Free Response to Motion - District Court of Delaware - Delaware

Case 1:08-cv-00033-JJF

Document 6

Filed 07/07/2008

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ORIGINAL
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE HARRY E. COUTZ, and JENNIFER COUTZ, Plaintiffs,
v.
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CIVIL ACTION No. 1:08-cv-33-JJF

GEICO DIRECT, t/a GEICO GENERAL INSURANCE COMPANY, Defendant.

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)

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NOTICE OF PLAINTIFF'S OPPOSITION TO
MOTION TO TRANSFER VENUE


TO:

Nicholas E. Skiles, Esquire Michael B. Galbraith, Esquire 300 Delaware Avenue, Suite 1130 P.O. Box 330
Wilmington, DE 19899
PLEASE TAKE NOTICE that the attached Plaintiffs Opposition to Motion to

Transfer Venue will be presented to the Court on Thursday, July 11,2008 at 2:00 p.m.

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Dated: L \

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Antonia S. Bevis {, 1716 Wawaset Street P.O. Box 188 Wilmington, DE 19899-0188 (302) 656-7247 Attorney for Plaintiff

Case 1:08-cv-00033-JJF

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE HARRY E. COUTZ, and JENNIFER COUTZ, Plaintiffs, v. ) ) )
) )
) )
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)

CIVIL ACTION No. 1:08-cv-33-JJF

GElCO DIRECT, t/a GElCO GENERAL INSURANCE COMPANY,
Defendant.

PLAINTIFFS' OPPOSITION TO MOTION TO TRANSFER VENUE

Plaintiff Harry E. Coutz hereby opposes the Motion to Transfer Venue before the court. In support of his opposition to the motion, he states as follows: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. Admitted. Admitted. Admitted. Admitted. Admitted. Admitted. Admitted. Admitted. Admitted. Plaintiffs are unable to admit or deny this allegation as Plaintiffs are unaware of

who Defendant plans to call as witnesses. 11. Denied. GEICO has defended numerous claims in the State of Delaware in the

Case 1:08-cv-00033-JJF

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past and will continue to do so in the future. 12. 13. Admitted, as will the United States District Court of Delaware. Denied. Plaintiff will have to seek counsel in the State of Maryland if this matter

is transferred from Delaware.

WHEREFORE, for the foregoing reasons, the Plaintiff, Harry E. Coutz, respectfully
requests that the Defendant's Motion to Transfer Venue be DENIED.

Antonia S. Bevis #3379 1716 Wawaset Street P.O. Box 188 Wilmington, DE 19899-0188 (302) 656-7247 Attorney for Plaintiffs Dated:

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Case 1:08-cv-00033-JJF

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Filed 07/07/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE HARRY E. COUTZ, and JENNIFER COUTZ, Plaintiffs, v. GEICO DIRECT, t/a GEICO GENERAL INSURANCE COMPANY, Defendant. ) )
)


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CIVIL ACTION No. 1:08-cv-33-JJF

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ORDER

AND NOW, to wit, this

day of

, 2008, after

consideration of Defendant's Motion to Transfer Venue and Plaintiff's Opposition thereto, IT IS HEREBY ORDERED that the Motion to Transfer Venue is DENIED.

J.

Case 1:08-cv-00033-JJF

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CERTIFICATE OF SERVICE

I, Antonia S. Bevis, Esquire, hereby certify that on this t'day of July 2008, two copies of the foregoing Plaintiffs' Opposition to Defendant's Motion to Transfer Venue were hand delivered to the following: Nicholas E, Skiles, Esquire Michael B. Galbraith, Esquire 300 Delaware Avenue, Suite 1130 P,O. Box 330 Wilmington, DE 19899

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1716 Wawaset Street P,O. Box 188 Wilmington, DE 19899-0188 Attorney for Plaintiffs