附提交给美国联邦法院的动议（Motion to Dismiss for Lack of Personal Jurisdiction 隐去原被告姓名，用XX代替）
IN THE UNITED STATES DISTRICT COURT CENTRAL DISTRTICT OF California
DEfendants individually, Motion to
DEFENDANTS XX, INDIVIDUALLY, RULE12(b)(2) MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION
Defendant XX, individually, pro se, submit this his Motion to Dismiss for Lack of Personal Jurisdiction pursuant to Rule12(b)(2) of the Federal Rules of Civil Procedure and show the Court as follows;
XX, as a citizen of People’s Republic of China(hereinafter P.R.China), has never been to the United States of America and California, has no office, employees, agents, representatives, or accounts in Maryland, and should not be subject to the jurisdiction of United States District Court Central District of California.
MOTION TO DISMISS BASED ON LACK OF PERSONAL JURISDICTION
Defendant contend that this Honorable Court lacks personal jurisdiction over defendant and moves for dismissal of Plaintiff’s claims and cause of action because: (1) Defendant did not irrevocably consent to the jurisdiction of the Court; (2) Defendant did not purposefully direct any of his activity to California; (3)The court lacked jurisdiction because there was not a real and substantial connection between the dispute and Defendant; (4) The court lacked jurisdiction because the claim concerned foreign land;(5) if the court had jurisdiction, it should order a stay based on forum non conveniens.
This motion is supported by the following Exhibits:
Exhibit A Certification of Citizenship of P.R.China of XX
Exhibit B XX’s Certification of Employment by local law firm in Suzhou, P.R.China
WHEREFORE, PREMISES CONSIDERED, Defendant XX, individually request this Court grant his Motion to Dismiss for Lack of Personal Jurisdiction, both general and special, at law and in equity, to which Defendant may show himself to be justly entitled.
IN THE UNITED STATES DISTRICT COURT
CENTRAL DISTRTICT OF CALIFORNIA
COMES NOW the Defendant, XX, pro se , states as follows in answer to Plaintiff’s Complaint:
1.The allegation contained in paragraph 1 is a conclusion of a statement of jurisdiction . Defendants raises Objection to jurisdiction and submit his Motion to Dismiss for Lack of Personal Jurisdiction pursuant to Rule12(b)(2) of the Federal Rules. Defendant,
as a citizen of People’s Republic of China(hereinafter P.R.China), has never been to the United States of America and California, has no office, employees, agents, representatives, or accounts in Maryland, and should not be subject to the jurisdiction of United States District Court Central District of California.
2. Defendant admits the allegation contained in paragraph 2.
3. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 3. Allegations neither admitted nor denied are deemed denied.
4. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 4. Allegations neither admitted nor denied are deemed denied.
5. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 5. Allegations neither admitted nor denied are deemed denied.
6. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 6. Allegations neither admitted nor denied are deemed denied.
7. Defendant admits the allegation contained in paragraph 7.
8. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 8. Allegations neither admitted nor denied are deemed denied.
9. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 9. Allegations neither admitted nor denied are deemed denied.
10. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 10. Allegations neither admitted nor denied are deemed denied.
11. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 11. Allegations neither admitted nor denied are deemed denied.
12. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 12. Allegations neither admitted nor denied are deemed denied.
13. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 13. Allegations neither admitted nor denied are deemed denied.
14. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 14. Allegations neither admitted nor denied are deemed denied.
15. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 15. Allegations neither admitted nor denied are deemed denied.
16. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 16. Allegations neither admitted nor denied are deemed denied.
17. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 17. Allegations neither admitted nor denied are deemed denied.
18. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 18. Allegations neither admitted nor denied are deemed denied.
19. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 19. Allegations neither admitted nor denied are deemed denied.
20. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 20. Allegations neither admitted nor denied are deemed denied.
21. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 21. Allegations neither admitted nor denied are deemed denied.
22. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 22. Allegations neither admitted nor denied are deemed denied.
23. Defendant denies allegation contained in paragraph 23.Defendant denies he, as a attorney at law in China , represented Mr. Cher Koon Teo and never had a retainer agreement with Mr. Cher Koon Teo. Defendant denies he made blatantly false statements and submitted unsupported and or fabricated documents.
24. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 24. Allegations neither admitted nor denied are deemed denied.
25. Defendant is without knowledge sufficient to from a belief as to the allegations contained in paragraph 25. Allegations neither admitted nor denied are deemed denied.
Claim under Clark v. United States(1933)
26. Defendant repeat and reallege his answers to Paragraph 23.
27. Defendant denies each and very allegation contained in Paragraph 36.
28. That Plaintiff’s Complaint contained in paragraph 23, claim contained in Paragraph 36, fail to state a claim upon which relief can be granted.
WHEREFORE, the Defendant, XX individually, respectfully requests this Honorable court:
1. To dismiss for Lack of Personal Jurisdiction
2. To dismiss Count of Plaintiff’s Compliant in its entirely.
U633687664
U582679646
