Case 2:16-cv-02529-SHL-cgc Document 23 Filed 08/10/16 Page 1 of 2

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION ________________________________________________________________ SHIRLEY COHEN AND HANNAH COHEN, Plaintiffs, v.

NO. 2:16-CV-2529

TRANSPORTATION SECURITY ADMINISTRATION, MEMPHIS-SHELBY COUNTY AIRPORT AUTHORITY, AND MEMPHIS INTERNATIONAL AIRPORT POLICE DEPARTMENT, Defendants. DEFENDANT MEMPHIS INTERNATIONAL AIRPORT POLICE DEPARTMENT’S MOTION FOR JUDGMENT ON THE PLEADINGS COMES NOW the Defendant Memphis International Airport Police Department, by and through its counsel of record, pursuant to Rule 12(c) of the Federal Rules of Civil Procedure and Rule 12.1 of this Court’s Local Rules, and hereby moves this Court to enter an Order granting its Motion for Judgment on the Pleadings and to dismiss this case with prejudice because, based upon the pleadings, Defendant Memphis International Airport Police Department deserves a judgment as a matter of law. In support of this Motion, Defendant fully incorporates herein and relies upon its Memorandum of Law and the entire record in this matter. WHEREFORE, Defendant Memphis International Airport Police Department moves this Honorable Court to enter an Order granting

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Case 2:16-cv-02529-SHL-cgc Document 23 Filed 08/10/16 Page 2 of 2

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its Motion for Judgment on the Pleadings and to dismiss this case against it with prejudice. Respectfully submitted, PETKOFF AND FEIGELSON, PLLC /s/James L. Cresswell, Jr. James L. Cresswell, Jr. (#26257) David I. Feigelson (#20350) Logan A. Klauss (#34311) 305 Washington Avenue Memphis, Tennessee 38103-1911 (901) 523-1050 Attorneys for Memphis-Shelby County Airport Authority and Memphis International Police Department CERTIFICATE OF SERVICE I hereby certify that on August 10, 2016 a copy of the DEFENDANT MEMPHIS INTERNATIONAL AIRPORT POLICE DEPARTMENT’S MOTION FOR JUDGMENT ON THE PLEADINGS was filed electronically. Notice of this filing will be sent by operation of the Court’s electronic filing system to all parties indicated on the electronic filing receipt. All other parties will be served by regular U.S. Mail. Parties may access this filing through the Court’s electronic filing. Mr. William Hardwick Ms. Kelly Pearson 4745 Poplar Avenue, Suite 201 Memphis, Tennessee 38117 [email protected] [email protected] Attorneys for Plaintiff /s/James L. Cresswell, Jr. Certifying Attorney

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