Dismissal Review

[Slippy]

Please let me know if this is adequate.

This is my motion to dismiss based on lack of jurisdiction. The JDB filed in a county I have 'never" lived in or currently reside.

However the "alleged" debt where the hospital contract was signed is in the county the JDB filed, were I do not live.

I don't want the judge to consider and NOT allow dismissal since the alleged contract was signed in the other county and there is no proof yet this debt is mine.

I also asked to dismiss with prejudice. I figure this is unusual but all one can do is try. Take a look at let me know your thoughts!

MOTION

MOTION BY DEFENDANT (my name here) FOR DISMISSAL OF PLAINTIF'S COMPLAINT DUE TO LACK OF PERSONAL JURISDICTION

THE UNDERSIGNED, (my name here), makes this motion on his own behalf, individually, pursuant to Rule 12( of the Federal Rules of Civil Procedure and Nevada Rules of Civil Procedure, Rule 12 h(3) to dismiss with prejudice Plaintiffs' claims against the undersigned in the above for lack of jurisdiction.

FACT

1. The undersigned is the defendant named as "(my name here)" in the original complaint

2. The undersigned's true legal name is "(my name here)"".

3. The undersigned is, and has been, a continuous resident of (county Name) in the state of Nevada since

December 2004.

4. The undersigned moved from (different state name here) and first resided at (address here) NV in

December 2004 of (county Name).

5. In February 2008 the undersigned changed residency to (address here) NV, also in (different county) of

Nevada.

6. The undersigned is not, and has never been, a resident of the County, City or township of (County that JDB files suit in) in the State of Nevada.

7. The undersigned has not engaged in any business transaction with the Plaintiff within the State of

Nevada or (alleged county name) that would grant this court jurisdiction.

8. The only direct contact the undersigned has had with the Plaintiff is one certified mail, a request for

debt validation in which the plaintiff never responded. (FDCPA 809(

[Guest usctrojanalum]

You would not be moving to dismiss based on lack of personal jurisdiction. When you move to dismiss based on the venue being wrong, you want the case dismissed based on the Court not having subject matter jurisdiction.

[Slippy]

You would not be moving to dismiss based on lack of personal jurisdiction. When you move to dismiss based on the venue being wrong, you want the case dismissed based on the Court not having subject matter jurisdiction.

Unless I'm not following here, the problem is the subject matter since they claim the contract for the hospital was signed in the county they filed suite.

They haven't proved it's mine. I'm concerned the judge will allow it based on the location of the alleged contract in his jurisdiction.

Or I'm I missing something...