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IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, LAW DIVISION

E360INSIGHT, LLC, an Illinois Limited
Liability Company, and DAVID LINHARDT,
and individual,
Plaintiffs,

v.

MARK JAMES FERGUSON, an individual,
SUSAN WILSON A.K.A. SUSAN GUNN, an
individual, ROB SAECKER A.K.A. FUDO, an
individual, RICH TIETJENS A.K.A.
MORELY DOTES, an individual, WILLIAM
SILVERSTEIN, an individual, and TIM
SKIRVIN, an individual
Defendants.

REPLY BRIEF IN RESPONSE TO OPPOSITION TO MOTION TO DISMISS

This is e360's Response to Ferguson's Motion to Dismiss

This is Robert Saecker's Reply to e360's Response to his motion to dismiss.

The tone of this summed up in the following quote from the Conclusion:

"Plaintiffs rely upon a fringe minority opinion from a foreign jurisdiction and wrap that unusual piece of jurisprudence with incomplete and inaccurate positions of Illinois case law to bolster their argument that Illinois can assert personal jurisdiction over Saecker."

This is e360's Response to Saecker's Motion to Dismiss

This is Robert Saecker's motion to dismiss.

Like Ferguson's it alleges insufficient contacts with Illinois.

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, LAW DIVISION

E360INSIGHT, LLC, an Illinois Limited
Liability Company, and DAVID LINHARDT,
and individual,
Plaintiffs,

v.

MARK JAMES FERGUSON, an individual,
SUSAN WILSON A.K.A. SUSAN GUNN, an
individual, ROB SAECKER A.K.A. FUDO, an
individual, RICH TIETJENS A.K.A.
MORELY DOTES, an individual, WILLIAM
SILVERSTEIN, an individual, and TIM
SKIRVIN, an individual
Defendant’s.

DECLARATION

I Mark James Ferguson declare and state:

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, LAW DIVISION

E360INSIGHT, LLC, an Illinois Limited
Liability Company, and DAVID LINHEART, an individual,

Plaintiffs,

v.

MARK JAMES FERGUSON, an individual,
SUSAN WILSON A.K.A. SUSAN GUNN, an individual,
ROB SAECKER A.K.A. FUDO, an individual, RICH TIETJENS
A.K.A, MORELY DOTES, an individual, WILLIAM SILVERSTEIN,
an individual, and TIM SKIRVIN, an individual

Defendants.

DEFENDANTS' MOTION TO DISMISS PURSUANT TO 735 ILCS 2-619 AND 735 ILCS 2-613

On May 14, 2007, e360Insight LLC and David Linhardt filed a state court action in Cook County Circuit Court (Civil Division) against Mark Ferguson, Susan Wilson (a/k/a Susan Gunn), Rob Saecker (a/k/a Fudo), Rich Tietjens (a/k/a Morely Dotes), William Silverstein, and Tim Skirvin (a/k/a Screwtape III).

Your faithful scribe had been watching Cook County Circuit Court (Chancery Division) instead, and so we apologize for the delay in getting this case to you.