Southern California Institute of Law v. TCS Education System et al

Filing 14

NOTICE OF MOTION AND MOTION to Dismiss Case filed by Defendant TCS Education System. Motion set for hearing on 2/28/2011 at 01:30 PM before Judge Philip S. Gutierrez. (Attachments: # 1 Proposed Order Granting TCS Education System's Motion to Dismiss)(Casamassima, Christopher)

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Southern California Institute of Law v. TCS Education System et al Doc. 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Christopher T. Casamassima (SBN 211280) chris.casamassi ma@kirkland.co m Tanya Jackson (SBN 267975) tanya.jackson@kirkland.com KIRKLAND & ELLIS LLP 333 South Hope Street Los Angeles, California 90071 Telephone: (213) 680-8400 Facsimile: (213) 680-8500 Attorneys for TCS EDUCATION SYSTEM UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA SOUTHERN CALIFORNIA INSTITUTE OF LAW, a California corporation, Plaintiffs, vs. TCS EDUCATION SYSTEM, an Illinois corporation; DAVID J. FIGULI, an individual; GLOBAL EQUITIES, LTD. d/b/a HIGHER EDUCATION GROUP, a Colorado limited liability company, Defendants. CASE NO. CV10-8026 PSG NOTICE OF MOTION AND MOTION TO DISMISS Complaint Filed: October 25, 2010 Assigned: Date: Time: Ctrm.: Hon. Philip S. Gutierrez February 28, 2011 1:30 p.m. 880 Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PLEASE TAKE NOTICE that, on February 28, 2011 at 1:30 p.m. in Courtroom 880 of the United States District Court for the Central District of California, at the Spring Street Courthouse, located at 312 N. Spring Street, Los Angeles, California 90012, Defendant TCS Education System ("TCS") will and hereby does move the Court for an order dismissing this case in its entirety. Defendant's Motion is and will be based on: this Notice of Motion; the Memorandum of Points and Authorities in support of the Motion; any Reply; and, any oral argument that may be presented at the hearing on this matter. This motion is made following the conference of counsel pursuant to Local Rule 7-3 which took place on December 13, 2010. The parties were unable to reach agreement on the issues raised in the instant motion, and counsel for plaintiff agreed that TCS had satisfied its meet and confer obligations. DATED: December 23, 2010 Respectfully submitted, KIRKLAND & ELLIS LLP /s/ Christopher T. Casamassima Christopher T. Casamassima (SBN 211280) chris.casamassima@kirkland.com Tanya Jackson (SBN 267975) tanya.jackson@kirkland.com Attorneys for TCS EDUCATION SYSTEM 1

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