Magness v. Russian Federation
Properties Restitution


 

Motion to Set Aside Default Judgement
(defendant's motion)

In the United States District Court
for Southern District of Texas
Houston Division

Defendant American-Russian Cultural Cooperation Foundation's motion to set aside default judgment and rule 12(b) motion to dismiss for insufficiency of service of process and lack of personal jurisdiction.

COMES NOW Defendant American-Russian Cultural Cooperation Foundation ("the Federation") and files this Motion to Set Aside Default Judgment and Rule 12(b) Motion to Dismiss for Insufficiency of Service of Process and Lack of Personal Jurisdiction pursuant to Fed. R. Civ. P. 55(c), 60(b)(2),(4), and (6), 12(b)(2) and 12(b)(5). For the reasons set forth in the Foundation's Brief filed in support of this Motion, the Court should set aside the Final Judgment entered on June , 1999, and dismiss the claims against the Foundation.

Respectfully submitted,
VINSON & ELKINS
Christopher W. Byrd
Attorney-in-Charge
Texas Bar No. 03557500
Federal Admissions ID No. 703
2300 First City Tower
1001 Fannin
Houston, TX 77002-6760
(713) 758-2492
(713) 615-5589

Counsel for Defendant, American-Russian Cultural Cooperation Foundation.

OF COUNSEL:

D. Gibson Walton
Texas Bar No. 20824200
Federal Admissions ID No. 3306
D. John Neese, Jr.
Texas Bar No. 24002678
Federal Admissions ID No. 22641
2300 First City Tower
1001 Fannin
Houston, TX 77002-6760

CERTIFICATE OF CONFERENCE

I hereby certify that on June 23, 1999, I spoke with Plaintiffs' counsel, Mr. Lee Magness, regarding this Motion. Mr. Magness opposes this Motion.

(signature)
D. John Neese, Jr.

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