Epstein Secrets

tter of law." Fed.R.Civ.P. 56(c); Haul brook v. Michelin North Amer., Inc., 252 F.3d 696, 700 (4th Cir2001) (citing McKinney v. lid of Trustees of Mayland Only. Colt, 955 F.2d 924, 928 (4th Cir. 1992)) (stating that "summary judgment should be granted only when it is perfectly clear that no issue of

if de- fendant's activities within the forum state are substantial and pervasive, the court may exercise general jurisdiction over the defendant. Helicopteros, 466 U.S. at 415- 16, 104 S.Ct. 1868. At the hearing, the parties presented information regarding where both Plaintiff and Defendant resided durin

affiliat- ed. These contacts are not sufficiently “systematic and continuous” to maintain general jurisdiction over a defendant in this action.** See Helicopteros, 466 U.S. at 416, 104 S.Ct. 1868 (holding that purchas- ing in forum, sending personnel for train- ing in forum, and negotiating a contract in forum

d Resource’s Chairman by an executive of SBG. Ashton Complaint 1459; Burnett Complaint { 328. Plaintiffs claim that SBG had an address in Rockville, Maryland until very recently. Ashton Complaint 1545; Burnett Com- plaint 1318. SBG claims the Rockville address was the headquarters of a sepa- rately incorpo

nited States corporations based in Texas, and, during a trip to the United States in 1989, he met with President George H.W. Bush and the governor of Maryland. (Plaintiffs’ Opp’n to Prince Salman Mot. to Dismiss at 21-22; see generally Parrett Aff.) Additionally, Plaintiffs claim that Prince Salman’s son at

ownership of shares m Texas corporations, on its own, cannot be considered sufficiently systematic and continuous to establish general jurisdiction. Helicopteros, 466 U.S. at 414-16, 104 S.Ct. 1868 (finding CEO’s travel to forum for contract negotiations, employees’ travel to forum for training, receipt of fun