Transamerica Life Insurance Company v. Caramadre et al

Filing 33

MOTION to Dismiss WITH SUPPORTING MEMO by Edward Maggiacomo, Jr. Responses due by 12/21/2009 (Attachments: #1 Supporting Memorandum, #2 Exhibit 1-Annuity Contract, #3 Exhibit 2-Annuity Application)(Traini, Anthony)

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UNITED STATES DISTRICT COURT DISTRICT OF RHODE ISLAND ) ) ) ) ) ) ) ) ) ) ) ) ) ) TRANSAMERICA LIFE INSURANCE COMPANY, Plaintiff vs. JOSEPH CARAMADRE, RAYMOUR RADHAKRISHNAN, ESTATE PLANNING RESOURCES, INC., ESTELLA RODRIGUES, EDWARD MAGGIACOMO, JR., LIFEMARK SECURITIES CORP., and PATRICK GARVEY, Defendants. C.A. No. 09-471-S MOTION TO DISMISS OF DEFENDANT EDWARD L. MAGGIACOMO, JR. Pursuant to Fed. R. Civ. P. 12(b)(6), Defendant Edward L. Maggiacomo, Jr. ("Mr. Maggiacomo") hereby moves to dismiss plaintiff's Amended Complaint, for the reasons set forth in his memorandum in support thereof filed simultaneously herewith. EDWARD L. MAGGIACOMO, JR. By his Attorney, /s/ Anthony M. Traini Anthony M. Traini (#4793) Anthony M. Traini, P.C. 56 Pine Street, Suite 200 Providence, RI 02903 Tel. (401) 621-4700 Fax. (401) 621-5888 amt@trainilaw.com Dated: December 4, 2009 CERTIFICATE OF SERVICE I hereby certify that on December 4, 2009, a copy of the within document was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the court's electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System. /s/ Anthony M. Traini 2

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