Doninger v. Niehoff et al

Filing 1

NOTICE OF REMOVAL from Judicial District of New Britain at New Britain. Filing fee $350 receipt number H023116 filed by Lauren Doninger. (Attachments: #1 Complaint for Injunctive Relief#2 Notice of Filing of Notice of Removal#3 Certificate of Filing and Service of Notice of Removal#4 Notice of Consent to Removal)(Grady, B.)

UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT

LAUREN DONINGER, PPA
AVERY DONINGER
v.
KARISSA NIEHOFF AND
PAULA SCHWARTZ

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NO.:

JULY 26, 2007

NOTICE OF REMOVAL
To the United States District Court for the District of Connecticut:
Pursuant to 28 U.S.C. §§1441, 1443 and 1446, the defendants hereby give
notice that they have removed this action from the Superior Court of Connecticut,
Judicial District of New Britain at New Britain for the following reasons:
1.

Plaintiffs have commenced an action against the defendants in the

Judicial District of New Britain at New Britain, by service of a Summons and Complaint
dated July 16, 2007. The plaintiff served a copy of the Summons and Complaint upon
each defendant individually on or after July 16, 2007. Pursuant to 28 U.S.C. §1446(a),
the defendants have attached said Summons and Complaint hereto.
2.

The above-described action is a civil action and is one which may be

removed to the Court by the defendant pursuant to the provisions of Title 28, United
States Code §§1441, 1331 and 1343(3), in that the Complaint alleges a violation of

civil rights and a violation of the plaintiff’s rights under the First Amendment, involving
a federal question. The controversy arises under the said statutes.
3.

The action is returnable in the Superior Court for the Judicial District of

New Britain at New Britain on August 14, 2007.
4.

Attached hereto, in compliance with 28 U.S.C. §1446(a), are complete

and accurate copies of the process and pleadings received by the defendants to date.
5.

The defendants deny all of plaintiff’s allegations.

6.

Accordingly, this Court has original jurisdiction of this action under 28

U.S.C. §§1331, 1343(3) and supplemental jurisdiction pursuant to 28 U.S.C. §1367.
The action may be removed to this Court pursuant to 28 U.S.C. §§1441, 1443 and
1446.
WHEREFORE, the petitioners pray that the above action now pending in the
Superior Court of New Britain at New Britain be removed therefrom to this Court.

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DEFENDANTS,
KARISSA NIEHOFF AND
PAULA SCHWARTZ

By__/s/ Katherine E. Rule______________
Katherine E. Rule
ct27360
Howd & Ludorf, LLC
65 Wethersfield Avenue
Hartford, CT 06114
[phone]
[phone] (Fax)
E-Mail: [e-mail]

CERTIFICATION
This is to certify that a copy of the foregoing has been sent, handling charges
prepaid, via U.S. Mail, to the following counsel of record this 26th day of July, 2007.
Jon L. Schoenhorn, Esquire
Jon L. Schoenhorn & Associates, LLC
108 Oak Street
Hartford, CT 06106

_/s/ Katherine E. Rule________________
Katherine E. Rule

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