Ward v. Cisco Systems, Inc. et al

Filing 70

MOTION to Dismiss For Failure to State a Claim Upon Which Relief May Be Granted by Cisco Systems, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D-1, # 5 Exhibit D-2, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Proposed Order)(Babcock, Charles)

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Ward v. Cisco Systems, Inc. et al Doc. 70 Att. 6 Case 4:08-cv-04022-JLH Document 70-7 Filed 06/12/09 Page 1 of 2 EXHIBIT F Dockets.Justia.com Case 4:08-cv-04022-JLH Document 70-7 Filed 06/12/09 Page 2 of 2 JACKSON WALKER L.L.P. ATTORNEYS & COUNSELORS Charles L. Babcock (713) 752-4210 (Direct Dial) (713) 3084110 (Direct Fax) cbabcock@jw.com April 8, 2008 Nicholas H. Patton Patton, Tidwell & Schroeder, LLP 4605 Texas Boulevard Texarkana, Texas 75503 Re: John Ward, Jr. v. Cisco Systems, Inc. ("Cisco') and Rick Frenkel; Cause No. 084022 in the United States District Court, Western District of Arkansas, Texarkana Division; Dear Mr. Patton: As you know, Cisco has today filed its motion to dismiss or, in the alternative, to transfer venue. Subject to that motion, Cisco has filed an answer which calls your attention in paragraph 26 to Arkansas Code Section 16-63-505, which requires that you or your client file a verification contemporaneously with the complaint that provides that: (1) the party and his or her attorney of record, if any, have read the claim; (2) to the best of the knowledge, information, and belief formed after reasonable inquiry of the party or his or her attorney, the claim is well grounded in fact and is warranted by existing law or a good faith argument for the extension, modification, or reversal of existing law; (3) the act forming the basis for the claim is not a privileged communication; and (4) the claim is not asserted for any improper purpose such as to suppress the right of free speech or right to petition government of a person or entity, to harass, or to cause unnecessary delay or needless increase in the cost of litigation. Pleased be advised that if the required verification is not filed within ten days of this letter, Cisco will, subject to its motion to dismiss, request that the Court strike Ward's pleading pursuant to Section 16-65-506(a). Sincerely, CleA.At Charles L. Babcock 507047h0i McKinney Street, Suite 1900 www.jw.com Austin Dallas Houston, Texas 77010 Houston (713) 752-4200 San Angelo fax (713) 752-4221 Member of GLOBALAWsm Fort Worth San Antonio

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