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CHAPTER 33

The Defendants' Perspective

Ronan's Answer and Counterclaim

THE DRAFTING REQUEST

MEMORANDUM

TO: Marcia Losordo Associate

FROM: Arthur Ackerman

RE: Answer and counterclaim in Schulansky v. Ronan U.S. District Court No. 2011-6719

DATE: December 28, 2011

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Thank you for your informative memo and removal documents in this case. I have filed the notice of removal today and notified the plaintiff and the state court, so we are officially in federal court.

I have decided to file an answer to the complaint (instead of a Rule 12(b) motion) and would appreciate your assistance in drafting it. I realize that you have not yet had any Christmas vacation, but as your memo indicates, we are under the gun because Fed. R. Civ. P. 81(c)(2)(C) requires us to respond to the complaint within seven days of removing the case.

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