Michael R. Nack v. Reed Elsevier, Inc.

Filing 1

NOTICE OF REMOVAL from Circuit Court of St. Louis County, MO, Twenty-First Judicial Circuit, case number 12SL-CC00991, with receipt number 0865-3263263, in the amount of $350 Jury Demand,, filed by Reed Elsevier, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Civil Cover Sheet, # 4 Original Filing Form)(Bynum, Theodore)

IN THE CIRCUIT COURT OF ST. LOUIS COUNTY, MISSOURI
TWENTY-FIRST JUDICIAL CIRCUIT
MICHAEL R. NACK, individually and on
behalf of all others similarly-situated,
Plaintiff,
V.

Case No. 12SL-CC00991
E.D. of MO Case No.

REED ELSEVIER, INC.,
Defendant.

NOTICE OF FILING NOTICE OF REMOVAL
TO: THE CLERK OF THE CIRCUIT COURT OF ST. LOUIS COUNTY, MISSOURI
PLEASE TAKE NOTICE that Defendant LexisNexis, a division of Reed Elsevier Inc.
(improperly named by Plaintiff as "Reed Elsevier, Inc.") by and through its undersigned counsel,
hereby gives notice that it has filed the attached copy of its Notice of Removal in the United
States District Court for the Eastern District of Missouri on May 2, 2012. Pursuant to 28 U.S.C.
§ 1446(d), the filing of this Notice effects the removal of this action to the United States District
Court for the Eastern District of Missouri, and this Court shall proceed no further unless the
action is remanded from the District Court.
DATED: May 2, 2012

Respectfully submitted,
HUSCH BLACKWELL LLP
By:
John T, Richmond, Jr, # 5673
[e-mail]
Theodore R. Bynum III #60897
[e-mail]
190 Carondelet Plaza, Ste. 600
St. Louis, MO 63105
[phone]

5LC-6621033-1

CERTIFICATE OF SERVICE
I hereby certify that on May 2, 2012, I caused a copy of NOTICE OF FILING NOTICE
OF REMOVAL to be served upon the following counsel of record by electronic and First Class
U. S . Mail:
Max. G. Margulis
MARGULIS LAW GROUP
28 Old Belle Monte Rd.
Chesterfield, MO 63017
[e-mail]
Brian J. Wanca
ANDERSON + WANCA
3701 Algonquin Rd., Ste. 760
Rolling Meadows, IL 60008
[e-mail]
Phillip A. Bock
Bock & Hatch, LLC
134 N. LaSalle
Chicago, IL 60602
[e-mail]

SLC-6621033-1

IN THE CIRCUIT COURT OF ST. LOUIS COUNTY, MISSOURI
TWENTY-FIRST JUDICIAL CIRCUIT
MICHAEL R. NACK, individually and on
behalf of all others similarly-situated,
Plaintiff,

Case No. 12SL-CC00991

V.
REED ELSEVIER, INC.,
Defendant.

CLERK'S CERTIFICATION

The undersigned hereby certifies that a file-stamped copy of the Notice of Removal filed
in the United States District Court for the Eastern District of Missouri by Defendant Reed
Elsevier, Inc. in the above-styled cause was filed with the Clerk of this Court on the 2nd day of
May, 2012.

CLERK,
Circuit Court of St. Louis County, Missouri
Twenty-First Judicial Circuit
By:
Deputy Clerk
Dated: May 2, 2012

5LC-6621033-1