Harrison v. Bayer Corporation et al

Filing 1

NOTICE OF REMOVAL from Darlington County Court of Common Pleas, case number 2010-CP-16-0392 (filing fee $350 receipt number 0420-2860729), filed by Bayer AG, Bayer Healthcare LLC, Berlex Inc, Bayer Pharmaceuticals Corporation, Bayer Healthcare Pharmaceuticals Inc, Bayer Corporation, Berlex Laboratories Inc, Bayer Schering Pharma AG. (Attachments: # 1 State Court Documents, # 2 MDL Transfer Order, # 3 Berlex Name Change, # 4 Notice of Filing Notice of Removal) (hcic) [Transferred from South Carolina on 9/7/2010.]

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA FLORENCE DIVISION Theresa Dubose Harrison, Plaintiff, vs. Bayer Corporation, Bayer Healthcare, LLC, Bayer Pharmaceuticals Corporation, Bayer Healthcare Pharmaceuticals, Inc., Berlex Laboratories, Inc., Berlex, Inc., Bayer Schering Pharma AG, and Bayer AG, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) )

NOTICE OF FILING OF NOTICE OF REMOVAL C.A. No.: _______________________

TO:

J. THOMAS McBRATNEY, III, ESQ., and JAMES T. McBRATNEY, JR., ESQ., ATTORNEYS FOR PLAINTIFF PLEASE TAKE NOTICE that Defendants Bayer Corporation, Bayer HealthCare LLC,

and Bayer HealthCare Pharmaceuticals Inc., formerly known as Berlex, Inc., formerly known as Berlex Laboratories, Inc., on its own behalf and as successor by merger to Bayer Pharmaceuticals Corporation ("Bayer Defendants"), have filed in the office of the Clerk of Court of the United States District Court for the District of South Carolina, Florence Division, a Notice of Removal in the above-captioned case, together with a copy of the Summons and Complaint on the 30th day of July, 2010. Copies of the Notice of Removal are attached hereto and copies of the removal papers will be duly filed in the office of the Clerk of Court of the Darlington County Court of Common Pleas.

s/ Laura T. McDonald Daniel B. White (Fed. ID No. 4612) Laura T. McDonald (Fed. ID No. 9285) GALLIVAN, WHITE & BOYD, P.A. 55 Beattie Place, Suite 1200 P.O. Box 10589 Greenville, SC 29603 [phone] [phone] (fax) [e-mail] [e-mail] Attorneys for Defendants Bayer Corporation, Bayer HealthCare LLC, and Bayer HealthCare Pharmaceuticals Inc., f/k/a Berlex, Inc., f/k/a Berlex Laboratories, Inc., on its own behalf and as successor by merger to Bayer Pharmaceuticals Corporation

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