Overview of UL's Reply to Ryan's Response

UL’s Reply is, again, fairly self-explanatory and well pleaded.  It says, essentially, that Ryan's pleadings are still insufficient and that they still do not make out any legally comprehensible or viable claims.

It starts thus: 

"After filing an incredibly vague complaint and forcing UL to spend significant time guessing     at what causes of action are alleged, Plaintiff fails to clarify his complaint (“Complaint”) in his     response to UL’s motion to dismiss (“Response” or “Pl. Resp.”).  Worse yet, Plaintiff,                        represented by three different law firms, argues that he is not required in his Complaint to             identify a legal theory and, in fact, implies that he may be claiming a theory of which he                 himself is not yet aware.  The crux of his argument is that this Court should indulge his nearly     impossible-to-decipher Complaint because it might, at some point in the unforeseeable future,     give rise to a still unidentified claim."

Some other gems:

"While it may be true that federal courts are particularly liberal in their review of pro se                 complaints, [citation removed], Plaintiff here is not a pro se litigant. In fact, he is represented     by no less than three well respected attorneys from three different Indianapolis law firms.
    Despite his high level of legal representation, however, Plaintiff’s Response to UL’s motion to         dismiss is replete with factual inconsistencies, see, e.g., Pl. Resp. at 4 (decrying UL’s use of the     term “conspiracy theories” but stating that “of course the fact that there was a ‘conspiracy’ of     some  kind . . . has been accepted by all”), and legal inaccuracies. See, e.g., Parts I, III, VII             below."

"The bottom line, however, is that even with Plaintiff’s “additional detail,” Pl. Resp. at 20, the     claims Plaintiff is attempting to assert fail as a matter of law.  Notwithstanding his extensive         quotation of various provisions of  federal and state constitutions and laws, block quotation         and string citation of legal precedent, and repetition of large portions of the Complaint,                  Plaintiff has done nothing to make his claims any clearer or more legally cognizable.                         Accordingly, and for the many reasons discussed below, all of Plaintiff’s claims should be             dismissed with prejudice."

So far, I concur entirely with UL's take on this matter.  The Ryan complaint is practically incoherent as currently constituted, and it is very difficult to find a viable cause of action pleaded therein.