I would like the court to enforce Georgia's long arm statute. Can you read below and let me know if I need to add any more information for the Court.Stratton’s ties to The State of Georgia26. Stratton, on an ongoing basis raised investment capital from Georgia residents on many different occasions from 2008 to 2010.27. Stratton actively assisted in the sale of video phones and provided technical support for services that were sold to Georgia residents and businesses. 28. Stratton made the interpretation and enforcement of certain consultant agreements subject to the laws of the State of Georgia.29. Stratton committed tortuous and fraudulent acts in the State of Georgia in 2009 when he falsely recorded loans made by Baird to BlinkMind Inc. as stock. 30. Stratton committed tortuous and fraudulent acts in the State of Georgia in 2009 when he used BlinkMind Inc. fraudulent financial statement to solicit the investment of other Georgia residents.
State/Country relating to question: Georgia
Hi, The most important fact, really, is #29. There are a couple of things you could add, if they are true:1. The defendant had systematic and on-going contact with the state of Georgia, and the suit arises out of those contacts.2. The defendant was physically present when the tortuous acts occurred. 3. Extending Georgia's long-arm statute to exert jurisdiction over the defendant is consistent with due process. You always have to satisfy due process, in addition to the long arm statute. Of course, usually, if you satisfy the long-arm statute, it's consistent with due process. But, most people would still say it.#29 says that the defendant committed tortious and fraudulent acts in the state, and you do say elsewhere in the complaint that he was physically in Georgia when it happened, but it doesn't hurt to explicitly state it.If you have any evidence that he regularly visited the state, called the state, solicited investors in the state, etc., all of that would also help. It becomes more important should he dispute jurisdiction, but there's no reason you can't mention it in the complaint.
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