UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

YVONNE ROSILLO,

Plaintiff,

v.

MARYAM SIDDIQUI, M.D., ACCESS

COMMUNITY HEALTH NETWORK,

AMARDEEP SINGH, M.D., LOUIS

SCRATTISH, M.D., PAULINA KUCHINIC,

M.D., MARIA ILLIESCU, M.D., BRIANA

SOUTHERLAND, M.D., SHUMAL

MALEPATI, M.D., SAQUIB ANJUM, M.D.,

PAM KHOSLA, M.D., ANDRES SERRANO,

M.D., WILLIAM TRAINOR, M.D., MOUNT

SINAI HOSPITAL MEDICAL CENTER OF

CHICAGO d/b/a MOUNT SINAI

HOSPITAL, SINAI HEALTH SYSTEM, and

THE MOUNT SINAI COMMUNITY

FOUNDATION d/b/a SINAI MEDICAL

GROUP,

Defendants.

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No. 12 C 5585

Formerly case No. 11 L 6767,

Circuit Court of Cook County, Illinois

NOTICE OF REMOVAL OF A CIVIL ACTION AND

SUBSTITUTION OF THE UNITED STATES AS DEFENDANT

To: Clerk of the Court

Circuit Court of Cook County

Richard J. Daley Center, Room 801

50 West Washington Street

Chicago, Illinois 60602

Terrence M. Quinn

Phillips Law Offices

161 North Clark Street, Suite 4925

Chicago, Illinois 60601

The United States, by its attorney, Gary S. Shapiro, Acting United States Attorney for the

Northern District of Illinois, submits this notice of removal of the above-captioned civil action from

the Circuit Court of Cook County, Illinois, to the United States District Court, Northern District of

Case: 1:12-cv-05585 Document #: 1 Filed: 07/17/12 Page 1 of 3 PageID #:1
Illinois, pursuant to the Federal Tort Claims Act (“FTCA”), 28 U.S.C. § 2679, and 42 U.S.C. § 233,

and in support thereof states the following:

1. On or about June 29, 2011, plaintiff Yvonne Rosillo commenced the above civil

action against Maryam Siddiqui, M.D., Amardeep Singh, M.D., Louis Scrattish, M.D., Paulina

Kuchinic, M.D., Maria Illiescu, M.D., Briana Southerland, M.D., Shumal Malepati, M.D., Saquib

Anjum, M.D., Pam Khosla, M.D., Andres Serrano, M.D., William Trainor, M.D., Mount Sinai

Hospital Medical Center of Chicago d/b/a Mount Sinai Hospital and Sinai Health System A copy

of the original state court complaint is attached as Exhibit A. An amended complaint added, among

others, Access Community Health Network as a defendant. Access Community Health Network is

a private entity that receives grant money from the Public Health Service pursuant to 42 U.S.C. §

233, and for purposes of this lawsuit, Maryam Siddiqui, M.D., was a physician for Access

Community Health Network.

2. This notice of removal is filed in accordance with 28 U.S.C. § 2679(d)(2) and 42

U.S.C. § 233 upon certification by the designee of the Attorney General of the United States that the

defendant Maryam Siddiqui, M.D., was acting within the scope of her employment as a federal

government employee at the time of the incidents out of which the claim arose. Exhibit B.

3. This notice of removal may be filed without bond at any time before trial. 28 U.S.C.

§ 2679(d)(2). Trial has not yet been had in this action.

4. Pursuant to the certification by the Attorney General’s designee and the filing of this

notice of removal, under 28 U.S.C. § 2679, this civil action is deemed an action against the United

States and the United States is substituted as the sole federal party defendant in place of defendants

Maryam Siddiqui, M.D. and Access Community Health Network. 

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Case: 1:12-cv-05585 Document #: 1 Filed: 07/17/12 Page 2 of 3 PageID #:2
WHEREFORE, this action now pending in the Circuit Court of Cook County, Illinois, is

properly removed to this court pursuant to 28 U.S.C. § 2679(d) and 42 U.S.C. § 233, and the United

States is substituted as a defendant in lieu of Maryam Siddiqui, M.D. and Access Community Health

Network.

Respectfully submitted,

GARY S. SHAPIRO

Acting United States Attorney

By: s/ Zachary D. Clopton

 ZACHARY D. CLOPTON

 Assistant United States Attorney

 219 South Dearborn Street

 Chicago, Illinois 60604

 (312) 353-6630

 zachary.clopton@usdoj.gov

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