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57_2009!06!11_OPPOSITION to #23 Sankey Motion to Dismiss

57_2009!06!11_OPPOSITION to #23 Sankey Motion to Dismiss

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Published by Jack Ryan
Liberi v Taitz Entry # 57 Opposition to Sankey Motion to Dismiss
Liberi v Taitz Entry # 57 Opposition to Sankey Motion to Dismiss

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Published by: Jack Ryan on Jun 12, 2009
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05/11/2014

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 Z:\Liberi, et al, Response in Opposition to the Neil Sankey, et al Motion to Dismiss…1
UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF PENNSYLVANIA
LISA LIBERI, et al,Plaintiffs,vs.ORLY TAITZ, et al,Defendants.::::::::::Case No.: 09-cv-01898-ECR 
ORDER THIS CAUSE
came before the United States District Court Judge, Honorable EduardoC. Robreno on Defendant’s Neil Sankey and Sankey Investigations a/k/a Sankey Investigations,Inc. Motion to Dismiss or in the alternative the Action be transferred to the Western District of Texas pursuant to 28 U.S.C. §1406(a). Having reviewed the Motion and Plaintiffs’ Response inOpposition to said Motion and for good cause shown, it is hereby
ORDERED
that Defendant’s Neil Sankey and Sankey Investigations a/k/a SankeyInvestigations, Inc. Motion to Dismiss or in the alternative the Action be transferred to theWestern District of Texas pursuant to 28 U.S.C. §1406(a) is
DENIED
.
IT IS SO ORDERED
Dated: June _____, 2009 _____________________________ Hon. Eduardo C. RobrenoUnited States District Court JudgeFor the Eastern District of PA
 
 Z:\Liberi, et al, Response in Opposition to the Neil Sankey, et al Motion to Dismiss…2
Law Offices of:
Philip J. Berg, Esquire
555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531Identification No. 09867(610) 825-3134
 Attorney for Plaintiffs
UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF PENNSYLVANIA
LISA LIBERI, et al,Plaintiffs,vs.ORLY TAITZ, et al,Defendants.::::::::::Case No.: 09-cv-01898-ECR 
PLAINTIFFS’ RESPONSE IN OPPOSITION TO DEFENDANT’S,NEIL SANKEY and SANKEY INVESTIGATIONS a/k/a SANKEY INVESTIGATIONS,INC. MOTION TO DISMISS or IN THE ALTERNATIVE TRANSFER THE ACTIONTO THE WESTERN DISTRICT OF TEXAS PURSUANT TO 28 U.S.C. §1406(a)
Plaintiffs’ Lisa Liberi [hereinafter “Liberi”]; Philip J. Berg, Esquire [hereinafter “Berg”],the Law Offices of Philip J. Berg; Evelyn Adams a/k/a Momma E [hereinafter “Adams”]; LisaOstella [hereinafter “Ostella”]; and Go Excel Global by and through their undersigned counsel,Philip J. Berg, Esquire files the within Response in Opposition to Defendant’s, Neil Sankey[hereinafter “Sankey”] and Sankey Investigations a/k/a Sankey Investigations, Inc. [hereinafter “Sankey Investigations”] Motion to Dismiss or in the alternative to transfer the within action tothe Western District of Texas pursuant to 28 U.S.C. §1406(a) on the following grounds:Sankey and Sankey Investigations Motion is an improper Motion. Sankey andSankey Investigations fail to support their Motion to Dismiss or in the alternative to
 
 Z:\Liberi, et al, Response in Opposition to the Neil Sankey, et al Motion to Dismiss…3
transfer the case to the Western District of Texas with any type of Statute or supportingLaw. Orly Taitz, Esq. by her own admission prepared Sankey and Sankey InvestigationsAnswer and Motion to Dismiss. Despite this, Plaintiffs’ will assume Sankey and SankeyInvestigations are filing said Motion pursuant to Federal Rules of Civil Procedure, Rule12;This Court has subject matter Jurisdiction pursuant to Diversity Jurisdiction pursuant to 28 U.S.C. §1332, as outlined in Plaintiffs’ Complaint;Sankey and Sankey Investigations Motion fail to address any claims in Plaintiffs’Complaint and fail to give any type of legally sufficient defense;Sankey and Sankey Investigations subjected themselves to the Eastern District of Pennsylvania when they acted to harm the Plaintiffs’ at their residence and harm thePlaintiffs’ businesses, some of which are located in the Eastern District of Pennsylvania;Sankey and Sankey Investigations are NOT within the Western District of Texas jurisdiction;Sankey and Sankey Investigations have failed to state any type of hardships; hasfailed to list any witnesses in the Western District of Texas; and has failed to cite anytype of convenience issues pertaining to witnesses;Sankey and Sankey Investigations are
NOT
within the Western District of Texas jurisdiction. Sankey and Sankey Investigations are willing to travel to the WesternJurisdiction, thus this forum is
not
inconvenient.Pursuant to Diversified Jurisdiction 28 U.S.C. §1332(a); and Venue pursuant to 28 U.S.C. §1391(a)(3), because the Defendants all reside in different states

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