Stuntebeck v. Janssen Research & Development, LLC et alMOTION to RemandE.D. Pa.March 26, 2014UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA PLAINTIFF VIRGINIA G. STUNTEBECK’S, NOTICE OF MOTION TO REMAND PURSUANT TO 28 U.S.C. § 1447(c) Plaintiff Virginia G. Stuntebeck, by and through counsel, respectfully moves to Remand the Plaintiff’s Complaint to the Court of Common Pleas of Philadelphia County, where it was originally and properly filed, as the Defendant’s removal violates 28 U.S.C.A. § 1441(b), is otherwise procedurally infirm and for the reasons to be set forth in an accompanying Memorandum of Law. A proposed form or Order is attached hereto as Exhibit “A”. Dated: March 26, 2014 Respectfully submitted, NAPOLI BERN RIPKA SHKOLNIK & ASSOC., LLP VIRGINIA G. STUNTEBECK, Plaintiff, v. JANSSEN RESEARCH & DEVELOPMENT, LLC f/k/a JOHNSON AND JOHNSON PHARMACEUTICAL RESEARCH AND DEVELOPMENT LLC.; JANSSEN ORTHO, LLC, JANSSEN PHARMACEUTICALS, INC. f/k/a JANSSEN PHARMACEUTICA INC., f/k/a ORTHO-MCNEIL-JANSSEN PHARMACEUTICALS, INC., BAYER CORPORATION, BAYER AG, BAYER HEALTHCARE LLC, and BAYER HEALTHCARE PHARMACEUTICALS INC., and JOHN DOES 1-100, Defendants. C.A. No. 2:14-cv-01097-JHS Jury Trial Demanded Case 2:14-cv-01097-JHS Document 9 Filed 03/26/14 Page 1 of 2 By: /s/ W. Steven Berman___________ W. Steven Berman, Esquire (PA # 45927) One Greentree Center, Suite 201 10,000 Lincoln Dr. E. Marlton, NJ 08053 856-988-5574 Email: wsberman@nkblaw.com Attorneys for Plaintiff Case 2:14-cv-01097-JHS Document 9 Filed 03/26/14 Page 2 of 2
