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COME NOW the Defendants, Keyen Farrell and John J. Farrell (collectively the
“Farrells”), pursuant to Rule 12(b)(2) of the Federal Rules of Civil Procedure and request an
Order of the Court dismissing the Complaint of Plaintiff Shoemoney Media Group, Inc. In
support of their Motion, the Farrells submit the accompanying Memorandum Brief and Index of
Evidence.
WHEREFORE, the Farrells respectfully request that their Motion to Dismiss for lack of
personal jurisdiction pursuant to Fed. Rule Civ. P. 12(b)(2) be granted and that the Complaint be
dismissed, along with all other relief this Court deems just.
Respectfully submitted,
Omaha, NE 68102
(402)341-3070
(402)341-0216 (fax)
jpaul@mcgrathnorth.com
msmith@mcgrathnorth.com
ATTORNEYS FOR THE DEFENDANTS
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on the 30th day of April, 2008, I electronically filed
the above foregoing document with the Clerk of the Court using the CM/ECF system which sent
notification of such filing to the following:
Troy F. Meyerson
Patrick S. Cooper
Fraser Stryker PC LLO
500 Energy Plaza
409 South 17th Street
Omaha, NE 68102-2663
(402)341-6000