United States District Court
___________ DISTRICT OF _______________
Joe Patriot )
Plaintiff ) Docket No. 1234-567
Vs. ) MOTION FOR SPECIAL APPEARANCE
Juanita Freeman )
Defendant above named hereby appears specially to object to the jurisdiction of the court, based on the following grounds
- Plaintiff filed lawsuit against defendant for auto accident in SC on January 1, 2007. Plaintiff filed his complaint in the district court in the sate of Alaska on July 1, 2007.
- Plaintiff is resident and citizen of Alaska, Defend is a resident and citizen of SC
- Defendant is entitled to sue in district where he resides according to the constitution of this great nation and both states. Defendant is entitled to sue in the district where he resides.
- The defendant is a resident of South Carolina, and the Automobile accident that is the subject of this suit happened in SC. Therefore Defend is entitled to sue in the state where he lives and therefore this case should be transferred to SC. However, if Defend makes a change for motion of venue, then his motion would confer jurisdiction in the sate of Alaska.
- Defendant will file a motion for change of venue and other motions subject to this special appearance.
- In conclusion, Defendants further motions will not confer jurisdiction to the courts in Al due to this special appearance. Further, this case will be transferred to the district where defendant resides as the law requires.
CERTIFICATE OF SERVICE: I do hereby certify on this date that a copy this pleading was sent to properly to opposing council.
___________________________ Date: August 20, 2007
Joe Patriot, Pro Se