitations Quick Guide
POSTED DECEMBER 14, 2020
USLAW NETWORK today releases its newest compendium of law, a multi-state resource that addresses state statutes of limitations during the ongoing COVID-19 pandemic. Written by USLAW NETWORK member attorneys, the compendium takes advantage of local knowledge and experience in each…
VIEW ARTICLERESOURCES

Fall 2020 USLAW MAGAZINE
VIEW RESOURCE
State Judicial Profiles by County
VIEW RESOURCE
2020 USLAW Member Directory & SourceBook
VIEW RESOURCEYOUR HOMEFIELD ADVANTAGE
A Legal Network for Purchasers of Legal Services.
In today’s global marketplace, legal needs often transcend geographic boundaries. Clients with complex needs turn to USLAW NETWORK member firms to represent them in the courtroom and the boardroom, next door and across the United States and around the world.
USLAW PERSPECTIVE
Cory J. Feinberg
Associate General Counsel
MoneyGram International • Dallas, Texas
MoneyGram is a global provider of innovative money transfer and payment services. It's mission is to connect friends and family throughout the world anyway that is convenient by providing a reliable financial connection for life's essentials and daily needs.
Linda G. Thoede
Senior Corporate Counsel Litigation
iHeartMedia, Inc. • San Antonio, Texas
iHeartMedia is a leading global media and entertainment company specializing in radio, digital, outdoor, mobile, social, live events and on-demand entertainment.
LEARN MOREMichael J. Chmielewski
Corporate Risk & Insurance Manager
Ace Hardware Corporation • Oak Brook, Illinois
Ace Hardware Corporation is a cooperative hardware wholesaler supporting the business needs of more than 3,000 individual member retailers who own and operate more than 4,600 stores located in all 50 states and in more than 60 countries.
LEARN MORESusan V. Stucker
VP, Legal - Litigation, Risk & Employment
HD Supply • Orlando, Florida
HD Supply is one of the largest industrial distributors in North America. The company provides a broad range of products and value-add services to approximately 500,000 customers with leadership positions in maintenance, repair and operations and residential and non-residential construction sectors. It's leading businesses include HD Supply Facilities Maintenance and HD Supply Construction & Industrial - White Cap.
LEARN MORERose M.J. Charles
Vice President, Head of Excess and Primary Casualty Claims Counsel
Endurance Services, Ltd. • New York, New York
Endurance Specialty Holdings Ltd. is a global specialty provider of property and casualty insurance and reinsurance.
LEARN MOREMike Kennedy
General Counsel
Associated General Contractors of America • Arlington, Va.
The Associated General Contractors of America (AGC) is the leading association for the construction industry.
LEARN MOREJean Dalmore
Attorney
Murchison & Cumming LLP • Los Angeles, California
Murchison & Cumming represents domestic and international businesses, insurers, professionals and individuals in litigated, non-litigated and transactional matters. In this clip, Jean Dalmore talks about the current construction law landscape.
LEARN MOREStephanie Fisher
Director of Risk Management and Insurance
Quanta Services, Inc. • Houston, Texas
Quanta Services (NYSE: PWR) is a leading provider of specialized contracting services, delivering infrastructure solutions to the electric power and natural gas and pipeline industries.
LEARN MORETom Thornton
Attorney
Carr Allison • Birmingham, Alabama
Carr Allison was formed in Birmingham, Ala., in 1997, and serves the legal defense needs of businesses and the insurance industry.
LEARN MOREKristin Burman
Director, Insurance and Claims
United Road • Romulus, Michigan
Headquartered in Romulus, Mich., United Road is one of the largest vehicle transportation logistics solutions providers in the United States.
LEARN MORESUCCESS
JSH Attorneys Win on Appeal from New Trial Order Entered Two Years After Defense Verdict
Jones, Skelton & Hochuli, P.L.C. (Phoenix, AZ)
LEARN MOREWicker Smith obtained a defense verdict in a nursing home negligence case
Wicker, Smith, O’Hara, McCoy & Ford, P.A. (Orlando and Tampa, FL)
LEARN MORESnyder Burnett Egerer, LLP secured defense verdict in race retaliation, whistleblower, and defamation case
Snyder Burnett Egerer, LLP (Santa Barbara, CA)
LEARN MOREWilliams Kastner earns victory for manufacturer and supplier of dryer felts
Williams Kastner (Seattle, WA)
LEARN MOREJones, Skelton & Hochuli Attorneys Jay Rosenthal and John Lierman Conquer Four-Day Jury Trial
Jones, Skelton & Hochuli (Phoenix, AZ)
LEARN MORERod Umberger of Williams Kastner obtained a defense verdict for national utility construction services company
Williams Kastner (Seattle, WA)
LEARN MOREJones, Skelton & Hochuli attorneys Cristy Chait, Cory Tyszka obtained a defense verdict for a medical malpractice case
Jones, Skelton & Hochuli (Phoenix, AZ)
LEARN MOREJim Girman from Pion, Nerone, Girman, Winslow & Smith received a defense verdict
Pion, Nerone, Girman, Winslow & Smith, P.C. (Pittsburgh, PA)
LEARN MOREBingham Greenebaum Doll LLP successfully defend a data security breach case
Bingham Greenebaum Doll LLP (Indianapolis, IN)
LEARN MOREPierce Couch successfully defended a motor carrier in a catastrophic traumatic brain injury case
Pierce Couch Hendrickson Baysinger & Green, L.L.P (Oklahoma City, OK)
LEARN MOREMcCranie Sistrunk Anzelmo Hardy McDaniel & Welch LLC successfully represented Nissan entities in manufacturing defect case
McCranie Sistrunk Anzelmo Hardy McDaniel & Welch LLC (New Orleans, Louisiana)
LEARN MOREBingham Greenebaum Doll LLP obtained significant victory on appeal
Bingham Greenebaum Doll LLP (Indianapolis, IN)
LEARN MOREPierce Couch secured a summary judgment in favor of a defendant physician
Pierce Couch Hendrickson Baysinger & Green, L.L.P (Oklahoma City, OK)
LEARN MOREMcCranie Sistrunk Anzelmo Hardy McDaniel & Welch LLC obtained a unanimous defense verdict for ACE
McCranie Sistrunk Anzelmo Hardy McDaniel & Welch LLC (New Orleans, Louisiana)
LEARN MORERichmond & Quinn earn defense verdict in Ice Road Truckers case
Richmond & Quinn (Anchorage, Alaska)
LEARN MOREPierce Couch obtained a unanimous defense verdict on behalf of a neurosurgeon
Pierce Couch Hendrickson Baysinger & Green, L.L.P. (Oklahoma City, OK)
LEARN MOREMurchison & Cumming Partners Claim Two Trial Victories in One Week
Murchison & Cumming, LLP (Los Angeles, CA)
LEARN MORESteve Bullington and Cory Tyszka Obtain Unanimous Defense Verdict
Jones, Skelton & Hochuli (Phoenix, Arizona)
LEARN MOREPierce Couch obtained summary for an interventional radiologist in a wrongful death lawsuit
Pierce Couch Hendrickson Baysinger & Green, L.L.P (Oklahoma City, OK)
LEARN MOREMike Sistrunk, Devin Fadaol victory for Republic Vanguard Insurance Company’s named insured
McCranie, Sistrunk, Anzelmo, Hardy, McDaniel & Welch, LLC (New Orleans, Louisiana)
LEARN MOREDefense Verdict Obtained in Legal Malpractice Case
Jones, Skelton & Hochuli (Phoenix, Arizona)
LEARN MORESummary Judgment Granted in Premise Liability and Fraudulent Land Transfer Case
Jones, Skelton & Hochuli (Phoenix, Arizona)
LEARN MORERussell Skelton and Douglas Cullins Obtain Unanimous Defense Verdict
Jones, Skelton & Hochuli (Phoenix, Arizona)
LEARN MOREMichael Hensley and John Lierman Obtain Summary Judgment
Jones, Skelton & Hochuli (Phoenix, Arizona)
LEARN MOREBill Caravetta Prevails on Defense of Bad Faith Claim, Judge Rules on Motion for Summary Judgment
Jones, Skelton & Hochuli (Phoenix, Arizona)
LEARN MOREKlinedinst Attorneys Successfully Defend Injured Concertgoer’s $10.7M Suit After Stage Dive by Celebrity DJ
Klinedinst P.C. (San Diego, CA)
LEARN MOREJSH Attorneys Prevailed By Motion To Dismiss In Professional Negligence Matter
Jones, Skelton & Hochuli (Phoenix, Arizona)
LEARN MORERoetzel & Andress Earn Significant Victory for Trucking Company in Admitted Negligence Case
Roetzel & Andress LPA (Akron, Ohio)
LEARN MORETraub Lieberman Partner Lisa Black Obtains Summary Judgment Dismissing All Claims Against Contractor in Bronx County Construction Site Accident Case
Traub Lieberman Straus & Shrewsberry LLP (Hawthorne, NY)
LEARN MOREJones, Skelton & Hochuli Successfully Obtained A Directed Verdict for WaterFurnace International, Inc.
Jones, Skelton & Hochuli (Phoenix, AZ)
LEARN MORESweeny, Wingate & Barrow, P.A. prevailed on an appeal to the Fourth Circuit Court of Appeals
Sweeny, Wingate & Barrow, P.A. (Columbia, SC)
LEARN MOREMurchison & Cumming, LLP Scares Away Plaintiff in Assumption of Risk Case
Murchison & Cumming LLP (Los Angeles, CA)
LEARN MORESweeny, Wingate & Barrow, P.A. attorneys obtain a defense verdict after jury deliberations in data center case
Sweeny, Wingate & Barrow, P.A. (Columbia, SC)
LEARN MORETraub Lieberman Obtains Defense Verdict in Motor Vehicle Accident case
Traub Lieberman Straus & Shrewsberry LLP (Hawthorne, N.Y.)
LEARN MOREGoldberg Segalla LLP acted as primary trial counsel in the defense of a commercial aviation disaster
Goldberg Segalla (Buffalo, NY)
LEARN MORECarr Allison attorneys successfully defended a major transportation client in a week-long trial in Circuit Court in north Alabama
Carr Allison (Birmingham, AL)
LEARN MOREHinckley, Allen & Snyder LLP obtained a $5+ million award in favor of Stonington Water Street Associates
Hinckley, Allen & Snyder LLP (Hartford, CT)
LEARN MORETLSS Attorneys Obtain Dismissal in Adjacent Support Property Damage Matter
Traub Lieberman Straus & Shrewsberry LLP (Hawthorne, N.Y.)
LEARN MOREPoyner Spruill attorneys successfully defended Sheriff Donnie Harrison, the Sheriff of Wake County, and three of his detention officers in an excessive force claim
Poyner Spruill LLP (Raleigh N.C. )
LEARN MOREJones, Skelton & Hochuli obtained summary judgment in declaratory judgment/coverage litigation involving choice of law and stacking of UM/UIM
Jones, Skelton & Hochuli (Phoenix, AZ)
LEARN MORETLSS Attorneys Mario Castellitto and Timothy G. McNamara Obtain Dismissal of Labor Law Based Personal Injury Matter
Traub Lieberman Straus & Shrewsberry LLP (Hawthorne, N.Y.)
LEARN MOREPoyner Spruill obtained an order from the United States District Court for the Eastern District of North Carolina affirming the dismissal of claims brought against their client, AgCarolina Farm Credit, ACA, based on PACA
Poyner Spruill LLP (Raleigh, NC)
LEARN MORETLSS Attorneys Stephen D. Straus and Jeremy P. Monosov Obtain Dismissal of Legal Malpractice Complaint against Client Arising from Mortgage Foreclosure Action
Traub Lieberman Straus & Shrewsberry LLP (Hawthorne, N.Y.)
LEARN MORELewis Roca Rothgerber LLP part of team that successfully brought to conclusion a habeas corpus death penalty case in Texas
Lewis Roca Rothgerber LLP (Denver, CO)
LEARN MORELarson • King Trial Team Successfully Defends Catastrophic Derailment Claim
Larson • King LLP (Minneapolis, Minn.)
LEARN MOREDefense verdict in multimillion-dollar product liability trial
Goldberg Segalla (Syracuse, NY)
LEARN MORETLSS Attorneys Stephen D. Straus and Jeremy P. Monosov Obtain Summary Judgment Dismissing New York Labor Law Suit
Traub Lieberman Straus & Shrewsberry LLP (Hawthorne, N.Y.)
LEARN MORECarr Allison obtained arbitrator's decision in favor of an employer in a union grievance arbitration
Carr Allison (Birmingham, AL)
LEARN MOREModrall Sperling obtained a defense verdict in a wrongful death case
Modrall Sperling (Albuquerque, NM)
LEARN MOREEbeltoft . Sickler . Lawyers obtained summary judgment for Travelers Property Casualty Company of America
Ebeltoft . Sickler . Lawyers (Dickinson, ND)
LEARN MORESix separate defense verdicts in a hotly contested battle between adjoining landowners
Murchison & Cumming LLP (Los Angeles, CA)
LEARN MORETLSS obtains summary judgment in Southern District of New York voiding excess property insurance policy and awarding insurer nearly $4 million for recoupment of payments
Traub Lieberman Straus & Shrewsberry LLP (Hawthorne, NY)
LEARN MOREFollowing a 6-day arbitration hearing in January 2014, the arbitrator issued an award that rescinded the contract...
Bingham Greenebaum Doll LLP (Indianapolis, IN)
LEARN MORESuccessful defense of an oilfield drilling rig moving company, gin pole truck driver
Pierce Couch Hendrickson Baysinger & Green, L.L.P. (Oklahoma City, OK)
LEARN MOREDefense verdict in the Marteny, Diane (E/O) v. Irma Alves, M.D. case
Wicker, Smith, O’Hara, McCoy & Ford, P.A. (Coral Gables, FL)
LEARN MORECourt granted summary judgment in favor of CorrectHealth Jefferson, LLC and two of its nurses
McCranie Sistrunk Anzelmo Hardy McDaniel & Welch LLC (New Orleans, LA)
LEARN MOREFavorable damages verdict in chain-reaction rear end automobile accident trial.
Franklin & Prokopik (WILMINGTON, DE)
LEARN MOREEstoppel cannot be used to create insurance coverage
Sweeny, Wingate & Barrow, P.A. (Columbia, SC)
LEARN MOREFollowing a four-week federal antitrust trial, the largest hospital system in Idaho was ordered to unwind a transaction in which it had acquired the largest independent physician practice group in Idaho.
Duke Scanlan & Hall, PLLC (Boise, ID)
LEARN MORETraub Lieberman’s motion for Summary Judgment was granted on behalf of its client Carp Construction Corp. (“Carp”) in a decision issued by New York State Supreme Court on a construction site accident case.
Traub Lieberman Straus & Shrewsberry LLP (Hawthorne, N.Y.)
LEARN MORECarmel Cosgrave and Colin Gainer of SmithAmundsen successfully defended their client, a large suburban hospital, at trial against a claim of apparent agency.
SmithAmundsen (Chicago, Ill.)
LEARN MOREChris Cotter with Roetzel & Andress, LPA obtained a verdict for his clients, a motor carrier and insurance company, in a recent trial in Stark County, Ohio.
Roetzel & Andress LPA (Akron, Ohio)
LEARN MOREPeter J. Wanek and Trevor C. Davies defended Chick-fil-A in a premises liability case (John and Casie Dekerlegand v. John Arton d/b/a/ Chick-fil-A of I-10 at Louisiana Avenue FSU, et al ) wherein the plaintiffs claimed employees mopped and failed to post caution wet floor signs.
McCranie Sistrunk Anzelmo Hardy McDaniel & Welch LLC (New Orleans, La.)
LEARN MOREDamages awarded under the Tennessee Consumer Protection Act
Martin, Tate, Morrow & Marston, P.C. (Memphis, TN)
LEARN MOREIn an unusual turn of events, a major motor carrier was recently awarded a sizable judgment by a Tennessee jury. Lee Piovarcy and Lew Wardlaw of the Martin Tate firm in Memphis tried the case to verdict.
Martin, Tate, Morrow & Marston, P.C. (Memphis, Tenn.)
LEARN MOREThe joint efforts of the Transactional and Litigation practice groups from Bingham Greenebaum Doll LLP achieved significant results for firm client First Merchants Corporation (“FMC”). This is a great example of synergy to achieve client results.
Bingham Greenebaum Doll LLP (Louisville, Ky.)
LEARN MOREJennifer D. Tricker, a partner at Baird Holm LLP in Omaha, Neb., obtained a defense verdict for her client, Landstar Ranger, Inc. ("Landstar"), in the United States District Court for the District of Nebraska, in a case alleging violation of the Carmack Amendment (49 U.S.C. §14706).
Baird Hold (Omaha, Neb.)
LEARN MOREA New Mexico federal judge recently granted a BNSF summary judgment motion that plaintiff’s ballast claims are preempted by federal law.
Modrall Sperling (Albuquerque, N.M.)
LEARN MOREWicker Smith O'Hara McCoy & Ford P.A. secures $1.25 million verdict settlement
Wicker Smith O'Hara McCoy & Ford P.A. (Coral Gables, Fla.)
LEARN MOREPhillip Stanfield and Jeremy Johnson of Jones, Skelton & Hochuli, recently obtained a defense verdict on behalf of Werner Enterprises in a highly-contested wrongful death case in federal court.
Jones, Skelton & Hochuli, P.L.C. (Phoenix, Ariz.)
LEARN MORERandall Sickler and Nicholas Grant of Ebeltoft . Sickler . Lawyer . PLLC were recently successful in obtaining summary judgment in North Dakota state court on behalf of their client on claims arising from an explosion and fire at a commercial building.
Ebeltoft . Sickler . Lawyer . PLLC (Dickinson, N.D.)
LEARN MOREMartha G. Brown and Deana M. Bennett, attorneys with the USLAW law firm Modrall Sperling in Albuquerque, New Mexico, received a favorable decision from the New Mexico Supreme Court
Modrall Sperling (Albuquerque, N.M.)
LEARN MOREDonald Myles and Josh Snell, with Jones, Skelton & Hochuli, received summary judgment in Maricopa County for Farmers in a breach of contract, bad faith claim arising from an underlying $5,000,000 stipulated judgment claim involving...
Successful Verdict: Jones, Skelton & Hochuli (Phoenix, Ariz.)
LEARN MOREGoldberg Segalla helped a Fortune 100 company recover a significant sum in a case involving the misappropriation and fraudulent conveyance of funds by a contractor over the course of a several-year business relationship.
Goldberg Segalla (Buffalo, N.Y.)
LEARN MORELashly & Baer attorneys obtain dismissal of lawsuit involving warehouse accident
Lashly & Baer, P.C. (St. Louis, Mo.)
LEARN MOREAfter six days of trial, Sweeney & Sheehan partner and USLAW Board member Michael Kunsch obtained a defense verdict in favor of Louisville Ladder and W.W. Grainger in a product liability case in the U.S. District Court for the Middle District of Pennsylvania.
Sweeney & Sheehan (Philadelphia, Pa.)
LEARN MOREKunsch obtains defense verdict for American Multi Cinema, Inc.
Sweeney & Sheehan, Philadelphia, Pa.
LEARN MORETraub Lieberman Straus & Shrewsberry Attorneys Robert Nobel and Megan Bronk successfully obtained summary judgment on behalf of their insurer client
Traub Lieberman Straus & Shrewsberry LLP (Hawthorne, N.Y.)
LEARN MORECircuit Court of Shelby County (Memphis), Tennessee, rendered a defense verdict (take nothing judgment) in favor of a national bus company. Lee Piovarcy and Lew Wardlaw of the Martin Tate Firm in Memphis tried the case to verdict.
Martin Tate Morrow and Marston, P.C. (Memphis, Tenn.)
LEARN MOREThe Court found that the parties had charted a summary judgment course, and granted TLS&S summary judgment. Mr. Castellitto and Mr. Kuebler successfully opposed Plaintiffs’ motion to reargue.
Traub Lieberman Straus & Shrewsberry LLP (Hawthorne, N.Y.)
LEARN MOREJim Moore and Eric Toney of Copeland, Cook, Taylor & Bush, P.A., in Ridgeland, MS obtained a defense verdict for their client, Kohler Transport, Inc., in a recent four-day trial in federal court.
Copeland, Cook, Taylor & Bush, P.A. (Ridgeland, MS)
LEARN MOREThe Fourth District Court of Appeal affirmed in full the Orange County Superior Court's granting of Essentia Insurance Company's Motion for Summary Judgment. Carolyn A. Mathews handled the Motion for Summary Judgment and the opposition to the appeal, and Maria A. Starn handled the oral argument.
Murchison & Cumming, LLP (Los Angeles, Calif.)
LEARN MORETraub Lieberman Straus & Shrewsberry’s (TLS&S) motion for summary judgment was granted on behalf of its client Transitional Services for New York (TSNY) in a decision issued by New York State Supreme Court Judge Augustus Agate.
Traub Lieberman Straus & Shrewsberry LLP (Hawthorne, N.Y.)
LEARN MOREGoldberg Segalla’s Environmental Practice Group successfully defended the corporate owner of the premises and its principal, avoiding in their entirety civil penalties against the corporation and the criminal prosecution of the principal for alleged violations of the Clean Air Act.
Goldberg Segalla LLP (Buffalo, N.Y.)
LEARN MORERandall Sickler and Nicholas Grant of Ebeltoft . Sickler . Lawyers . PLLC recently obtained summary judgment for their client, Werner Enterprises, Inc.
Ebeltoft . Sickler . Lawyers (Dickinson, N.D.)
LEARN MOREA landmark ruling upholding the rights of minority shareholders in a case involving one of Virginia’s most prosperous and longstanding mining and landholding enterprises has set a strong precedent and reversed the family’s fortune.
LeClairRyan (Richmond, VA)
LEARN MORECourtney Olson of Ebeltoft . Sickler . Lawyers recently obtained the rarely-seen Order for Summary Judgment in a negligence action in North Dakota District Court.
Ebeltoft . Sickler . Lawyers (Dickinson, N.D.)
LEARN MOREDoug Martin and Eric Stevens of Poyner Spruill, LLP successfully defended a claim for copyright infringement in architectural plans.
Poyner Spruill, LLP (Raleigh, NC)
LEARN MOREAfter an excavator operated by Frontier Services, Inc. (Frontier) collided with an underground high-pressure natural gas line, an explosion, fire and significant property damage resulted. Ebeltoft . Sickler . Lawyers represented Frontier, an underground pipeline installation company active in the North Dakota Bakken oil play
Ebeltoft . Sickler . Lawyers (Dickinson, N.D.)
LEARN MORESweeney & Sheehan senior associate Frank LaRocca obtained summary judgment in Pennsylvania state court on behalf of a baseball team which was part of a national youth baseball league.
Sweeney & Sheehan (Philadelphia, Pa.)
LEARN MOREA Bakersfield jury returned a defense verdict in a premises liability case handled by Joseph Kang of Murchison & Cumming for defendant Tehachapi Towne Center, LLC. In Betty Ramirez v. Tehachapi Towne Center, LLC, the plaintiff alleged personal injury, general negligence and premises liability after tripping and falling on the flared side of the handicap ramp near the entrance of a store located in the shopping center.
Murchison & Cumming, LLP (Los Angeles, CA)
LEARN MOREOn October 25, 2012, Keely E. Duke and Richard E. Hall of Duke Scanlan & Hall, PLLC, secured a final decision from the Ninth Circuit affirming a jury verdict in favor of their defendant physician in a highly publicized case involving emergency room care provided to an infant in the face of parental refusal of such care.
Duke Scanlan & Hall PLLC (Boise, ID)
LEARN MOREJ. Lawson Johnston, Scott D. Clements and Aaron Ponzo of Pion Johnston were successful in having a Common Pleas Court Judge grant Defendant’s Motion for Frye Hearing and dismiss multiple occupational lung disease cases filed by former employees of Delaware and Hudson Railway Company.
Pion, Johnston, Nerone, Girman, Clements & Smith, P.C. (Pittsburgh, PA)
LEARN MOREFollowing oral argument, the Court granted Traub Lieberman Straus & Shrewsberry’s motion in its entirety.