JONES DAY v. SCRUSHY

Filing 2

MOTION to Transfer for Lack of Jurisdiction by RICHARD M. SCRUSHY. (Glaser, Christopher) Modified on 6/16/2006 (lc, ).

JONES DAY v. SCRUSHY

Doc. 2

Case 1:06-cv-00466-JR

Document 2

Filed 05/08/2006

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IN THE UNITED STATES DISTRICT COURT District of Columbia JONES DAY, Plaintiff, v. RICHARD M. SCRUSHY, Defendant. RICHARD M. SCRUSHY'S MOTION TO TRANSFER FOR LACK OF PERSONAL JURISDICTION AND FOR LACK OF PROPER VENUE Defendant Richard M. Scrushy, pursuant to Fed. R. Civ. P. 12(b)(2) and (3) and 28 U.S.C. §§ 1391, 1404 and 1406, through his undersigned counsel, moves to transfer this case to the United States District Court for the Northern District of Alabama because this Court lacks personal jurisdiction and venue is not proper in this Court. In support hereof, this Court is referred to the accompanying Memorandum of Points and Authorities and Declaration of Richard M. Scrushy. WHEREFORE, Richard M. Scrushy respectfully requests that this Court grant his Motion to Transfer for Lack of Personal Jurisdiction and for Lack of Proper Venue and (i) transfer this action to the United States District Court for the Northern District of Alabama and (ii) grant any further relief deemed just and proper by this Court. Case No. 1:06CV00466 Judge: James Robertson

-1Dockets.Justia.com

Case 1:06-cv-00466-JR

Document 2

Filed 05/08/2006

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Respectfully submitted, BEAN, KINNEY & KORMAN, P.C. By: /s/ James R. Schroll James R. Schroll, Esq., D.C. Bar No. 256099 Christopher A. Glaser, Esq., D.C. Bar No. 463583 Alan Bowden, Esq., D.C. Bar No. 465700 2000 North 14th Street, Suite 100 Arlington, Virginia 22201 [phone]/[phone] (Fax) Counsel for Defendant Richard M. Scrushy

CERTIFICATE OF SERVICE I hereby certify that on May 8, 2006, a copy of the foregoing and annexed pleading was served by electronic case filing to:

Mark W. Foster, Esq. Thomas B. Mason, Esq. Lisa L. Barclay, Esq. Zuckerman Spaeder, LLP 1800 M Street, N.W. Suite 1000 Washington, DC 20036

/s/ James R. Schroll

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