Oaxaco El Bey v. NCO Financial Systems, Inc.MOTION to dismiss caseW.D. Mo.July 28, 2015 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MISSOURI WESTERN DIVISION Oaxaco El Bey, Plaintiff, -v- NCO Financial Systems, Inc., Defendant. ) ) ) ) ) ) ) ) ) CASE NO.: 4:15-cv-00560-DGK DEFENDANT NCO FINANCIAL SYSTEMS, INC.’S MOTION TO DISMISS Now comes NCO Financial Systems, Inc., by and through the undersigned counsel, and pursuant to FED. R. CIV. P. 12(b)(6), hereby moves this honorable court to dismiss plaintiff’s complaint, for the reason that Plaintiff has failed to state a claim for which relief may be granted. NCO relies on the suggestions of law filed contemporaneously herewith. Respectfully Submitted, /s/Krystle M. Dunn Paul M. Croker MO #57000 Krystle M. Dunn MO #64139 Armstrong Teasdale LLP 2345 Grand Boulevard, Suite 1500, Kansas City, Missouri 64108-2617 816.221.3420 FAX: 816.221.0786 pcroker@armstrongteasdale.com kdunn@armstrongteasdale.com Attorneys for Defendant, NCO Financial Systems, Inc. Case 4:15-cv-00560-DGK Document 5 Filed 07/28/15 Page 1 of 2 CERTIFICATE OF SERVICE I hereby certify that on July 28, 2015, a copy of the foregoing was filed electronically in accordance with the Court’s Electronic Filing Guidelines. Notice of this filing will be sent to the parties by operation of the court’s electronic filing system, at the address of counsel noted below. Parties may access this filing through the court’s system. A true copy was also sent via ordinary U.S. Mail, postage prepaid on July 28, 2015 to: Oaxaco El Bey P.O. Box 670824 Coral Springs, Florida 33067 /s/Krystle M. Dunn Krystle M. Dunn Case 4:15-cv-00560-DGK Document 5 Filed 07/28/15 Page 2 of 2
