Notice of Removal

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF CALIFORNIA

SINDEELOU THOMSON,
Plaintiff,

v.

JOHN DOOLITTLE,
Defendant.

NOTICE OF REMOVAL OF DEFENDANT JOHN DOOLITTLE

Pursuant to 28 U.S.C. § 1446, defendant John Doolittle, U.S. Representative for California’s 4th Congressional District, hereby gives notice that the above action is removed from the Superior Court of California, County of Placer, where it was originally filed, to the U.S. District Court for the Eastern District of California. The attached Complaint, which gives rise to this removal petition, was filed by plaintiff in the Superior Court of California, County of Placer on or about July 5, 2007. The Congressman received the complaint in Washington, D.C. on July 9, 2007.

-2-
Jurisdiction

The grounds for this removal petition are 28 U.S.C. § 1442(a)(1) inasmuch as Congressman Doolittle is a Member of the United States House of Representatives and the claims asserted against him appear to arise out of alleged actions taken, if at all, in his official capacity as a Member of the House, in furtherance of the performance of his official duties, and while acting within the scope of his office.

Copies of all pleadings delivered to Congressman Doolittle’s district office are attached hereto.

Respectfully submitted,

GERALDINE R. GENNET
General Counsel

KERRY W. KIRCHER
Deputy General Counsel

/s/ Christine Davenport, Esquire
CHRISTINE DAVENPORT
Assistant Counsel

Counsel for Defendant John Doolittle

AttachmentDateSize
[file] RemovalNotice.pdf06/28/09 1:05 pm10.31 KB
[file] CivilCoverSheet.pdf06/28/09 1:05 pm82.63 KB
[file] complaint.pdf06/28/09 1:05 pm373.46 KB

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