NOTICE OF REMOVAL - FORM

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NOTICE OF REMOVAL - FORM

Postby Administrator » Thu Oct 02, 2014 12:10 pm

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
NEW ORLEANS DIVISION

LAS ENTERPRISES, INC. CIVIL ACTION NO.

VERSUS JUDGE

ACCU SYSTEMS, INC. MAGISTRATE

NOTICE OF REMOVAL
NOW INTO COURT through undersigned counsel, comes Defendant, ACCU-SYSTEMS, INC., IMPROPERLY NAMED AS “ACCU SYSTEMS, INC.,” who respectfully files this Notice of Removal of the above captioned lawsuit to the United States District Court in and for the Eastern District of Louisiana, New Orleans Division, from the 24th Judicial District Court for the Parish of Jefferson, State of Louisiana, where the action is now pending, as follows:
1.
This Court has original jurisdiction by virtue of 28 U.S.C. 1332 as this case involves claims between [corporate] citizens of different states, diversity of citizenship exists by law and the amount in controversy exceeds $75,000.00, per pars. VII and XX of the petition.
2.
Plaintiff LAS ENTERPRISES, INC., filed this civil action entitled "LAS ENTERPRISES, INC. v. ACCU SYSTEMS, INC., suit no. 703-515-D, 24th Judicial District Court for the Parish of Jefferson, State of Louisiana," in the state district court in Jefferson Parish, Louisiana. That state court is within Jefferson Parish which is designated as part of the Eastern District of Louisiana and specifically designated as a Parish assigned by the New Orleans Division. Thus, removal to this Division and this Honorable Court is mandated.
3.
Copies of all process, pleadings, orders and other papers contained in the state court lawsuit, "LAS ENTERPRISES, INC. v. ACCU SYSTEMS, INC., suit no. 703-515-D, 24th Judicial District Court for the Parish of Jefferson, State of Louisiana," are attached hereto as Exhibit A.
4.
The only named defendant herein consents to this removal.
5.
Removal of this action is permitted and authorized by 28 U.S.C. 1334 and 28 U.S.C. 1452.
6.
This Honorable Court has subject matter jurisdiction over all cases under 28 U.S.C. 1332.
WHEREFORE DEFENDANT ACCU-SYSTEMS, INC., IMPROPERLY NAMED AS “ACCU SYSTEMS, INC.,” respectfully files this Notice of Removal of the above captioned lawsuit and all claims and demands made therein to the United States District Court in and for the Eastern District of Louisiana, New Orleans Division, from the 24th Judicial District Court for the Parish of Jefferson, State of Louisiana, where the action is now pending, and PRAYS that the above entitled and captioned action be removed from the 24th Judicial District Court for the Parish of Jefferson, State of Louisiana, to this Honorable Court, and for any and all other legal or equitable relief.
Respectfully submitted,

Bodenheimer, Jones & Szwak, LLC



By: ______________________________________
David A. Szwak, LBR# 21157, TA
416 Travis Street, Ste. 1404
Mid South Tower
Shreveport, Louisiana 71101
[318] 424-1400
FAX 221-6555


WIMMER & PITTS, P.C.


By: ______________________________________
JUDSON PITTS, UBR# _____
45 West 10000 South, Suite 211
Sandy, Utah 84070
[801] 285-8737
FAX 285-8738
ATTORNEY FOR DEFENDANT, ACCU-SYSTEMS, INC., IMPROPERLY NAMED AS “ACCU SYSTEMS, INC.

CERTIFICATE OF SERVICE
I hereby certify that a copy of the above and foregoing has been served upon all counsel of record, as noted below, by placing a copy of same in the United States Mail, properly addressed and first class postage pre-paid on this the 1st day of September, 2011.

Lee Rand, Attorney
1010 Common Street #2700
New Orleans, LA 70112-2428

___________________________________
OF COUNSEL
David A. Szwak
Bodenheimer, Jones & Szwak, LLC
416 Travis Street, Suite 1404, Mid South Tower
Shreveport, Louisiana 71101
318-424-1400 / Fax 221-6555
President, Bossier Little League
Chairman, Consumer Protection Section, Louisiana State Bar Association

Administrator
Site Admin
Posts: 11757
Joined: Tue Jul 26, 2005 4:15 am

Re: NOTICE OF REMOVAL - FORM

Postby Administrator » Thu Oct 02, 2014 12:11 pm

LAS ENTERPRISES, INC. NO. 703-515-D

VERSUS 24th JUDICIAL DISTRICT COURT

ACCU SYSTEMS, INC. JEFFERSON PARISH, LOUISIANA

NOTICE TO PLAINTIFF OF REMOVAL OF ACTION
TO: Lee Rand, Attorney
1010 Common Street #2700
New Orleans, LA 70112-2428

PLEASE TAKE NOTICE that Defendant ACCU-SYSTEMS, INC., IMPROPERLY NAMED AS “ACCU SYSTEMS, INC.,” has filed a Notice of Removal of the above captioned lawsuit to the United States District Court in and for the Eastern District of Louisiana, New Orleans Division, from the 24th Judicial District Court for the Parish of Jefferson, State of Louisiana, lawsuit, "LAS ENTERPRISES, INC. v. ACCU SYSTEMS, INC., suit no. 703-515-D, 24th Judicial District Court for the Parish of Jefferson, State of Louisiana."
Respectfully submitted,

Bodenheimer, Jones & Szwak, LLC



By: ______________________________________
David A. Szwak, LBR# 21157, TA
416 Travis Street, Ste. 1404
Mid South Tower
Shreveport, Louisiana 71101
[318] 424-1400
FAX 221-6555

WIMMER & PITTS, P.C.


By: ______________________________________
JUDSON PITTS, UBR# _____
45 West 10000 South, Suite 211
Sandy, Utah 84070
[801] 285-8737
FAX 285-8738
ATTORNEY FOR DEFENDANT, ACCU-SYSTEMS, INC., IMPROPERLY NAMED AS “ACCU SYSTEMS, INC.

CERTIFICATE OF SERVICE
I hereby certify that a copy of the above and foregoing has been served upon all counsel of record, as noted below, by placing a copy of same in the United States Mail, properly addressed and first class postage pre-paid on this the 1st day of September, 2011.

Lee Rand, Attorney
1010 Common Street #2700
New Orleans, LA 70112-2428

___________________________________
OF COUNSEL
David A. Szwak
Bodenheimer, Jones & Szwak, LLC
416 Travis Street, Suite 1404, Mid South Tower
Shreveport, Louisiana 71101
318-424-1400 / Fax 221-6555
President, Bossier Little League
Chairman, Consumer Protection Section, Louisiana State Bar Association

Administrator
Site Admin
Posts: 11757
Joined: Tue Jul 26, 2005 4:15 am

Re: NOTICE OF REMOVAL - FORM

Postby Administrator » Thu Oct 02, 2014 12:12 pm

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
NEW ORLEANS DIVISION

LAS ENTERPRISES, INC. CIVIL ACTION NO.

VERSUS JUDGE

ACCU SYSTEMS, INC. MAGISTRATE

NOTICE TO PLAINTIFF OF REMOVAL OF ACTION
TO: Lee Rand, Attorney
1010 Common Street #2700
New Orleans, LA 70112-2428

PLEASE TAKE NOTICE that Defendant ACCU-SYSTEMS, INC., IMPROPERLY NAMED AS “ACCU SYSTEMS, INC.,” has filed a Notice of Removal of the above captioned lawsuit to the United States District Court in and for the Eastern District of Louisiana, New Orleans Division, from the 24th Judicial District Court for the Parish of Jefferson, State of Louisiana, lawsuit, "LAS ENTERPRISES, INC. v. ACCU SYSTEMS, INC., suit no. 703-515-D, 24th Judicial District Court for the Parish of Jefferson, State of Louisiana."
Respectfully submitted,

Bodenheimer, Jones & Szwak, LLC



By: ______________________________________
David A. Szwak, LBR# 21157, TA
416 Travis Street, Ste. 1404
Mid South Tower
Shreveport, Louisiana 71101
[318] 424-1400
FAX 221-6555


WIMMER & PITTS, P.C.


By: ______________________________________
JUDSON PITTS, UBR# _____
45 West 10000 South, Suite 211
Sandy, Utah 84070
[801] 285-8737
FAX 285-8738
ATTORNEY FOR DEFENDANT, ACCU-SYSTEMS, INC., IMPROPERLY NAMED AS “ACCU SYSTEMS, INC.

CERTIFICATE OF SERVICE
I hereby certify that a copy of the above and foregoing has been served upon all counsel of record, as noted below, by placing a copy of same in the United States Mail, properly addressed and first class postage pre-paid on this the 1st day of September, 2011.

Lee Rand, Attorney
1010 Common Street #2700
New Orleans, LA 70112-2428

___________________________________
OF COUNSEL
David A. Szwak
Bodenheimer, Jones & Szwak, LLC
416 Travis Street, Suite 1404, Mid South Tower
Shreveport, Louisiana 71101
318-424-1400 / Fax 221-6555
President, Bossier Little League
Chairman, Consumer Protection Section, Louisiana State Bar Association


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