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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA
WESTERN DIVISION
Civil Action No. 5:09-cv-00449
R. DANIEL BRADY ET AL., )
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Plaintiffs, )
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v. )
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XE SERVICES LLC ET AL., )
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Defendants. )
____________________________________)
DEFENDANT JEREMY P. RIDGEWAY’S OPPOSITION TO PLAINTIFFS’
SEPARATED MOTION FOR LEAVE TO CONDUCT JURISDICTIONAL DISCOVERY
COMES NOW Defendant Jeremy P. Ridgeway (“Mr. Ridgeway”), by counsel, pursuant
to Local Rule 7.1, and hereby submits this Opposition to Plaintiffs’ Separated Motion for Leave
to Conduct Jurisdictional Discovery (the “Opposition”). Plaintiffs’ Separated Motion for Leave
to Conduct Jurisdictional Discovery (the “Motion”) should be denied because Plaintiffs have not
established the requisite prima facie evidence of personal jurisdiction that is needed for the Court
to grant Plaintiffs leave to conduct the discovery in question. The grounds for this Opposition
are set forth more fully in the accompanying Memorandum in Support.
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WHEREFORE, Mr. Ridgeway requests respectfully that the Court deny Plaintiffs’
Motion.
Respectfully submitted this the 17th day of February, 2010.
By: /s/ Edward H. Maginnis
Edward H. Maginnis (Bar No. 39317)
MAGINNIS LAW, PLLC
6030 Creedmoor Road, Suite 200
Raleigh, NC 27612
Telephone: 919.526.0450
Facsimile: 919.882.8763
emaginnis@maginnislaw.com
Counsel for defendant Jeremy P. Ridgeway
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CERTIFICATE OF SERVICE
I hereby certify that on February 17, 2010, I caused true and correct copies of the foregoing
Opposition to Plaintiffs’ Separated Motion for Leave to Conduct Jurisdictional Discovery to be served
on counsel registered with the CM/ECF system.
/s/ Edward H. Maginnis
Edward H. Maginnis