DLL v. Ramkelawan, Reply Memo, ED Pa.

[David A. Szwak]

 UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF PENNSYLVANIA
PHILADELPHIA DIVISION


DE LAGE LANDEN FINANCIAL SERVICES,
INC., ET AL CIVIL ACTION NO.
2:2006CV01747
VERSUS JUDGE DIAMOND

CYNTHIA RAMKELAWAN, DDS a/k/a
CYNTHIA RAMKELAWAN

DEFENDANT’S REPLY TO PLAINTIFF’S OPPOSITION TO DEFENDANT’S
12[2], 12[3], 12[6], and 12[7] OF THE FEDERAL
RULES OF CIVIL PROCEDURE AND MOTION
FOR ABSTENTION AND, ALTERNATIVELY,
MOTION TO TRANSFER VENUE UNDER 28 U.S.C. 1404[a]

MAY IT PLEASE THE COURT:

Defendant, CYNTHIA RAMKELAWAN, respectfully replies to the Opposition of the
plaintiff to Defendant’s various motions, as follows:

Personal Jurisdiction Waiver
Defendant respectfully corrects a misconception that has been stated in the motion and
opposition. The clause at issue is actually not a forum selection clause [not stating that
Pennsylvania courts are where disputes must be addressed], rather the clause is a purported “personal jurisdictionâ€