Wow, reading the DL motions makes me wonder where the Plaintiff's lawyer got their degree. She didn't fill out the forms, and there's no way she could since she's basing her case off research nine months later, for different dates.
Legally speaking the motion to dismiss is a slam-dunk. I thought a lawyer would at least be smart enough to know the basics required for a case to go to court. When your own filings prove that you've not met the requirements you have problems. I could see DL asking for lawyer fees and that the court take action against the lawyer.