American Waste Management and Recycling, LLC. v. CEMEX Puerto Rico, Inc. et al

Filing 51

]SURREPLY to Reply to Opposition to 17 Ecoterra's Motion to Dismiss/Lack of Jurisdiction filed by American Waste Management and Recycling, LLC. (Attachments: # 1 Exhibit 1- State Department Authorization)(Esteves, Ada) Modified on 10/3/2007 creating link (np, ).

Download PDF
American Waste Management and Recycling, LLC. v. CEMEX Puerto Rico, Inc. et al Doc. 51 Case 3:07-cv-01658-JAF Document 51 Filed 10/02/2007 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO AMERICAN WASTE MANAGEMENT AND RECYCLING, LLC. Plaintiff, v. CIVIL NO.: 07- 1658 (JAF) BREACH OF CONTRACT; COLLECTION OF MONIES; and DAMAGES. CE MEX PUERTO RICO; CANOPY E C O T E R R A , X Y Z I N S U R A N C E JURY TRIAL DEMANDED COMPANIES. Defendants. AWMR'S SUR-REPLY TO THE HONORABLE COURT: NOW APPEARS Plaintiff AMERICAN WASTE MANAGEMENT AND RECYCLING, LLC, and through the undersigned attorneys, respectfully STATES, ALLEGES and REQUESTS as follows: On September 25, 2007, co-Defendant Ecoterra filed a reply to Plaintiff's Opposition to their Motion to Dismiss (docket No. 39), alleging that the document filed by AWMR in its opposition was not an authorization to so business in Puerto Rico, even though the title explicitly said so. In any event, as Exhibit 1 to this Motion, AWMR is attaching the Certificate by the Puerto Rico Department of State authorizing it to do business in Puerto Rico. Defendant's Motion to Dismiss is therefore moot and should be denied. Dockets.Justia.com Case 3:07-cv-01658-JAF Document 51 Filed 10/02/2007 Page 2 of 2 WHEREFORE, Plaintiffs respectfully request that the Honorable Court DENY coDefendant Ecoterra's Motion to Dismiss, and that it issue any further relief it deem just and proper under the law. RESPECTFULLY SUBMITTED. In San Juan, Puerto Rico, this 25th day of September, 2007. INDIANO & WILLIAMS, P.S.C. 207 del Parque Street Third Floor San Juan, Puerto Rico 00912 Tel.: (787) 641-4545 / FAX: (787) 641-4544 jeffrey.williams@indianowilliams.com sofia.esteves@indianowilliams.com By: s/ Jeffrey M. Williams JEFFREY M. WILLIAMS U.S.D.C.P.R. Bar No. 202414 By: s/ Ada Sofia Esteves ADA SOFIA ESTEVES U.S.D.C.P.R. Bar No. 216910 Page 2 of 2

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?