Tronsen v. Toledo-Lucas County Public Library

Filing 149

IN UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION AUTOMATED SOLUTIONS CORPORATION, Plaintiff vs. PARAGON DATA SYSTEMS INC., Defendant ) ) ) ) ) ) ) ) ) ) ) CASE NO. 1:05 CV 1519 JUDGE LESLIE BROOKS WELLS Magistrate Judge Hemann DEFENDANT PARAGON DATA SYSTEMS, INC.'S SUPPLEMENT TO THE NOTICE OF REMOVAL

NOW COMES Defendant Paragon Data Systems, Inc. ("Paragon"), by and through its undersigned counsel, and hereby supplements its May 31, 2005 Notice of Removal [ECF No. 1] with the following: 1) 2) 3) Order Granting Plaintiff Automated Solutions Corporation's Motion for Designation of Process Server (Exhibit "A"); Subpoena Duces Tecum served upon the Plain Dealer Publishing Co., and proof of service of same (Exhibit "B"); Plaintiff Automated Solutions Corporation's First Request for Production of Documents Propounded upon Defendant Paragon Data Systems, Inc. (Exhibit "C"); and, Plaintiff Automated Solutions Corporation's First Set of Interrogatories Propounded upon Defendant Paragon Data Systems, Inc. (Exhibit "D").

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Respectfully submitted, s/Timothy J. Fitzgerald JAMES F. KOEHLER (0007904) TIMOTHY J. FITZGERALD (0042374) GALLAGHER SHARP Sixth Floor - Bulkley Building 1501 Euclid Avenue Cleveland, Ohio 44115 [phone] (Telephone) [phone] (Fax) [e-mail] [e-mail] Attorneys for Defendant Paragon Data Systems, Inc. CERTIFICATE OF SERVICE A copy of the foregoing Defendant Paragon Data Systems, Inc.'s Supplement to the Notice of Removal was filed electronically on the 1st day of December 2005. Notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's electronic filing system. s/Timothy J. Fitzgerald JAMES F. KOEHLER (0007904) TIMOTHY J. FITZGERALD (0042734) Attorneys for Defendant Paragon Data Systems, Inc.

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