Portfolio Project Part 4 .docx - 1 2 3 4 5 Lisa Howard Law...

This preview shows page 1 - 5 out of 10 pages.

Lisa HowardLaw Offices of Howard & Mills, P.C.1234 Main StreetCharlotte, N.C. 28277(704) 555-1234[email protected]Representing Defendant UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SWEET LORRAINE’S SYSTEMS, LLC,1100 Snarl Avenue, suite 310Detroit, MI 42330, Plaintiff,vs.SWEET LORRAINE’S BAKERY, LLC,220 West BoulevardCharlotte, NC 28277,DefendantCase No.: 2013-77569MOTION TO REMOVE ACTION TO FEDERAL COURT TO THE CLERK OF THE ABOVE-ENTITLED COURT:PLEASE TAKE NOTICE that the defendant, Sweet Lorraine’s Bakery, LLC., will bring amotion to this Court for an order to remove this case to federal district court on a date and time which will be provided by the Court later.This Motion will be made of the grounds of diversity of citizenship under the provisions of Federal Rule of Civil Procedure 12(b)(3) and (5), and 28 U.S.C. § 1441(b), in that the defendant is not a resident of, and does not conduct business in, the State of Michigan and has nosubstantial contacts with the State of Michigan. This Motion shall be based upon this Notice, the attached affidavit of Lisa Howard, and the attached supporting brief in support of this motion. [TYPE BODY OF PLEADING HERE.] - 112345678910111213141516171819202122232425262728
Respectfully submitted this 9thday of June 2018.Lisa HowardAttorney at Law Law Offices of Howard & Mills, P.C.1234 Main StreetCharlotte, N.C. 282779(704) 555-1234[email protected]Representing Defendant [TYPE BODY OF PLEADING HERE.] - 212345678910111213141516171819202122232425262728
Lisa HowardLaw Offices of Howard & Mills, P.C.1234 Main StreetCharlotte, N.C. 282779(704) 555-1234[email protected]Representing DefendantUNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SWEET LORRAINE’S SYSTEMS, LLC,1100 Snarl Avenue, suite 310Detroit, MI 42330,Plaintiff,vs.SWEET LORRAINE’S BAKERY, LLC,220 West BoulevardCharlotte, NC 28277,DefendantCase No.: 2013-77569LISA HOWARD’S AFFIDAVIT IN SUPPORTOF MOTION TO REMOVE TO FEDERAL COURTLisa Howard, being duly sworn upon oath, states as follows:1.I, Lisa Howard, am the attorney for the Defendant, Sweet Lorraine’s Bakery, and respectfully request the Court to issue an order to move this case to federal court. 2.A legal action was commenced in Michigan Circuit Court in the State of Michigan in and for Wayne County entitled Sweet Lorraine’s Systems, LLC vs. Sweet Lorraine’s Bakery, LLC, as case number 2013-77569 attached hereto as Exhibit “A” and incorporated herein by reference.[TYPE BODY OF PLEADING HERE.] - 312345678910111213141516171819202122232425262728
3.Christine Donnelly, owner of Sweet Lorraine’s Bakery, received a copy of the said complaint via email attachment from opposing counsel, Marsha Jabber, from the said state court. A copy of the Summons in attached hereto as Exhibit “B” and incorporated herein by reference. 4.The reasons why I believe my client is entitled to the relief we are seeking are set forth below.

  • Left Quote Icon

    Student Picture

  • Left Quote Icon

    Student Picture

  • Left Quote Icon

    Student Picture