Transamerica Life Insurance Company v. Caramadre et al

Filing 62

MOTION to Dismiss and Request for Reconsideration WITH SUPPORTING MEMO by Edward Maggiacomo, Jr. Responses due by 10/21/2010 (Attachments: #1 Supporting Memorandum)(Traini, Anthony)

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Transamerica Life Insurance Company v. Caramadre et al Doc. 62 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 AND REQUEST FOR RECONSIDERATION OF DEFENDANT EDWARD L. MAGGIACOMO, JR. Pursuant to Fed.R.Civ.P. 8(a), 9, 11 and 12(b)(6), Defendant Edward L. Maggiacomo, Jr. hereby moves to dismiss plaintiff's Amended Complaint, and for reconsideration of his previous motion to dismiss to the extent that motion was denied, all for the reasons set forth in his memorandum in support hereof 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: October 4, 2010 Dockets.Justia.com CERTIFICATE OF SERVICE I hereby certify that on October 4, 2010, 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 Anthony M. Traini 2

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