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CHAPTER 32

A Change of Forum

Ronan Removes to Federal Court

THE DRAFTING REQUEST

MEMORANDUM

TO: Marcia Losordo Associate

FROM: Arthur Ackerman

RE: Schulansky v. Ronan Plymouth Superior Court No. 2011-2982

DATE: December 19, 2011

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As you know, this office frequently handles litigation for Federal Security Insurance Company, a large insurer specializing in construction accounts. Federal Security has just asked us to represent one of their insureds, a New Hampshire contractor named Richard Ronan. On December 10, Ronan was served with process in a suit commenced against him and Ronan Construction Company in the Plymouth Superior Court. Copies of the complaint and summons are attached.

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