IN THE CIRCUIT COURT OF THE STATE OF OREGON

Pursuant to ORCP 21 A(2), Defendant CRAIG PORTWOOD moves the court for an order dismissing the complaint because this court lacks jurisdiction over the Defendants.

POINTS AND AUTHORITIES

1.

 Plaintiff’s Allegations

Plaintiffs allege that this Court has jurisdiction over plaintiffs claim under Article VII, Section 9 of the Oregon Constitution.

Plaintiffs further allege, that the Defendant was at all material times a resident of Jackson County, Oregon.

2.

ARGUMENT IN SUPPORT OF MOTION TO DISMISS

The Defendant maintains that the Court has no jurisdiction over Defendant as claimed under Article VII, Section 9 of the Oregon Constitution, which plainly states that;

Provision may be made by law for juries consisting of less than 12 but not less than six jurors.
[Created through S.J.R. 17, 1971, and adopted by the people Nov. 7, 1972]

Furthermore, the only place in which any specific activity is alleged to have occurred, is the state of MICHIGAN for examples, paragraphs 6, 14 (a), 14 (b), 14 (c), 14 (d), 14 (e), 14 (f), 14 (g), 14 (h), 14 (i), 14 (j), 14 (k), 14 (l), 14 (m), 14 (n), 14 (o), 14 (p), 14 (q), 14 (r), 14 (s), 14 (t), 14 (u), 14 (v), 14 (w), 14 (x), and 14 (y) of the complaint, refer to actions which have taken place while the Defendant was a resident of the State of MICHIGAN.

Conclusory allegations intended to support Oregon court jurisdiction over a nonresident are disfavored. State ex rel Michelin v. Wells, supra, 294 Or at 301-02. The complaint must be dismissed for lack of jurisdiction of this court over Defendants CRAIG PORTWOOD and JOHN DOES 1 through 4.