PART 1 - DEFENDANT'S MOTION TO DISMISS AMENDED COMPLAINT OR, IN THE ALTERNATIVE, TO TRANSFER VENUE.

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CANIEL M. HORRIGAN
210 JUN 15. PH t: 22

cout RN THE COURT OF COMMON PLEAS
CLERK OF CO, S#MMIT COUNTY, OHIO f

COUNTY OF SUMMIT, et al., ) CASE NO. CV 2009 12 9273
)
Plaintiffs, ) JUDGE THOMAS A. TEODOSIO
) MAGISTRATE JOHN SHOEMAKER
v. )
)
NORTHEAST OHIO REGIONAL SEWER ) DEFENDANT’S MOTION TO DISMISS
DISTRICT, ) AMENDED COMPLAINT OR, IN THE
) ALTERNATIVE, TO TRANSFER VENUE
Defendant. )

Pursuant to Rule 12(B)(1) of the Ohio Rules of Civil Procedure, Defendant, the Northeast

Ohio Regional Sewer District (the “District”), respectfully moves this Court for an order

dismissing the Amended Complaint filed against it on the grounds that the Cuyahoga County

Common Pleas Court has exclusive jurisdiction over matters pertaining to the purpose,
organization, and operations of the District.

Alternatively, pursuant to Rule 3(C) of the Ohio Rules of Civil Procedure, the District

) requests that the instant action be transferred to the Cuyahoga County Common Pleas Court so

th…