Free Renotice motion hearing - District Court of California - California

Case 3:08-cv-03073-JSW

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Filed 07/22/2008

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RICHARD T. WHITE #58622 MARK A. DELGADO #215618 FITZGERALD ABBOTT & BEARDSLEY LLP 1221 Broadway, 21st Floor Oakland, California 94612 Telephone: (510) 451-3300 Facsimile: (510) 451-1527 Email: [email protected] [email protected] Attorneys for Defendants SAUNDRA COSTICK (erroneously sued as SANDY COSTICK) and JOHN COSTICK UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO TEG STAFFING, INC., a California Corporation, dba PLATINUM LEGAL Plaintiff, Case No.: 08-cv-3073-JSW AMENDED NOTICE OF MOTION AND MOTION OF DEFENDANTS SAUNDRA COSTICK AND JOHN COSTICK TO DISMISS COMPLAINT BASED ON LACK OF PERSONAL JURISDICTION AND IMPROPER VENUE Date: Time: Dept.: Before: October 17, 2008 9:00 a.m. Courtroom 2, 17th Floor Honorable Jeffrey S. White

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TO PLAINTIFF TEG STAFFING, INC dba PLATINUM LEGAL AND ITS ATTORNEYS OF RECORD: PLEASE TAKE NOTICE THAT on October 17, 2008, at 9:00 a.m., or as soon thereafter as counsel may be heard in the courtroom of the Honorable Jeffrey S. White, Courtroom 2, 17th Floor, 450 Golden Gate Avenue, San Francisco, California, Defendants Saundra Costick (erroneously sued as Sandy Costick) and John Costick (collectively "Defendants") will bring before the Court their motion to dismiss for lack of personal jurisdiction in the forum state and for improper venue. The grounds for this motion are as follows: Defendants file this Motion under Rules 12 (b)(2) and 12(b)(3) of the Federal Rules of Civil Procedure to dismiss Plaintiff's suit for lack of 1 AMENDED NOTICE OF MOTION AND MOTION TO DISMISS CASE NO.: 08-CV-3073-JSW
7/22/08 (25540) #307436.1

Case 3:08-cv-03073-JSW

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Filed 07/22/2008

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personal jurisdiction over Defendants in the forum state and improper venue. This motion is based on the pleadings and papers on file in this action, this Notice of Motion, the accompanying Memorandum of Points and Authorities, the Declarations of Saundra Costick and John Costick, and whatever evidence and argument is presented at the hearing of this motion. Dated: July 22, 2008 FITZGERALD ABBOTT & BEARDSLEY LLP By /s/ Mark A. Delgado Mark A. Delgado Attorneys for Defendants Saundra Costick (erroneously sued as Sandy Costick) and John Costick

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2 AMENDED NOTICE OF MOTION AND MOTION TO DISMISS CASE NO.: 08-CV-3073-JSW
7/22/08 (25540) #307436.1