REPLY TO

• 
• 
• 
• 
• 
• 

                        

						    Preview
                        
                        
                          Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Oct 10 4:46 PM-18CV002305
OE360 - C45

IN THE FRANKLIN COUNTY COURT OF COMMON PLEAS

CIVIL DIVISION
ED MAP, INC
Plaintiff,
Case No. 2018 CV 2305
v.
Judge Cain
DELTA CAREER EDUCATION

CORPORATION. ef al.,
Defendants.
REPLY OF PLAINTIFF ED MAP, INC.
TO ANCORA DEFENDANTS’
MEMORANDUM CONTRA TO MOTION FILED SEPTEMBER 19, 2018

No less than thirteen separate times, the Ancora Defendants falsely assert in their
memorandum contra that Ed Map has introduced “no evidence” supporting the Court’s personal
jurisdiction over the Ancora Defendants. But repeating a falsehood does not make it true. The
complete APA, which includes the APA’s schedules and exhibits and reveals previously-
redacted terms, is evidence establishing that the Ancora Defendants acquired the Agreement
between Delta and Ed Map and are subject to its forum-selection clause.'

Even if the Court is not persuaded that Ed Map has met its prima facie burden to
establish p…