Kenneth J. Cool, P.C. et al v. Berkeley Law & Technology Group, LLP

Filing 1

Attachment 1
NOTICE OF REMOVAL from Douglas County District Court, Case Number 2007CV1020. ( Filing fee $ 350 Receipt Number COX001555), filed by Berkeley Law & Technology Group, LLP. (Attachments: # 1 Exh 1 - Declaration# 2 Exh 2 - Affidavit of Svc# 3 Exh 3 - Complaint# 4 Exh 4 - State Cover Sheet# 5 Exh 5# 6 Exh 6 - Notice# 7 Summons# 8 Civil Cover Sheet # 9 Supplemental Civil Cover Sheet # 10 Receipt)(llr, )

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Kenneth J. Cool, P.C. et al v. Berkeley Law & Technology Group, LLP Doc. 1 Att. 1 Case 1:07-cv-01088-WYD-MEH Document 1-2 Filed 05/23/2007 Page 1 of 3 EXHIBIT 1 09901-0001/LEGAL11364364.1 Dockets.Justia.com Case 1:07-cv-01088-WYD-MEH Document 1-2 Filed 05/23/2007 Page 2 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. _________ KENNETH J. COOL., P.C., a Colorado Corporation, and KENNETH J. COOL, Plaintiffs, v. BERKELEY LAW & TECHNOLOGY GROUP, LLP, f/k/a BERKELEY LAW & TECHNOLOGY GROUP, LLC, an Oregon limited liability partnership, Defendant. ______________________________________________________________________________ DECLARATION OF HOWARD A. SKAIST IN SUPPORT OF NOTICE OF REMOVAL ______________________________________________________________________________ My name is Howard A. Skaist. I am an individual over the age of eighteen (18) years. I have personal knowledge of the facts stated herein, and would be willing and able to testify thereto if and when called upon to do so. 1. I am the founder and principal counsel of Berkeley Law & Technology Group, LLP ("BLTG"), the defendant in the above-captioned action. 2. On or about April 23, 2007, a process server delivered a copy of the Complaint in this matter to BLTG at its office in Beaverton, Oregon. This was the first notice BLTG had of the action. 3. Attached to the Notice of Removal as Exhibit 5 is a true and correct copy of an annual report regarding Kenneth J. Cool, P.C., filed with the Colorado Secretary of State, and available from the Secretary of State's website, at www.sos.state.co.us. Case 1:07-cv-01088-WYD-MEH Document 1-2 Filed 05/23/2007 Page 3 of 3 4. BLTG is a limited liability partnership with its principal place of business in Beaverton, Oregon. None of its partners reside in Colorado. 5. To my knowledge, no hearings have been set in the State court action. Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct. DATED this 23rd day of May, 2007. s/ Howard Skaist Howard A. Skaist [33668-0073/13233536_1.DOC] 57391-0002/LEGAL13233536.1 2

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