A start would be to look at the "facts" given in the pacer documents and see if there is anything which might refute them.

The two links provided, for which I can only take credit for the second, were to assist you in arriving at a decision as to the merits or otherwise of the defense "facts".

I humbly apologize if you read my reply as being uncivil and trust that your day is going splendidly.

Be well