C.R.W.B. v. City Of Chicago

Filing 1

NOTICE of Removal from Circuit Court of Cook County, Illinois, County Dept, Law Div, case number (2011 L 09818) filed by City Of Chicago and including copy of state court summons, complaint, and exhibits to complaint (Attachments: # 1 Exhibit State Court Summons & Complaint, # 2 Exhibit Exhibits attached to Complaint)(Graver, David)

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION
C.R.W.B. Corporation,

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Plaintiff,
v.
The City of Chicago,
Defendant.

Case No. 11-cv-7452

NOTICE OF REMOVAL
Defendant City of Chicago (“City”), by its attorney, Stephen R. Patton, Corporation Counsel,
removes the captioned action to this Court pursuant to 28 U.S.C. §§ 1441 and 1446 and in support
states:
1.

Plaintiff C.R.W.B. Corporation filed this action in the Circuit Court of Cook County,

Illinois, County Department, Law Division, Case No. 2011 L 009818, entitled C.R.W.B. Corporation
v. The City of Chicago.
2.

The City was served with summons and a copy of the Complaint on September 22,

2011. A copy of the Summons and Complaint along with its exhibits is attached hereto as Exhibit
1.
3.

The Complaint alleges causes of action against the City under the U.S. Constitution.

See Ex. 1, Complaint, Counts I & V.
4.

The City is entitled to remove this action pursuant to 28 U.S.C. § 1441(b), which

provides in relevant part that “any civil action of which the district courts have original jurisdiction
founded on a claim or right arising under the Constitution, treaties or laws of the United States shall

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be removable. . . .” This Notice of Removal is timely under 28 U.S.C. § 1446(b).
5.

The Summons and the Complaint with its Exhibits A through C are the only pleadings

that Plaintiff has served in this action, and they have been attached to this Notice of Removal. See
Ex. 1.
6.

Promptly after filing this Notice of Removal, the City will file a copy of this Notice

of Removal with the Clerk of the Circuit Court of Cook County, Illinois, as required by 42 U.S.C.
§ 1446(d).
Wherefore, the City, by this Notice, removes the above-described action now pending in the
Circuit Court of Cook County, Illinois, County Department, Law Division, Case No. 2011 L 009818,
entitled C.R.W.B. Corporation v. The City of Chicago, to this United States District Court for the
Northern District of Illinois, Eastern Division.
Dated: October 20, 2011

Respectfully submitted,
Stephen R. Patton, Corporation Counsel for
the City of Chicago.
By: /s/ David Graver

MICHAEL DOLESH
DAVID GRAVER
City of Chicago Department of Law
Constitutional and Commercial Litigation Division
30 N. LaSalle Street, Suite 1230
Chicago, IL 60602
Phone: [phone] / 3244

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CERTIFICATE OF SERVICE
I, David Graver, an attorney, certify that I served a copy of the foregoing Notice of
Removal along with its Exhibit 1 on the party listed below by causing it to be placed in the U.S.
mail at 30 North LasSalle with proper postage affixed and addressed as shown below before 5:00
p.m. on October 20, 2011.
By: /s/ David Graver
Service List
Joseph J. Siprut
Siprut PC
122 South Michigan Avenue
Suite 1850
Chicago, IL 60603