CoStar Realty Information, Inc. et al v. Klein & Heuchan, Inc. et al

Filing 11

MOTION to Dismiss for Lack of Jurisdiction, MOTION to Transfer Case by Scott Bell Responses due by 8/28/2008 (Attachments: # 1 Affidavit Affidavit of Scott Bell (Exhibit A), # 2 Exhibit CoStar Terms of Use (Exhibit B), # 3 Text of Proposed Order, # 4 Memorandum of Law in Support of Motion)(Rubin, Julie)

CoStar Realty Information, Inc. et al v. Klein & Heuchan, Inc. et al

Doc. 11

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND Southern Division COSTAR REALITY INFORMATION, INC. et al., Plaintiffs v. KLEIN & HEUCHAN, INC., et al., Defendants ___________________________________/ DEFENDANT BELL'S MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION OR, ALTERNATIVELY, TO TRANSFER VENUE Defendant Scott Bell, by and through his undersigned counsel and pursuant to the Federal Rules of Civil Procedure 12(b)(2) and 12(b)(3), as well as 28 U.S.C. §1404(a), hereby respectfully requests that this case be dismissed against him for lack of personal jurisdiction or, alternatively, that this case be transferred to the United States District Court for the Middle District of Florida, Tampa Division. In support of these alternative motions, Bell submits Civil No.: 08-CV-01575-AW

herewith on this same date for the Court's consideration a Memorandum of Law, the Affidavit of Defendant Scott Bell (Exhibit A), and Plaintiffs' Terms of Use (Exhibit B). WHEREFORE, on the bases set forth in the Memorandum of Law in support of the instant Motion, Defendant Scott Bell respectfully requests that the Court dismiss this case against him for lack of personal jurisdiction or, alternatively, that the Court transfer this case out of this venue and to the United States District Court for the Middle District of Florida, Tampa Division.

Dockets.Justia.com

Respectfully submitted, /S/ ___________________________________ James B. Astrachan, Federal Bar #03566 Julie R. Rubin, Federal Bar #25632 ASTRACHAN GUNST THOMAS, P.C. 217 East Redwood Street Suite 2100 Baltimore, Maryland 21202 410.783.3550 telephone [phone] facsimile Attorneys for Defendant Scott Bell
21063.001.74485

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