Bancroft Life & Casualty ICC, Ltd. v. GRBR Ventures, L.P.

MEMORANDUM AND ORDER

KEITH P. ELLISON, District Judge.

Before the Court is Plaintiff Bancroft Life & Casualty ICC, Ltd.’s (“Bancroft”) Motion to Dismiss GRBR Ventures, L.P.’s (“GRBR”) Second Amended Counterclaims (Doc. No. 76).1 The Court is persuaded that GRBR has failed to state a claim upon which relief can be granted in the challenged counterclaims in its Third Amended Answer and Counterclaim and Third-Party Complaint (“Third Amended Answer,” or “TAA”; Doc. No. 87-1). Therefore, the Court GRANTS Bancroft’s Motion.

I. BACKGROUND2

This ease arises from a complex foreign tax advantaged…