On February 17, 2024 a
Party Notice
was filed
involving a dispute between
Coulter, Ramsey,
and
Planet Home Lending Llc,
for NEGLIGENCE- OTHER
in the District Court of Madison County.
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Filing # 194235161 E-Filed 03/18/2024 01:37:42 PM
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MADISON COUNTY, FLORIDA
RAMSEY COULTER,
individually, and on behalf of other similarly
situated consumers,
Case No. 192182843
Plaintiff,
VS.
PLANET HOME LENDING, LLC,
Defendant.
/
NOTICE OF REMOVAL TO FEDERAL COURT
PLEASE TAKE NOTICE THAT on March 18, 2024, Defendant Planet Home Lending,
LLC (“PHL”) removed this action to the United States District Court for the Northern District of
Florida, Tallahassee Division. You are also advised that PHL, on filing the Notice of Removal in
the Office of the Clerk of the United States District Court for the Northern District of Florida, also
filed a copy of it with the Clerk of the Circuit Court, in and for Madison County, Florida, to
effectuate removal, pursuant to 28 U.S.C. § 1446(d). A copy of the Notice of Removal is attached
hereto as Exhibit A.
Further, this Court is requested to take no further actions and to stay all proceedings before
this Court, pursuant to 28 U.S.C. 1446(d), unless and until further Order is forthcoming from the
Federal Court.
Electronically Filed Madison Case # 2024000019CAAXMX 03/18/2024 01:37:42 PM
Respectfully submitted this 18th day of March 2024.
/s/ Diana Marie Fasshender
Diana Marie Fassbender
Florida Bar No. 0017095
ORRICK, HERRINGTON & SUTCLIFFE LLP
1152 15" St. N.W.
Washington, D.C. 20005
202-339-8533
dszego@orrick.com
Attorneys for Defendant PHL
CERTIFICATE OF SERVICE
I hereby certify that on this 18th day of March 2024, the foregoing document was
served on counsel of record for Plaintiff Ramsey Coulter, listed below, via email and
certified mail:
Matthew Fornaro, P.A.
Florida Bar No. 650641
11555 Heron Bay Blvd., Ste. 200
Coral Springs, FL 33076
(954) 324-3651
mfornaro@fornarolegal.com
Counsel for Plaintiff Ramsey Coulter
/s/ Diana Marie Fassbender
Diana Marie Fassbender
Document Filed Date
March 18, 2024
Case Filing Date
February 17, 2024
Category
NEGLIGENCE- OTHER
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Filing # 194235161 E-Filed 03/18/2024 01:37:42 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MADISON COUNTY, FLORIDA RAMSEY COULTER, individually, and on behalf of other similarly situated consumers, Case No. 192182843 Plaintiff, VS. PLANET HOME LENDING, LLC, Defendant. / NOTICE OF REMOVAL TO FEDERAL COURT PLEASE TAKE NOTICE THAT on March 18, 2024, Defendant Planet Home Lending, LLC (“PHL”) removed this action to the United States District Court for the Northern District of Florida, Tallahassee Division. You are also advised that PHL, on filing the Notice of Removal in the Office of the Clerk of the United States District Court for the Northern District of Florida, also filed a copy of it with the Clerk of the Circuit Court, in and for Madison County, Florida, to effectuate removal, pursuant to 28 U.S.C. § 1446(d). A copy of the Notice of Removal is attached hereto as Exhibit A. Further, this Court is requested to take no further actions and to stay all proceedings before this Court, pursuant to 28 U.S.C. 1446(d), unless and until further Order is forthcoming from the Federal Court. Electronically Filed Madison Case # 2024000019CAAXMX 03/18/2024 01:37:42 PM Respectfully submitted this 18th day of March 2024. /s/ Diana Marie Fasshender Diana Marie Fassbender Florida Bar No. 0017095 ORRICK, HERRINGTON & SUTCLIFFE LLP 1152 15" St. N.W. Washington, D.C. 20005 202-339-8533 dszego@orrick.com Attorneys for Defendant PHL CERTIFICATE OF SERVICE I hereby certify that on this 18th day of March 2024, the foregoing document was served on counsel of record for Plaintiff Ramsey Coulter, listed below, via email and certified mail: Matthew Fornaro, P.A. Florida Bar No. 650641 11555 Heron Bay Blvd., Ste. 200 Coral Springs, FL 33076 (954) 324-3651 mfornaro@fornarolegal.com Counsel for Plaintiff Ramsey Coulter /s/ Diana Marie Fassbender Diana Marie Fassbender