Netquote Inc. v. Byrd

Filing 8

MOTION to Dismiss for Lack of Personal Jurisdiction and for Failure to State a Claim for Fraud Upon Which Relief can be Granted by Defendant Brandon Byrd. (Attachments: # 1 Memorandum in Support of Defendant's Motion to Dismiss# 2 Exhibit A# 3 Exhibit B# 4 Exhibit C)(Eichenbaum, Rachel)

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Netquote Inc. v. Byrd Doc. 8 Case 1:07-cv-00630-DME-MEH Document 8 Filed 04/04/2007 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 07-cv-00630-DME-MEH NETQUOTE, INC., a Colorado corporation Plaintiff, v. BRANDON BYRD, Defendant. DEFENDANT'S MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION AND FOR FAILURE TO STATE A CLAIM FOR FRAUD UPON WHICH RELIEF CAN BE GRANTED COMES NOW, Defendant in the above-styled action and herein moves for dismissal based of the plaintiff's complaint upon a lack of personal jurisdiction, or in the alternative to dismiss the Plaintiff's claim for Fraud for Failure to State a Claim Upon Which Relief can be Granted. In support of this motion, defendant relies upon all pleadings of record, his affidavit, and the memorandum of law in support hereof. Wherefore, Defendant prays that this motion be granted and for such and further relief deemed necessary and just by this Court. Respectfully submitted, s/Rachel L. Eichenbaum Teresa L. Ashmore Rachel L. Eichenbaum HOLME ROBERTS & OWEN LLP 1700 Lincoln Street, Suite 4100 Denver, CO 80203 Telephone: (303) 861-7000 Facsimile: (303) 866-0200 #1238350 v1 Dockets.Justia.com Case 1:07-cv-00630-DME-MEH Document 8 Filed 04/04/2007 Page 2 of 2 and Ryan L. Isenberg, Esq. Isenberg & Hewitt, P.C. 7000 Peachtree Dunwoody Road Building 15, Suite 100 Atlanta, Georgia 30328 770-351-4400 (Voice) 678-990-7737 (Fax) www.isenberg-hewitt.com CERTIFICATE OF SERVICE The undersigned hereby certifies that on this 4th day of April, 2007, I electronically filed the a true and correct copy of the foregoing DEFENDANT'S MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION AND FOR FAILURE TO STATE A CLAIM FOR FRAUD UPON WHICH RELIEF CAN BE GRANTED with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following email addresses: Christopher P. Beall FAEGRE & BENSON LLP 3200 Wells Fargo Center 1700 Lincoln Street Denver, CO 80203 Email: CBeall@faegre.com s/ Rachel L. Eichenbaum­ Signature on File #1238350 v1

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