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CDCA - Judd - ECF 21 - 2012-10-09 - (GA) Kemp Notice of Motion and Motion to Dismiss

CDCA - Judd - ECF 21 - 2012-10-09 - (GA) Kemp Notice of Motion and Motion to Dismiss

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Published by Jack Ryan

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Categories:Types, Research, Law
Published by: Jack Ryan on Oct 09, 2012
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10/09/2012

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AMALA
D.
 
H
ARRIS
 Attorney General of California
ICHARD
J.
 
OJO
 Supervising Deputy Attorney GeneralState Bar No. 100157300 South Spring Street, Suite 1702Los Angeles, CA 90013Telephone: (213) 897-2134Fax: (213) 897-2810E-mail: Richard.Rojo@doj.ca.gov
 Attorneys for Defendant Brian Kemp
 IN THE UNITED STATES DISTRICT COURTFOR THE CENTRAL DISTRICT OF CALIFORNIASOUTHERN DIVISION
KEITH JUDD, et al.
Plaintiffs,
v.BARAK OBAMA, et al.
Defendants.Case No. SACV 12-CV-01507 DOC
NOTICE OF MOTION ANDMOTION TO DISMISS GEORGIASECRETARY OF STATE BRIANKEMP
Date: November 12, 2012Time: 8:30 a.m.Courtroom: 9DJudge: The Honorable C. DavidO. Carter Pursuant to Fed. R. Civ. P. 12(b)(2), Brian Kemp (“Secretary Kemp”),Secretary of State of the State of Georgia, by and through counsel, gives notice of and files this Motion to Dismiss of Georgia Secretary of State Brian Kemp based onlack of personal jurisdiction. As shown in the accompanying Memorandum of Lawin Support of Motion to Dismiss of Georgia Secretary of State Brian Kemp,incorporated by reference herein, Secretary Kemp does not have minimum contactswith the State of California, and, accordingly, this lawsuit must be dismissed as
Case 8:12-cv-01507-DOC-AN Document 21 Filed 10/09/12 Page 1 of 3 Page ID #:151
 
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against Secretary Kemp for lack of personal jurisdiction.This motion is made following the conference of counsel, via telephone, pursuant to L.R. 7-3 which took place on October 5, 2012. After a discussion ingood faith, no resolution was agreed upon.Further, while Secretary Kemp has requested the hearing date of November 12, 2012, pursuant to L.R. 7-4, he nonetheless submits that this Court is able toadjudge this motion on the briefs without an evidentiary hearing. Further, SecretaryKemp requests a waiver of oral argument on this motion pursuant to L.R. 7-15.Respectfully submitted this 9
th
day of October, 2012 by:/s/ Richard RojoRichard RojoCalifornia Bar No. 250277Deputy Attorney General California Department of JusticeCounsel for Defendant Brian Kemp
 
Case 8:12-cv-01507-DOC-AN Document 21 Filed 10/09/12 Page 2 of 3 Page ID #:152

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