State of New Hampshire v. Purdue Pharma L.P. et al

Filing 1

NOTICE OF REMOVAL from Merrimack County Superior Court, NH, case number 217-2017-CV-00402 (filing fee $400, receipt number 0102-1561627) filed by The Purdue Frederick Company Inc., Purdue Pharma Inc., Purdue Pharma L.P.. Answer Follow Up on 10/6/2017. The court only follow up date DOES NOT include 3 additional days that may apply per FRCP 6(d) and FRCrP 45(c). State Court Record Follow Up 9/29/2017. (Attachments: # 1 Exhibit A: State Court Docket and Redacted Complaint, # 2 Exhibit B: Notice of Conventional Filing, # 3 Exhibit C: Notice of Removal to Counsel, # 4 Exhibit D: Notice of Removal to State Court, # 5 Civil Cover Sheet) Complaint includes a claim under the NH Consumer Protection Act. A copy of the Complaint has been sent to the NH Attorney General via an automatic Notice of Electronic filing.(Deane, W.)

EXHIBIT C

THE STA1E OF NEW HAMPSHIRE
SUPERIOR COURT

MERRIMACK, SS.
State of New Hampshire
v.
Purdue Pharma L.P.;
Purdue Pharma Inc.; and
The Purdue Frederick Company Inc.
Case No. 217-2017-CV-00402

NOTICE OF FILING OF NOTICE OF REMOVAL (TO PLAINTIFF)
PLEASE TAKE NOTICE that on September 15, 2017, pursuant to the provisions of Title
28 U.S.C. §§ 1331, 1332, 1441, 1446, and 1453, the Defendants Purdue Pharma L.P., Purdue
Pharma Inc., and The Purdue Frederick Company Inc. (collectively, "Purdue"), by and through
their counsel, Nixon Peabody LLP, filed in the United States District Court for the District of
New Hampshire a Notice of Removal of the above-captioned action.
True and correct copies of the Notice of Removal and the Notice of Filing Notice of
Removal, which is being contemporaneously filed with the Merrimack Superior Court, will be
served on counsel for Plaintiff.
Respectfully Submitted,
Purdue Pharma L.P.;
Purdue Pharma Inc.; and
The Purdue Frederick Company Inc.
By and Through Their Attorneys,
NIXON PEABODY LLP
Dated: September 15, 2017
W. Daniel Deane, Esq.
NH Bar No. 18700
David A. Vicinanzo, Esq.
NH Bar No. 9403
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4816-0812-4751 1

Nixon Peabody LLP
900 Elm Street, 14th Floor
Manchester, NH 03101
T: [phone]
dvicinanzo(ibnixonpeabody.com
ddeanealnixonpeabociv.com
CERTIFICATE OF SERVICE
I hereby certify that on this 15th day of September, 2017, the foregoing Notice of Filing of
Notice of Removal (to Plaintiff) was served via e-mail and by United States first-class mail,
postage prepaid, to the following counsel of record for the Plaintiff:
James T. Boffetti, Esq.
Senior Assistant Attorney General
Chief, Consumer Protection
and Antitrust Bureau
Department of Justice
33 Capitol Street
Concord, NH 03301
iames.hoffettro,:do3.nh.gov

Linda J. Singer, Esq.
Motley Rice LLC
401 9th Street NW, Suite 1001
Washington, D.C. 20004
lsmgeromotleynce.cow

W. Daniel Deane, Esq.

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4816-0812-4751.1