9 Motion To Dismiss
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- Words: 289
- Pages: 2
Case: 8:09-cv-00131-JFB-FG3
Document #: 9
Date Filed: 04/30/2009
Page 1 of 2
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA SHOEMONEY MEDIA GROUP, INC., Plaintiff, vs. KEYEN FARRELL and JOHN J. FARRELL, Defendants.
) ) ) ) ) ) ) ) )
CASE NO. 8:09-cv-00131
DEFENDANTS’ MOTION TO DISMISS PURSUANT TO FED. R. CIV. P. 12(b)(2) COME NOW the Defendants, Keyen Farrell and John J. Farrell (collectively the “Farrells”), pursuant to Rule 12(b)(2) of the Federal Rules of Civil Procedure and request an Order of the Court dismissing the Complaint of Plaintiff Shoemoney Media Group, Inc. In support of their Motion, the Farrells submit the accompanying Memorandum Brief and Index of Evidence. WHEREFORE, the Farrells respectfully request that their Motion to Dismiss for lack of personal jurisdiction pursuant to Fed. Rule Civ. P. 12(b)(2) be granted and that the Complaint be dismissed, along with all other relief this Court deems just. DATED this 30th day of April, 2009. Respectfully submitted, KEYEN FARRELL and JOHN J. FARRELL, Defendants
By:/s/ Michaela A. Smith J. Scott Paul, #16635 Michaela A. Smith, #22737 McGrath, North, Mullin & Kratz, PC LLO First National Bank Tower, Suite 3700 1601 Dodge Street
Case: 8:09-cv-00131-JFB-FG3
Document #: 9
Date Filed: 04/30/2009
Page 2 of 2
Omaha, NE 68102 (402)341-3070 (402)341-0216 (fax) [email protected] [email protected] ATTORNEYS FOR THE DEFENDANTS
CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 30th day of April, 2008, I electronically filed the above foregoing document with the Clerk of the Court using the CM/ECF system which sent notification of such filing to the following: Troy F. Meyerson Patrick S. Cooper Fraser Stryker PC LLO 500 Energy Plaza 409 South 17th Street Omaha, NE 68102-2663 (402)341-6000
/s/ Michaela A. Smith
2
Document #: 9
Date Filed: 04/30/2009
Page 1 of 2
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA SHOEMONEY MEDIA GROUP, INC., Plaintiff, vs. KEYEN FARRELL and JOHN J. FARRELL, Defendants.
) ) ) ) ) ) ) ) )
CASE NO. 8:09-cv-00131
DEFENDANTS’ MOTION TO DISMISS PURSUANT TO FED. R. CIV. P. 12(b)(2) COME NOW the Defendants, Keyen Farrell and John J. Farrell (collectively the “Farrells”), pursuant to Rule 12(b)(2) of the Federal Rules of Civil Procedure and request an Order of the Court dismissing the Complaint of Plaintiff Shoemoney Media Group, Inc. In support of their Motion, the Farrells submit the accompanying Memorandum Brief and Index of Evidence. WHEREFORE, the Farrells respectfully request that their Motion to Dismiss for lack of personal jurisdiction pursuant to Fed. Rule Civ. P. 12(b)(2) be granted and that the Complaint be dismissed, along with all other relief this Court deems just. DATED this 30th day of April, 2009. Respectfully submitted, KEYEN FARRELL and JOHN J. FARRELL, Defendants
By:/s/ Michaela A. Smith J. Scott Paul, #16635 Michaela A. Smith, #22737 McGrath, North, Mullin & Kratz, PC LLO First National Bank Tower, Suite 3700 1601 Dodge Street
Case: 8:09-cv-00131-JFB-FG3
Document #: 9
Date Filed: 04/30/2009
Page 2 of 2
Omaha, NE 68102 (402)341-3070 (402)341-0216 (fax) [email protected] [email protected] ATTORNEYS FOR THE DEFENDANTS
CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 30th day of April, 2008, I electronically filed the above foregoing document with the Clerk of the Court using the CM/ECF system which sent notification of such filing to the following: Troy F. Meyerson Patrick S. Cooper Fraser Stryker PC LLO 500 Energy Plaza 409 South 17th Street Omaha, NE 68102-2663 (402)341-6000
/s/ Michaela A. Smith
2
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