David L. Arneson, Plaintiff Vs. Gary Gygax, Tactical Study Rules, A
UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA FOURTH DIVISION . ,. DAVID L. ARNESON, Plaintiff vs. Civil Action No. 4-79-109 MEMORANDUM GARY GYGAX, TACTICAL STUDY IN SUPPORT OF DEFENDANTS' RULES, a partnership consisting MOTION TO QUASH SERVICE of Gary Gygax and Brian Blume, OF PROCESS AND DISMISS and TSR HOBBIES, INC. , , a FOR LACK OF PERSONAL corporation, JURISDICTION, AND IN SUPPORT OF DEFENDANTS ' Defendants. ALTERNATE MOTION TO TRANSFER UNDER 28 U. S . C . 51404 (a) TABLE OF CONTENTS Page No. INTRODUCTION ARGUEMENT I. DEFENDANTS' MOTION TO DISMISS AFTER REMOVAL IS PROPER 11. THE BURDEN IS UPON PLAINTIFF TO PROVE THAT THE COURT HAS JURISDICTION OVER EACH OF THE DEFENDANTS, FOR EACH ALLEGED CAUSE OF ACTION, CONSISTENT WITH DUE PROCESS 111. MINNESOTA LONG-AIIM STATUTES 7 IV. THE COURT LACKS PERSONAL JURISDICTION 8 OVER EACH OF THE DEFENDANTS A. The Court Lacks Jurisdiction Over the 8 Non-res ident Individual Defendant, Gary Gygax (1) Jurisdiction over Gygax is not 9 conferred by Minnesota Statutes (2) Jurisdiction over Gygax is not 10 consis tent with due process B. The Court Lacks Jurisdiction Over The 13 Defendant Partnership, Tactical Studies Rules, (Dissolved in November, 1975) (1) Jurisdiction over the Terminated 15 Partnership is not Conferred by Minnesota Statutes (2) Jurisdiction over the Partnership 16 is not Consistent with Due Process (3) Jurisdiction Cannot Be Obtained over 17 A Terminated or Nonexistent Partner- ship C. The Court Lacks Jurisdiction Over The 2.2. Defendant Corporation, TSR Hobbies, Inc. (1) Summary of TSR's Contacts with 2.3 Minnesota (2) Jurisdiction over TSR Hobbies, Inc.
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