Netquote Inc. v. Byrd
Netquote Inc. v. Byrd
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
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
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)
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?