Free Joinder - District Court of Delaware - Delaware

i p Case 1 :07—cv—00066-GIVIS Document 27 Filed 06/15/2007 Page 1 of 2
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE .
RICHARD SNYDER g
U Plaintiff, V § ‘
I
) .
v. )
p , )
GPM2 LLC, CHRISTY MANAGEMENT, g Case No.: 1:07-cv-00066-GMS ‘
LLC, BONNIE BENSON, P.A., THE )
FELTON BANK OF DELAWARE, JAMES P. )
CONNOR, JR., UNKNOWN TITLE )
INSURANCE COMPANY, and SERGOVIC )
& ELLIS P.A., )
Defendants. g
J OINDER OF DEFENDAN T GPM2 LLC
AND REPLY IN SUPPORT OF ITS
MOTION TO DISIVHSS
Defendant GPM2 LLC ("GPM"), by its undersigned counsel, hereby joins in the
Response to Plaintiff Snyder’s Objection to Letter(s) and Motion for Sanctions filed by
Defendant Bonnie Benson, P.A., and further replies in support of its own motion to
dismiss In support hereof Defendant GPM states:
q lx For the reasons set forth in Defendant Benson’s Response, Plaintiff has:
a. failed to adequately request oral argument regarding the pending
motions; -
I b. failed to support its request for sanctions; and
c. failed to respond to any of the motions to dismiss in general, and
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specifically has failed to oppose the motion to dismiss on the grounds that (i) this Court
lacks subject matter jurisdiction over this dispute because there is no federal question at _
l. . l A 548951.16/15/07

Case 1 :07—cv—00066-GIVIS Document 27 Filed 06/15/2007 Page 2 of 2
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issue in this action and there is no diversity of parties; and (ii) the Complaint fails to state q
a claim as the contract at issue in this action required that the sale of the subject property
I was to occur by December 5, 2005 and that time was of the essence. Mr. Snyder failed to
l timely perform his obligations under the Contract. Thus, Mr. Snyder cannot state a claim
I ‘ for breach of a Contract that he, himself, has terminated.
1 WHEREFORE, for the reasons stated in its brief in support of its motion to
dismiss as well as the reasons set forth in Benson’s Response to Plaintiff Snyder’s
Objection to Letter(s), Defendant GPM2 LLC respectfully requests that this Honorable L
Court dismiss the Complaint and grant such other and furtherrelief as is necessary, just
and proper. ‘
Dated: June 15,2007 . ll`! _ _
Jere i y W. Ryan (Bar N 7)
Mic 6 ael R. Robinson (Bar No. 4452)
1 ‘ · SA EWING LLP
` 222 Delaware Avenue, Suite 1200
P.O. Box 1266
Wilmington, DE 19899-1266
` Telephone: (302) 421-6800
Email: [email protected]
_ [email protected] ’
Counsel for Defendant GPM2 LLC
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V 548951.16/15/07 I l

i Case 1:07-cv-00066-GI\/IS Document 27-2 Filed 06/15/2007 Page 1 of 1
1 CERTIFICATE OF SERVICE
1 I, Jeremy W. Ryan, hereby certify that on this 15th day of June, 2007, I caused to ‘
i be electronically tiled a true and correct copy of the foregoing Joiuder and Reply in
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1 Support of its Motion to Dismiss with the Clerk of Court using CM/ECF which will
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1 send notification of such tiling. A copy of the document was served on the following
i persons in the manner indicated: »
. VIA U.S. MAIL VIA E-MAIL
Richard Snyder John H. Newcomer, Jr., Esq.
23 Harbor Road MORRIS JAMES LLP A
Rehoboth Beach, DE 19971 500 Delaware Avenue, Suite 1500 ‘ ·
Wilmington, DE 19801
VIA U.S. MAIL
Richard Snyder VIA U.S. MAIL
P.O. Box 374 SERGOVIC & ELLIS, P.A.
Davidsonville, MD 21035 9 North Front Street
P.O. Box 875 ‘
VIA E-MAIL Georgetown, DE 19947
Jeffrey M. Weiner, Esq. p
1332 N. King Street
Wilmington, DE 19801
Jerem W. yan (Bar
SAU j E LLP
222 laware Avenue, Suite 1200
P.O. Box 1266
Wilmington, DE 19899-1266
V Telephone: (302) 421-6800 t
Email: [email protected]
548951.1 6/15/07