Ronan's Answer and Counterclaim
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.