Response | Filed: September 16, 2026
| Entered: September 16, 2026
Bonhomme et al v. Denny's, Inc. et al
Civil Rights: Accomodations | Pennsylvania Middle
Brief in Opposition (Do not use for Summary Judgment Motions)
BRIEF IN OPPOSITION re 56 MOTION to Dismiss Second Amended Complaint, 54 MOTION to Dismiss for Failure to State a Claim filed by Daniella Bonhomme, Quantavia Grant, Aminique Kirnon, Tatiana Poulard, Selina Sacasa. (Attachments: # 1 Certificate of Service, # 2 Declaration Word Count)(Platt, Kyle)
Motion | Filed: September 11, 2026
| Entered: September 11, 2026
Gibbs v. Williams et al
Civil Rights: Other | Texas Southern
Amended Motion
First AMENDED MOTION( Motion Docket Date 10/2/2026.), Agreed MOTION to Amend by Basil Clark Gibbs, filed. Motions referred to Richard W Bennett. (Attachments: # 1 Complaint Memorandum Supporting Motion for Leave to Amend Complaint Page, # 2 Affidavit Exhibits In Support of Motion for Leave to Amend Complaint, # 3 Exhibit Exhibit 1-A Proposed Second Amended Complaint (without Tracked Changes), # 4 Exhibit Exhibit 1-B Proposed Second Amended Complaint (with Tracked Changes), # 5 Exhibit Exhibit 2 United Nations Universal Declaration of Human Rights and international human rights law, # 6 Exhibit Exhibit 3 United Nations General Assembly Resolution 61/295 Universal Declaration on the Rights of Indigenous Peoples, # 7 Exhibit Exhibit 4 Defendant Denny's Entities' Human Rights Policy, adopted May 2024, # 8 Exhibit Exhibit 5 United Nations Guiding Principles on Business and Human Rights., # 9 Exhibit Exhibit 6 Federal Judicial Center International Litigation Guide International Human Rights Litigation: A Guide for Judges David Nersessian, J.D., Ph.D. Assistant Professor, Accounting and Law Division, Babson College, # 10 Exhibit Exhibit 7 Excerpt of the ENCYCLICAL LETTER MAGNIFICA HUMANITAS OF THE HOLY FATHER LEO XIV, # 11 Exhibit Exhibit 8 United Nations A/80/L.48, General Assembly 17 March 2026 Declaration of the Trafficking of Enslaved Africans and Racialized Chattel Enslavement of Africans as the Gravest Crime against Humanity, # 12 Exhibit Exhibit 9 Title 1 of the United States Code, section 112, # 13 Exhibit Exhibit 10 Texas Constitution, Article 1, Bill of Rights, section 3, # 14 Exhibit Exhibit 11 No. I, October 7, 1763, By The King A Proclamation, King George III., # 15 Exhibit Exhibit 12 The Companies House - GOV.UK registration of THE UNITED STATES OF AMERICA Registration Number: OE015146 Notified 3 July 1776 The Keeper, who is the Chief Executive Officer of the National Archives, manager of the Crown database rights under Letters Patents and makes Crown copyright material available under the Open Government Licence., # 16 Proposed Order [Proposed] Order Granting Motion for Leave to File Second Amended Complaint, # 17 Certificate of Service for Motion for Leave to Amend Complaint Page) (Gibbs, Basil)