Upon information and belief, Jessica Bennett is a resident of California and is theco-founder and operator of Grub Street Reads.11.
Upon information and belief, Leslie Ramey is a resident of California and is theco-founder and operator of Grub Street Reads.
JURISDICTION AND VENUE
This Court has subject matter jurisdiction over these claims pursuant to 28 U.S.C.§§ 1331, 1338(a) and (b), and this Court’s supplemental jurisdiction under 28 U.S.C. § 1367.13.
This Court has personal jurisdiction over defendants because, upon informationand belief, defendants regularly solicit and conduct business in Massachusetts, have contracted tosupply services in Massachusetts, and have caused harm in Massachusetts.14.
Upon information and belief, venue is proper in this Court pursuant to 28 U.S.C.§ 1391(b) and (c) because this is the judicial district where (i) a substantial part of the events oromissions giving rise to the claim occurred; and (ii) where Defendants are subject to personal jurisdiction.
Grub Street’s Writing and Publishing Services
Grub Street is a nationally recognized, non-profit corporation that educates andsupports writers by offering workshops, seminars, conferences, instruction, and manuscriptconsulting. Founded in 1997, Grub Street is the second-largest independent center for creativewriting in the United States, and attracts writers from around the country through its manyservices.16.
Grub Street was founded by Eve Bridburg, a renowned literary agent who hasedited and sold numerous titles, including several
New York Times
bestsellers. Grub Street’s
Case 1:12-cv-11860-WGY Document 1 Filed 10/04/12 Page 3 of 25