Jeffrey Steven Jackson
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P.O. Box 3174
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Liverpool, NY 13089
Phone | Fax
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Plaintiff in pro per
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IN THE NEW YORK STATE SUPREME COURT
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FOR THE COUNTY OF ONONDAGA
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JEFFREY STEVEN JACKSON,
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Plaintiff,
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vs.
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THE BUREAU OF NATIONAL AFFAIRS, INC.; STF SERVICES CORP.; BLOOMBERG
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L.P.; ND MICHAEL R. BLOOMBERG, AND 15
THE UNITED STATES OF AMERICA 16
Defendant
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TO THE HONORABLE COURT
Case No.: Number
NOTICE OF REMOVAL OF STATE COURT ACTION TO UNITED STATES DISTRICT COURT
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PLEASE TAKE NOTICE that Plaintiff Jeffrey Steven Jackson has removed to the United States
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District Court for the Northern District of New York all claims and causes of action in the civil 21
action styled Jeffrey S. Jackson v. The Bureau of National Affairs, Inc. et. al., Case No. SU-2020- 22
005022 (the “State Court Action”) now pending in the New York State Supreme Court, County of 23
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Onondaga at Anchorage pursuant to New York Civil Practice Law & Rules § 325 which states as
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follows: “Grounds for removal. (a) By supreme court for mistake in choice of court. Where a
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mistake was made in the choice of the court in which an action is commenced, the supreme court, 27
upon motion, may remove the action to the proper court, upon such terms as may be just.” A copy 28
NOTICE OF REMOVAL OF STATE COURT ACTION TO UNITED STATES DISTRICT COURT – 1
of all process, pleadings and orders served upon defendants to date in the State Court Action are 1
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attached as Exhibit 1.
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Plaintiff’s grounds for removal are as follows:
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1. This State Court Action is removable to the United States District Court, for the Northern 5
District of New York, pursuant to 28 U.S.C. §1441 as Plaintiff’s cause of action is a 6
federal question arising under the laws of the United States, specifically, the Civil Rights 7
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Act of 1964, 42 U.S. Code § 1981(a).
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2. Plaintiff alleges that during his employment by Defendants, Defendants violated § 10
1981(a) by subjecting him to disparate treatment and race. Accordingly, this matter 11
presents a federal question and removal is appropriate under 28 U.S.C. § 1441(a). 12
3. The facts alleged by Plaintiff and the remedies he seeks show that the cause of action is 13
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essentially for the tort of intentional infliction of emotional distress, therefore constituting
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a federal question that arises under the Federal Tort Claims Act (FTCA), 28 U.S. Code § 16
1346.
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4. The Federal Tort Claims Act provides the exclusive remedy for money damages against 18
Defendants arising from alleged torts. 28 U.S. Code § 1346 (a)(2).
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5. Claims under the Federal Tort Claims Act are within the exclusive federal question
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jurisdiction of the United States courts. 28 U.S. Code § 1346 (b). As such, the State Court 22
Action is removable to the United States District Court, for the Northern District of New 23
York.
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6. The United States District Court, for the Northern District of New York, has both 25
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personal and subject matter jurisdiction over all parties.
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REASONS WHEREFORE, Plaintiff respectfully requests this Honorable Court to exercise its 28
NOTICE OF REMOVAL OF STATE COURT ACTION TO UNITED STATES DISTRICT COURT – 2
jurisdiction under New York Civil Practice Law & Rules § 325 and remove this matter to the 1
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United States District Court, for the Northern District of New York.
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Dated this ____ day of _________________, 2021.
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Respectfully Submitted,
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___________________________________
Jeffrey Steven Jackson,
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Plaintiff in pro per
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NOTICE OF REMOVAL OF STATE COURT ACTION TO UNITED STATES DISTRICT COURT – 3
EXHIBIT 1
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NOTICE OF REMOVAL OF STATE COURT ACTION TO UNITED STATES DISTRICT COURT – 4
VERIFICATION
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I, Jeffrey Steven Jackson, being duly sworn depose and say that I am the Plaintiff in the above
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entitled action, that I have read the foregoing Notice of Removal and know the contents thereof. 4
That the same is true of my own knowledge except as to those matters and things stated upon 5
information and belief, and as to those things, I believe them to be true.
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_________________________________
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(Sign in the presence of a Notary Public)
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Sworn to and subscribed before me this _____ day of ____________________, 2021. 10
______________________________
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Notary Public
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________________________________________
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(Printed name of Notary Public)
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My Commission Expires: ____________________
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NOTICE OF REMOVAL OF STATE COURT ACTION TO UNITED STATES DISTRICT COURT – 5
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