On August 13, 2021 a
NOTICE OF REMOVAL / REMAND (PRE RJI) Notice of Filing of Notice of Removal of Action to the United States District Court for the Northern - Notice of Filing of Notice of Removal of Action to the United States District Court for the Northern ... show more
was filed
involving a dispute between
Eric Eckardt,
and
The Radian Group, Inc.,
for Commercial - Contract
in the District Court of Saratoga County.
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FILED: SARATOGA COUNTY CLERK 08/19/2021 03:16 PM INDEX NO. EF20212436
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 08/19/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SARATOGA
ERIC ECKARDT,
Index No. EF2021-2436
Plaintiff,
DEFENDANT’S NOTICE OF
-against-
REMOVAL
THE RADIAN GROUP, INC.,
Electronically Filed
Defendant.
NOTICE OF FILING OF NOTICE OF REMOVAL OF ACTION TO THE UNITED
STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF NEW YORK
TO: Clerk of Supreme Court
Supreme Court of the State of New York
County of Saratoga
Saratoga County Municipal Center
30 McMaster Street – Building 3
Ballston Spa, New York 12020
PLEASE TAKE NOTICE that, on August 18, 2021, Defendant Radian Group Inc.
(incorrectly captioned herein as “The Radian Group, Inc.”; hereinafter “Radian” or
“Defendant”), by and through its counsel, Morgan Lewis & Bockius LLP, filed the attached
Notice of Removal, a true copy of which is annexed hereto as Exhibit A, thereby removing the
above-captioned action from the Supreme Court of the State of New York, County of Saratoga,
to the United States District Court for the Northern District of New York.
PLEASE TAKE FURTHER NOTICE that Defendant, upon filing the Notice of
Removal in the office of the Clerk of the United States District Court for the Northern District of
New York, hereby files a copy thereof with the Chief Clerk of the Supreme Court of the State of
New York, County of Saratoga to effect removal pursuant to 28 U.S.C. §§ 1332, 1441, and 1446.
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FILED: SARATOGA COUNTY CLERK 08/19/2021 03:16 PM INDEX NO. EF20212436
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 08/19/2021
Because Defendant has filed such Notice of Removal, the Supreme Court of the State of New
York, County of Saratoga, may not proceed further with the above-captioned case.
Dated: August 19, 2021 Respectfully submitted,
/s/ Leora Grushka________________
Leora Grushka
MORGAN, LEWIS & BOCKIUS LLP
101 Park Avenue
New York, NY 10178
Tel: (212) 309-6000
Fax: (212) 309-6001
Email: leora.grushka@morganlewis.com
Attorneys for Defendant Radian Group Inc.
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FILED: SARATOGA COUNTY CLERK 08/19/2021 03:16 PM INDEX NO. EF20212436
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 08/19/2021
CERTIFICATE OF SERVICE
I hereby certify that on August 19, 2021, the foregoing Notice of Removal and Notice of
Removal filed in the United States District Court for the Northern District of New York, with
attached exhibits, were filed via the NYSCEF filing system and served by U.S. mail on the
following:
Scott C. Paton, Esq.
HODGSON RUSS LLP
677 Broadway, Suite 301
Albany, New York 12207
/s/ Leora Grushka
Leora Grushka
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Document Filed Date
August 19, 2021
Case Filing Date
August 13, 2021
Category
Commercial - Contract
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FILED: SARATOGA COUNTY CLERK 08/19/2021 03:16 PM INDEX NO. EF20212436 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 08/19/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SARATOGA ERIC ECKARDT, Index No. EF2021-2436 Plaintiff, DEFENDANT’S NOTICE OF -against- REMOVAL THE RADIAN GROUP, INC., Electronically Filed Defendant. NOTICE OF FILING OF NOTICE OF REMOVAL OF ACTION TO THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF NEW YORK TO: Clerk of Supreme Court Supreme Court of the State of New York County of Saratoga Saratoga County Municipal Center 30 McMaster Street – Building 3 Ballston Spa, New York 12020 PLEASE TAKE NOTICE that, on August 18, 2021, Defendant Radian Group Inc. (incorrectly captioned herein as “The Radian Group, Inc.”; hereinafter “Radian” or “Defendant”), by and through its counsel, Morgan Lewis & Bockius LLP, filed the attached Notice of Removal, a true copy of which is annexed hereto as Exhibit A, thereby removing the above-captioned action from the Supreme Court of the State of New York, County of Saratoga, to the United States District Court for the Northern District of New York. PLEASE TAKE FURTHER NOTICE that Defendant, upon filing the Notice of Removal in the office of the Clerk of the United States District Court for the Northern District of New York, hereby files a copy thereof with the Chief Clerk of the Supreme Court of the State of New York, County of Saratoga to effect removal pursuant to 28 U.S.C. §§ 1332, 1441, and 1446. 1 of 3 FILED: SARATOGA COUNTY CLERK 08/19/2021 03:16 PM INDEX NO. EF20212436 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 08/19/2021 Because Defendant has filed such Notice of Removal, the Supreme Court of the State of New York, County of Saratoga, may not proceed further with the above-captioned case. Dated: August 19, 2021 Respectfully submitted, /s/ Leora Grushka________________ Leora Grushka MORGAN, LEWIS & BOCKIUS LLP 101 Park Avenue New York, NY 10178 Tel: (212) 309-6000 Fax: (212) 309-6001 Email: leora.grushka@morganlewis.com Attorneys for Defendant Radian Group Inc. 2 2 of 3 FILED: SARATOGA COUNTY CLERK 08/19/2021 03:16 PM INDEX NO. EF20212436 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 08/19/2021 CERTIFICATE OF SERVICE I hereby certify that on August 19, 2021, the foregoing Notice of Removal and Notice of Removal filed in the United States District Court for the Northern District of New York, with attached exhibits, were filed via the NYSCEF filing system and served by U.S. mail on the following: Scott C. Paton, Esq. HODGSON RUSS LLP 677 Broadway, Suite 301 Albany, New York 12207 /s/ Leora Grushka Leora Grushka 3 3 of 3