Page 1 of 3 – NOTICE OF REMOVAL The Rosen Law Firm, P.C. 

1000 SW Broadway, Suite 1220 

Portland, Oregon 97205 

Phone: (503) 525-2525; Fax: (503) 525-2526 

Steven O. Rosen, OSB #785009 

Rosen@RosenLawFirm.com 

Elizabeth M. Ferrarini OSB #944859 

Ferrarini@RosenLawFirm.com 

The Rosen Law Firm, P.C. 

1000 SW Broadway, Suite 1220 

Portland, OR 97205 

Telephone: (503) 525-2525 

Facsimile: (503) 525-2526 

Attorneys for Defendant 

Spirit Airlines, Inc.

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

TIMOTHY MEACHAM, 

 Plaintiff, 

v. 

SPIRIT AIRLINES INC. and; KERRIE 

CONRAD,

 Defendants. 

Case No. 3:15-cv-338 

NOTICE OF REMOVAL 

DEMAND FOR JURY TRIAL 

To: The Honorable Judges of the United States District Court for the District of 

Oregon, Portland Division, Mark O. Hatfield Courthouse, 1000 SW Third Avenue, 

Portland, Oregon 97204-2902; and to William Ball, Attorney William Ball, LLC, 

420 SW Washington, Suite 400, Portland, OR 97204.

Case 3:15-cv-00338-SI Document 1 Filed 02/25/15 Page 1 of 4
Page 2 of 3 – NOTICE OF REMOVAL The Rosen Law Firm, P.C. 

1000 SW Broadway, Suite 1220 

Portland, Oregon 97205 

Phone: (503) 525-2525; Fax: (503) 525-2526 

Pursuant to 28 U.S.C. §§ 1332 and 1441, defendant Spirit Airlines, Inc. 

submits this notice of removal from the Circuit Court of the State of Oregon for 

Multnomah County to the United States District Court for the District of Oregon 

on the grounds that:

1. Defendant Spirit Airlines, Inc. is a party in a civil action brought 

against it in the Circuit Court of the State of Oregon for Multnomah County 

entitled Timothy Meacham v. Spirit Airlines Inc. and Kerrie Conrad, Case No. 

15CV01985.

2. Plaintiff filed the complaint in the state court action, Timothy 

Meacham v. Spirit Airlines Inc. and Kerrie Conrad, with the clerk of the Circuit 

Court for the State of Oregon, County of Multnomah on January 29, 2015. A copy 

of the Summons and Complaint was served on Spirit Airlines, Inc. on January 30, 

2015. To the best of defendant Spirit Airlines, Inc.’s knowledge, information, and 

belief after a reasonable inquiry, defendant Kerrie Conrad has not yet been served. 

A copy of the Summons and Complaint in the state court action is attached to this 

Notice as Exhibit 1.

3. Plaintiff alleges that he is a resident of the State of Oregon.

4. Defendant Spirit Airlines, Inc. is a corporation organized and existing 

under the laws of the state of Delaware with its principal place of business in 

Miramar, Florida.

5. To the best of defendant Spirit Airlines, Inc.’s knowledge, 

information, and belief after a reasonable inquiry, Kerrie Conrad is a resident of 

the State of Washington.

6. This action is a civil action for personal injuries that allegedly 

occurred at Portland International Airport. Plaintiff's prayer for damages is 

$973,415, plus future medical costs and treatment, costs, and expenses.

Case 3:15-cv-00338-SI Document 1 Filed 02/25/15 Page 2 of 4
Page 3 of 3 – NOTICE OF REMOVAL The Rosen Law Firm, P.C. 

1000 SW Broadway, Suite 1220 

Portland, Oregon 97205 

Phone: (503) 525-2525; Fax: (503) 525-2526 

7. This action is one over which this court has original jurisdiction under 

28 U.S.C. § 1332, it is one that may be removed to this court by defendant Spirit 

Airlines, Inc. pursuant to the provisions of 28 U.S.C. § 1441, and it is a civil action 

wherein the matter in controversy exceeds $75,000, exclusive of interests and costs 

and is between citizens of different states.

8. Pursuant to Fed. R. Civ. P. 38(b), Spirit Airlines, Inc. demands a trial 

by jury.

WHEREFORE, Spirit Airlines, Inc. gives notice that the above-entitled 

action now pending against it in the Circuit Court of the State of Oregon for 

Multnomah County has been removed to this court.

DATED this 25th of February, 2015. 

 s/ Steven O. Rosen 

 Steven O. Rosen, OSB # 785009 

Rosen@RosenLawFirm.com 

Of Attorneys for Defendant Spirit Airlines, Inc. 

Case 3:15-cv-00338-SI Document 1 Filed 02/25/15 Page 3 of 4
Page 1 - Certificate of Service The Rosen Law Firm, P.C. 

1000 SW Broadway, Suite 1220 

Portland, Oregon 97205 

Phone: (503) 525-2525; Fax: (503) 525-2526 

 

 

CERTIFICATE OF SERVICE 

 I hereby certify that I served a copy of the foregoing NOTICE OF 

REMOVAL by the following indicated method or methods: 

 by mailing full, true, and correct copies thereof in sealed, 

 first-class postage-prepaid envelopes, addressed to the 

 attorney(s) as shown below, the last-known address(es) of the 

attorney(s) and deposited with the United States Postal Service 

at Portland, Oregon on the date set forth below. 

 by causing full, true, and correct copies thereof to be 

hand-delivered via messenger to the attorney(s) at the last-known 

 address(es) listed below on the date set forth below. 

 Notice of this filing will be sent by e-mail to all parties by operation 

 of the Court’s electronic filing system. Parties may access this filing 

 through the Court’s CM/ECF system. 

 

Mr. William Ball 

Attorney William Ball, LLC 

420 SW Washington, Suite 400 

Portland, OR 97204

Attorney for plaintiff Timothy Meacham 

 DATED this 25th day of February, 2015. 

 

 s/ Steven O. Rosen 

Steven O. Rosen, OSB #785009 

Case 3:15-cv-00338-SI Document 1 Filed 02/25/15 Page 4 of 4