Document 91pVrLepYpxJajO05V4R94M15
P.rnrul Sr>^nff Rirrn
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Sroloff & B; rcn
Suite 1020
35.iO \\ tlflfure BoiilrvAnl
Lo Aii^Im, California 90010 (213) 380-3140
February 23, 1979
Anthony F. Dragonetts, Esq. Riston & Nance P. O. Box 2220 Tustin, Ca. 92680
Of Counwrl
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Oratt^r Count y Offin
Suite 2<U 1937 \\7. Clupnuii Aw
Or*nev Cj 92668 (714) 771-1740 (213) 437-6200
Re: Antonio toner v. Doe I, et al.'
Dear Mr. Dragonette:
Enclosed, for your information, is the following:
(1) A copy of the Change of Name indicating the correct name of Sroloff & Biren;
(2) A copy of the Petition for Removal? as indicated the Federal Court case bears Civil Number 78-2591-LEW (Px).
Very truly yours.
<r
MATTHEW B. F. BIREN
MBFBiam
cc: Gordon F. Sausser, Esq. Uniroyal
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f 'PACK BLLOW yOH FIL1SC STAMP ONLY* _!
SROLOFF & BIREN
ATTORNSrS AT LAW
1 SUITE 1020 IbSOWlllMin 30ULCVARD
LOS ANGELES. CALIFORNIA BOOIO
2 <2131 3B0.3I40
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4 Plaintiff. Attorneys for_______________
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6 UNITED STATES DISTRICT COURT 7 CENTRAL DISTRICT OF CALIFORNIA
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9 ANTONIO ROMERO,
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Plaintiff,
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11 vs.
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12 DOE I, DOE II, DOE III,
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DOE IV, DOE V, 13
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Defendants. )
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Case No. CV 78 2591 LEW (Px)
NOTICE OF CEANGE OF NAME OF COUNSEL
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15 TO: ALL PARTIES AND THEIR COUNSEL OF RECORD
16 PLEASE TAKE NOTICE that the firm of SROLOFF, BIREN & HJELT 17 has changed its name to SROLOFF & BIREN. The address and 18 telephone number remain the same. All correspondence and
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19 communications should be directed in accordance with the foregoing.
20 Dated: February 20, 1979 21 22 23 24
SROLOFF & BIREN
By; MATTHEW B. F. BIREN Attorneys for Plaintiff.
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I, the undersigned, certify and declare thatl am a citizen of the United States, over the age of 18 years, employed in the County of Los Angeles, State of California, and not a party to the within action- On
February 20, 1979 the attacr.ed
_____________, I served a true cooy of
- NOTICE OF CHANCE OF NAME OF COUNSEL
, . : .-Detencant.. ~
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on the - - - ? - * -in said action by placing
said copy thereof enclosed in a sealed envelope with '
" postage thereon fully prepaid, in the United States mail
in the City of Los Angeles, County of Los Angeles, State
of California, addressed as follows;
George W. Fulton, Jr., Esq. -Schell & Delamer
. 1200 Wislhire Blvd-, Suite 500 Los Angeles, Ca. 90017
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and there is regular communication by mail between the place of mailing and the place so addressed-
I hereby certify that I am employed in the office of a member of the Bar of this Court at whose direction the service was made.
Executed on Fsbruary 20, 1979
at Los Angeles,
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1 GEORGE W. FULTON, JR. SCHELL DELAMER
2 1200 Wilshire Boulevard, Suite 500
Los Angeles, California 90017 5 (213) 481-1140
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5 Attorneys for Defendant, THE IMCO CONTAINER COMPANY, a Division of The Ethyl Development
6 Corporation, a Delaware Corporation, sued
herein as DOE II 7
8 UNITED STATES DISTRICT COURT
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9 CENTRAL DISTRICT OF CALIFORNIA
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11 ANTONIO ROMERO,
12 Plaintiff,
15 v.
14 DOE I, DOE II, DOE III, DOE IV, DOE V,
15 Defendants.
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no. CV
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PETITION FOR REMOVAL
URL 14058
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18 TO THE JUDGES OF THE UNITED STATES DISTRICT COURT FOR THE
19 CENTRAL DISTRICT OF CALIFORNIA:
20 The Petition of THE IMCO CONTAINER COMPANY, a Division 21 of The Ethyl Development Corporation, a Delaware Corporation, 22 sued herein as DOE II, respectfully shows: 23 1. On or about the 9th day of June, 1978, an action 24 was commenced against Petitioner in the Superior Court of the
25 State of California, in and for the County of Los Angeles, 26 entitled ANTONIO ROMERO v, DOE I, DOE II, DOE III, DOE IV, DOE V,
27 No. NCC 121 27B, by service upon Petitioner of a summons and
28 complaint on said date, copies of which are annexed hereto as
1 Exhibit "A" and Exhibit *'B", respectively. The Dow Chemical
2 Corporation was sued herein as DOE I. However, they were dismissed
3 with prejudice on June 21, 1978. There are no other defendants
4 and no further proceedings have been had therein.
5 2. The above described action is a civil action of 6 which this Court has original jurisdiction under the provisions
7 of Title 28, United States Code, Section 1332 {Diversity of
8 CitizenshipJ, and is one which may be removed to this Court by 9 the Petitioner, Defendant herein, purs'uant to the provisions of
10 Title 28, United States Code, Section 1441, in that it is a civil 11 action wherein the matter in controversy exceeds the sum or value 12 of $10,000 exclusive of interest and costs, and is between
13 citizens of different states.
14 The Plaintiff ANTONIO ROMERO at the time this action
15 was commenced, was and still is, a citizen of the State of
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ie California; but the Defendant THE IMCO CONTAINER COMPANY, a
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Division of The Ethyl Development Corporation, was at the time this action was commenced, and still is, a Delaware Corporation,
19 with its principal place of business in Virginia, and was not
20 and is not a citizen of the State-of California wherein this 21 action was brought. 22 3. Petitioner files herewith a bond with good and
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25 sufficient surety conditioned, as provided by Title 28, United
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24 States Code, Section 1446(d), that it will pay all costs and
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25 disbursements incurred by reason of the removal proceedings 26 hereby brought should it be determined that this action is not 27 removable or is improperly removed.
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URL 14080
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1 WHEREFORE Petitioner prays that the above action now
2 sending against it in the Superior Court of the State of 3 California, in and for the County of Los Angeles, be removed
4 therefrom to this Court. 5 DATED: July 7, 1978. 6 SCHELL DELAMER
7 8 By
~"Z GEETRGE W. FULTON, JR7/ 9 Attorneys for Defendant, TaE
IMCO CONTAINER COMPANY, a 10 Division of The Ethyl Develop
ment Corporation, a Delaware 11 Corporation, sued herein as
DOE II 12
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