Weinberg v. National Football League Players Association et al Doc.

6
Case 3:06-cv-02332 Document 6 Filed 12/27/2006 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION

STEVE WEINBERG §
§
Plaintiff, §
§
§
CIVIL ACTION NO. 3~06-CV-2332-B
NATIONAL FOOTBALL LEAGUE § ECF
PLAYERS ASSOCIATION, RICHARD §
BERTHELSEN, GENE UPSHAW, TOM §
DEPASO, TRACE ARMSTRONG, §
ROGER KAPLAN, JOHN COLLINS, §
KEITH WASHINGTON, TONY
AGNONE, HOWARD SHATSKY, and
MARK LEVIN

Defendants.

DEFENDANT ROGER P. KAPLAN'S MOTION TO

DISMISS FOR LACK OF PERSONAL JURISDICTION

Roger P. Kaplan ("Kaplan"): Defendant, pursuant to Fed. R. Civ. P. 12(b)(2) and Local

Rule 7.1 of the Local Rules of the Northern District of Texas, moves this Court for an Order

dismissing Kaplan from this case for lack of personal jurisdiction over him.

This Motion is supported by the Affidavit of Roger P. Kaplan, which is contained in the

Appendix filed with the accompanying Brief in Support of the Motion to Dismiss and

incorporated herein

WHEREFORE, for the foregoing reasons, as set forth fully in the accompanying Brief,

Kaplan requests that his Motion be granted and the Complaint against him be dismissed for lack

of jurisdiction.

Dockets.Justia.com
 Case 3:06-cv-02332 Document 6 Filed 12/27/2006 Page 2 of 2

Respectfully submitted,
HUNTON& WILLIAMS
LLP

By:
Allen Butler, SBN 035 19000

1601 Bryan Street, 3othFloor

Dallas, Texas 75201-3402
214.979.3000
214.979.3908 (fax)

ATTORNEYS FOR DEFENDANT

ROGER P. KAPLAN

CERTIFICATE OF SERVICE

The undersigned hereby certifies that on the 27thday of December 2006, true and correct
copies of the foregoing Defendant Roger Kaplan's Motion to Dismiss for Lack of Personal
Jurisdiclion were served by certified mail, return receipt requested, upon counsel for Plaintiff,
Lawrence J. Friedman, FRIEDMAN & FEIGER,LLP, 5301 Spring Valley Road, Suite 200, Dallas,
TX 75254 and counsel for Defendants, David Greenspan, DEWEYBALLANTINE, LLP, 1301
Avenue of the Americas, New York, NY 10019-6092 and Ralph Miller, WEIL,GOTSHAL &
MANGES LLP, 200 Crescent Court, Suite 300, Dallas, TX 75201.

.
Allen Butler

99999.000309 DALLAS 218946~3