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Scott Stuart Shogreen
7850 E Camelback Rd. Unit 211
Scottsdale, AZ 85251
Phone: 206.339.5651
UNITED STATES DISTRICT COURT
FOR THE
NORTHERN DISTRICT OF CALIFORNIA
|
THE REPUBLIC OF NICARAGUA, Plaintiff, vs. THE LOPEZ-GOYNE FAMILY TRUST, GOYNE Defendant(s) |
Case No.: 3:24-CV-03104-MMC IN PRO PER MOTION TO DISMISS FOR LACK Honorable Judge Maxine M. Chesney |
IN PRO PER MOTION TO DISMISS FOR LACK OF JURISDICTION BY SCOTT STUART SHOGREEN
MOTION TO DISMISS FOR LACK OF JURISDICTION
1. Respondent Scott Stuart Shogreen, in pro per. moves to dismiss Nicaragua's Petition under Federal Rule of Civil Procedure 12(b)(2) for lack of personal jurisdiction based on this Brief and Declaration and rather than hold an evidentiary hearing this motion is based on the fact Petitioner cannot make a prima facie showing of personal jurisdiction and jurisdiction over respondent Scott Stuart Shogreen is defeated by respondent's within declaration.
Declaration of Respondent:
2. Declaration of Mr. Scott Stuart Shogreen:
DECLARATION.
I, Scott Stuart Shogreen hereby declare that the information given in this declaration and in the within IN PRO PER MOTION TO DISMISS FOR LACK OF JURISDICTION BY SCOTT STUART SHOGREEN
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Motion is true to the best of my knowledge and belief and nothing has been concealed therein. I understand that if the information given by me is proved false/not true, I will have to face the punishment as per the law.
a. The allegation in the Petition by Nicaragua in paragraph p., line 20 on page 5 that "On information and belief, Mr. Shogreen maintains contacts in this District" is not true. I have no contacts with California. I have no incorporations in California. I am not physically present there. I have no domicile in California. I have not consented to jurisdiction in California.
b. I have no minimum contacts with California and the maintenance of this Petition by Nicaragua against me would offend traditional notions of fair play and substantial justice within the meaning of International Shoe Co. v. Washington, 326 U.S. 310, 1946.
Signed on 6/21/2024 in Scottsdale, AZ by Scott Stuart Shogreen on information and belief under penalty of perjury.
Signature
(Scott Stuart Shogreen).
WHEREFORE, said respondent Scott Stuart Shogreen moves to dismiss the Petition filed by Nicaragua for lack of jurisdiction.
Dated 6/21/2024
Signature
Scott Stuart Shogreen, in pro per.
7850 E Camelback Rd. Unit 211
Scottsdale, AZ 85251