Writing Briefs

prior false accusations would be admissible and that the allegations have no bearing on the issues. The motion should be denied.

II.     LEGAL STANDARD

        Motions to strike under Rule 12(f) are “generally disfavored, and should be granted only when there is a strong reason for doing so.” eShares, Inc. v. Talton, III, No. 1:22-cv-10987 (S.D.N.Y. Mar 27, 2025); Hafizov v. BDO USA, LLP, No. 1:22-cv-08853 (S.D.N.Y. Nov 14, 2022). Such motions are “infrequently granted” and “will not be granted unless the matter asserted clearly has no bearing on the issue in dispute.” Dubai Equine Hospital v. Equine Imaging, LLC, No. 1:18-cv-06925 (S.D.N.Y. Aug 14, 2019).

        The movant bears a heavy three-part burden. She “must demonstrate that no evidence in support of the allegation would be admissible, that the allegations have no bearing on the issues in the case, and that to permit the allegations to stand would result in prejudice to the movant.” eShares, Inc. v. Talton, III, No. 1:22-cv-10987 (S.D.N.Y. Mar 27, 2025); Hafizov v. BDO USA, LLP, No. 1:22-cv-08853 (S.D.N.Y. Nov 14, 2022). “Unless [Defendant] can demonstrate that no evidence in support of the [challenged] allegations would be admissible at trial,” the motion must be denied. Dubai Equine Hospital v. Equine Imaging, LLC, No. 1:18-cv-06925 (S.D.N.Y. Aug 14, 2019).

ARGUMENT

I. Paragraph 46 Is Material and Pertinent to Plaintiff’s Retaliation and Whistleblower Claims