Brownstein et al v. Natick Residence, LLC et al

Filing 1

NOTICE OF REMOVAL by Natick Residence, LLC f/k/a GGP Natick Residence, LLC, The Howard Hughes Corporation from Middlesex Superior Court, case number 2011-03556g. ( Filing fee: $ 350, receipt number 0101-3652642 Fee Status: Filing Fee paid) (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Affidavit, # 4 Civil Cover Sheet, # 5 Civil Cover Sheet)(Sampson, Lindsay)

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
LINDA and MICHAEL BROWNSTEIN,
BERNADINE ANTONUCCI, JOHN R.
CHISHOLM, DENISE A. COLLINSON,
DIAN FOX-HINDLEY, ROBERT H. HAAS
and BRIGITTE HAAS-BRUINING,
STANLEY H. KONEFAL, JR. and JOAN M.
WALSH-KONEFAL, SANDRA and
MYRON LEVINE as Trustees of THE
LEVINE AT NOUVELLE REALTY
TRUST, CLAIRE SANDELL, ARLENE and
IRVIN STIGLITZ, MONIKA and VINEET
VERMANI,
Civil Case No. _______________
Plaintiffs,
v.
NATICK RESIDENCE, LLC f/k/a GGP
NATICK RESIDENCE, LLC, HOWARD
HUGHES CORPORATION, and AARON
BARTELS,
Defendants.
DECLARATION OF PETER RILEY
IN SUPPORT OF NOTICE OF REMOVAL
I, Peter Riley, declare as follows:
1.

I am Senior Vice President, Secretary and General Counsel for Natick Residence,

LLC f/k/a GGP Natick Residence, LLC (“Natick Residence”) and The Howard Hughes
Corporation (“HHC”).
2.

Natick Residence is currently, and was at the time the Complaint was filed in the

above-captioned action, a Delaware limited liability company with its principal place of business
in Dallas, Texas. The sole member of Natick Residence is The Howard Research and
Development Corporation (“Howard Research and Development”). Howard Research and

Development is currently, and was at the time the Complaint was filed in the above-captioned
action, a corporation incorporated, organized, and existing under the laws of the state of
Maryland, with its principal place of business in Dallas, Texas.
3.

HHC is currently, and was at the time the Complaint was filed in the above-

captioned action, a corporation incorporated, organized, and existing under the laws of the State
of Delaware with its principal place of business in Dallas, Texas.
I declare under penalty of perjury, under the laws of the United States of America, that
the foregoing is true and correct.

EXECUTED on this 1st day of November, 2011.

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/s/Peter Riley
Peter Riley

CERTIFICATE OF SERVICE
I hereby certify that this document filed through the ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic Filing (NEF),
and paper copies will be sent by United States First Class Mail, postage prepaid, to those
indicated as non-registered participants as set forth below, on this 1st day of November 2011.
By First Class Mail:

By First Class Mail:

Tyler E. Chapman
[e-mail]
Michael Thad Allen
[e-mail]
Todd & Weld, LLP
28 State Street, 31st Floor
Boston, MA 02109
[phone]

Martin M. Fantozzi
[e-mail]
Jonathan E. Small
[e-mail]
Goulston & Storrs
400 Atlantic Avenue
Boston, MA 02110-3333
[phone]

/s/Lindsay S. Bishop
Lindsay S. Bishop

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