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Act 33: I Challenge the Court's Jurisdiction

When Paul Levy (the Public Citizen attorney who's been helping me) first looked at my case, one of his first reactions was that I should have moved to have the case dismissed for lack of jurisdiction. (I didn't tell him that I didn't understand the difference between jurisdiction and venue, and that I had moved for a change of venue.) And since I guess he didn't have anything else to do over the weekend, he wrote a rough draft of a "lack of jurisdiction" motion for me. This is the first submission I've made in this case that I didn't create entirely by myself – and although part of me would have enjoyed continuing to go it alone, another part of me recognizes that I'll enjoy winning the case more than I'll enjoy losing it, and that Paul's help greatly enhances the odds of my success. I should mention that Paul Levy isn't the only lawyer who's helped me during this ordeal. In fact, my motion to change venue was suggested by an attorney who learned about me through this website, and other lawyers (and law students, and paralegals) have made (and continue to make) very helpful suggestions. I am incredibly grateful for their advice, as I am for the support of all of you who have contacted me with words of encouragement. Anyway, here's the text of "my" jurisdiction motion. UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION THE TAUBMAN COMPANY LIMITED PARTNERSHIP,   Plaintiff,     Civil Action No. 01-72987 v.   Honorable Lawrence P. Zatkoff WEBFEATS and HENRY MISHKOFF, Magistrate Judge Komives   Defendants.   MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION Pursuant to Rule 12(b)(2) and 12(d) of the Federal Rules of Civil Procedure, and based on the accompanying affidavit of Henry Mishkoff and memorandum of law, defendants move the Court to dismiss this action for lack of personal jurisdiction. In the alternative, defendants move the Court to permit them to amend their motion to dismiss for lack of venue to include the additional ground that the Court lacks personal jurisdiction. Defendants attempted to obtain concurrence in this motion; however, plaintiff's attorney did not respond to defendants' voicemail message. Respectfully submitted, Henry Mishkoff WebFeats 2661 Midway Road, #224-225 Carrollton, TX 75006 (972)931-5421 Pro se November 12, 2001

©2001 Hank Mishkoff
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