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IN THE CIRCUIT COURT OF THE STATE OF OREGON

FOR THE COUNTY OF MULTNOMAH

BRANDON L. WINSLOW,

 Plaintiff,

v.

PROVIDENCE HEALTH & 

SERVICES - OREGON,

Defendant.

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Case No. 14CV16225

NOTICE TO CIRCUIT COURT 

CLERK OF REMOVAL OF ACTION 

TO THE UNITED STATES DISTRICT 

COURT FOR THE DISTRICT OF 

OREGON

TO: Clerk of the Circuit Court

Multnomah County Circuit Court

1021 SW 4th Avenue

Portland, Oregon 97204

PLEASE TAKE NOTICE that defendant caused to be filed on 

December 31, 2014, its Notice of Removal in the Portland Office of the clerk of 

the United States District Court for the District of Oregon pursuant to 28 U.S.C. § 

1446(a). A copy of the Notice of Removal (without exhibits) accompanies and is 

submitted with this Notice. 

Page 1 – Notice to Circuit Court Clerk of Removal of Action 

Druckman & Blatt, P.C.

0424 S.W. Iowa Street

Portland, Oregon 97239

Telephone: (503) 241-5033 | Facsimile: (503) 241-9033

Case 3:14-cv-02067-ST Document 1 Filed 12/31/14 Page 1 of 3
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The filing of the Notice effects the removal of this case and, pursuant 

to 28 USC § 1445(d), “the state court shall proceed no further unless and until the 

case is remanded.”

Dated this 31st day of December, 2014.

DRUCKMAN & BLATT, P.C.

s/Janine C. Blatt

Janine C. Blatt

OSB No. 922323

janine@jjdlaw.com

Attorney for Defendant

Page 2 – Notice to Circuit Court Clerk of Removal of Action 

Druckman & Blatt, P.C.

0424 S.W. Iowa Street

Portland, Oregon 97239

Telephone: (503) 241-5033 | Facsimile: (503) 241-9033

Case 3:14-cv-02067-ST Document 1 Filed 12/31/14 Page 2 of 3
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I hereby certify that I served the foregoing Notice to Circuit Court Clerk of 

Removal of Action to the United States District Court for the District of Oregon on:

Talia Y. Stoessel

Bennett, Hartman, Morris & Kaplan, LLP

210 S.W. Morrison St. Suite 500

Portland, Oregon 97204

stoesselt@bennetthartman.com

Attorney for Plaintiff

by the following indicated method or methods:

by mailing a full, true, and correct copy thereof in a sealed, first-class postage-prepaid 

envelope, addressed to the attorney as shown above, the last-known office address of 

the attorney, and deposited with the United States Postal Service at Portland, Oregon, 

on the date set forth below.

by causing a full, true, and correct copy thereof to be hand-delivered to the attorney at 

the attorney’s last-known office address listed above on the date set forth below.

by sending a full, true, and correct copy thereof via overnight courier in a sealed, 

prepaid envelope, addressed to the attorney as shown above, the last-known office 

address of the attorney, on the date set forth below.

by faxing a full, true, and correct copy thereof to the attorney at the fax number shown 

above, which is the last-known fax number for the attorney’s office on the date set 

forth below.

Dated this 31st day of December, 2014.

s/Janine C. Blatt

Janine C. Blatt

Attorney for Defendant

Page 1 – Certificate of Service

Druckman & Blatt, P.C.

0424 S.W. Iowa Street

Portland, Oregon 97239

Telephone: (503) 241-5033

Case 3:14-cv-02067-ST Document 1 Filed 12/31/14 Page 3 of 3