Plaintiff,
Vs.
CALISSIO RESOURCES GROUP,
INC., a Nevada Corporation; ADAM
CARTER, and individual; SIGNATURE
STOCK TRANSFER, INC., a Texas
corporation; and DOES 1-50,
MOTION TO DISMISS
Defendants.
COMES NOW defendant Signature Stock Transfer, Inc., a Texas corporation and in
support of its three level Motion to Dismiss complaint of plaintiff, per Federal Rules of Civil
Procedure 12(b)(2), 12(b)(6), and Rule 9(b), states as follows:
1. Plaintiff filed its complaint in this matter on August 26, 2015.
2. Defendant Signature Stock Transfer, Inc. (hereinafter SST) challenges Plaintiffs
complaint and alleges it fails to:
(a) Assert facts providing for personal jurisdiction for SST 12(b)(2); and,
(b) Assert facts to support its First and Second claims for relief against defendant
SST; 12(b)(6); and,
(c) Assert facts to support its Third claim for relief against SST under 12(b)(6) or
particularly Rule 9(b).
3. SST files a Memorandum in Support of its Motion to Dismiss based on 12(b)(2), 12(b)(6)
and Rule 9.
1
By:
CERTIFICATE OF SERVICE
I certify that on October 20, 2015, a true and correct copy of the forgoing was sent via
electronic mail through the CM/ECF system to all attorneys of record.
Michael T. Hilgers (#24483)
mhilgers@goberhilgers.com
Carrie S. Dolton (#24221)
cdolton@goberhilgers.com
GOBER HILGERS PLLC
14301 FNB Parkway, Suite 100
Omaha, NE 68154
Telephone: (402) 218-2106
Facsimile: (877) 437-5755
David L. Aronoft*
daronoff@winston.com
Saul R. Rostamian*
srostamian@winston.com
Andrew G. Smith*
agsmith@winston.com
WINSTON & STRAWN LLP
333 S. Grand Avenue, 38th Floor
Los Angeles, CA 90071-1543
Telephone: (213) 615-1700
Facsimile: (213) 615-1750
* admitted pro hac vice
Attorneys/or Plaintiff COR Clearing, LLC