Hillstone Motion

Case 3:20-cv-01151-M Document 5 Filed 05/08/20 Page 1 of 3 PageID 138
IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
JANE DOE, §
§
Plaintiff, §
§
v. §
C.A. No. 3:20-CV-01151-M
§
HILLSTONE RESTAURANT GROUP, §
INC. D/B/A R+D KITCHEN, §
§
Defendant. §
DEFENDANT’S MOTION TO REMAND AND BRIEF IN SUPPORT
CERTIFICATE OF CONFERENCE
On May 8, 2020, at approximately 7:39 p.m., the undersigned emailed counsel for
Plaintiff, Brent Walker and Charla G. Aldous, to confer whether they oppose this Motion.
Attached as Exhibit A are the “read receipts.” A second email was sent at 9:00 p.m. As
of this filing we have not received a response. We will amend this certificate of conference
if a response is received.
Rogge Dunn
Defendant Hillstone Restaurant Group, Inc. d/b/a R+D Kitchen (hereinafter
DEFENDANT’S MOTION TO REMAND AND BRIEF IN SUPPORT Page 1

R:\3\3569\001\SubPldgs\Drafts\Motion to Remand.docx
“Defendant”) files this Motion to Remand and Brief in Support (the “Motion”), and states:
1. On May 7, 2020, Plaintiff Jane Doe (hereinafter “Plaintiff”) filed suit against
Defendant in the District Court of Dallas County, Texas. That same day, Defendant timely
removed this case to federal court.
2. Defendant no longer wishes to maintain this action in federal court, and
therefore files this Motion seeking to remand this case back to state court. Accordingly,
Defendant respectfully requests that the Court enter the Order of Remand submitted
herewith and remand this case to the District Court of Dallas County, Texas.
Respectfully submitted,
____________________
R. ROGGE DUNN
Texas Bar No. 06249500
E-mail: [email protected]
GREGORY M. CLIFT
State Bar No. 00795835
E-mail: [email protected]
ROGGE DUNN GROUP, PC

500 N. Akard Street, Suite 1900
Dallas, Texas 75201
Telephone: (214) 888-5000
Facsimile: (214) 220-3833
ATTORNEYS FOR DEFENDANT

CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing
instrument has been served on all counsel of record listed below via the Court’s e-filing
system on May 8, 2020:
Charla G. Aldous VIA ECF

[email protected]
Brent R. Walker
[email protected]
Aldous\Walker, LLP
4311 Oak Lawn Ave., Suite 150
Dallas, TX 75219
Chelsea Priest VIA EMAIL:

Law Clerk to Honorable Chief Judge [email protected]
Barbara M.G. Lynn
United States District Court for the
Northern District of Texas
Rogge Dunn

Case 3:20-cv-01151-M Document 5-1 Filed 05/08/20 Page 1 of 2 PageID 141

From: Charla Aldous <[email protected]>

To: Rogge Dunn
Sent: Friday, May 8, 2020 7:41 PM
Subject: Read: RE: Hillstone/Doe Second Confirmation of Compliance with the TRO
Your message
To: Charla Aldous

Subject: RE: Hillstone/Doe Second Confirmation of Compliance with the TRO
Sent: Friday, May 8, 2020 7:38:59 PM (UTC-06:00) Central Time (US & Canada)
was read on Friday, May 8, 2020 7:40:51 PM (UTC-06:00) Central Time (US & Canada).
1

From: Brent Walker <[email protected]>

To: Rogge Dunn
Sent: Friday, May 8, 2020 7:55 PM
Subject: Read: RE: Hillstone/Doe Second Confirmation of Compliance with the TRO
Your message
To: Brent Walker

Subject: RE: Hillstone/Doe Second Confirmation of Compliance with the TRO
Sent: Friday, May 8, 2020 7:38:59 PM (UTC-06:00) Central Time (US & Canada)
was read on Friday, May 8, 2020 7:54:56 PM (UTC-06:00) Central Time (US & Canada).
1
IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
JANE DOE, §
§
Plaintiff, §
§
v. §
§ C.A. No. 3:20-CV-01151-M
HILLSTONE RESTAURANT GROUP, §
INC. D/B/A R+D KITCHEN, §
§
Defendant. §
ORDER REMANDING CASE TO STATE COURT
Came on to be considered Defendant’s Motion for Remand [ECF No. 5] (the “Motion”).
After considering the Motion, the Court believes the Motion should be granted.
IT IS THEREFORE ORDERED that this case shall be remanded to the state court in which
it was originally filed, the 116th District Court, Dallas, Texas with costs taxed against the party
incurring same. The Clerk of Court is ordered to do all things necessary to effectuate the remand.
Signed this ___ day of _____________, 2020.
BARBARA M. G. LYNN
UNITED STATES DISTRICT CHIEF JUDGE
ORDER REMANDING CASE TO STATE COURT – Solo Page

\\RDPC-DC02\ROGGE\3\3569\001\SUBPLDGS\DRAFTS\2020-05-08 PROPOSED ORDER REMANDING.DOCX

Hillstone Motion

Uploaded by

Document Information

Original Description:

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Hillstone Motion

Uploaded by

Copyright:

Available Formats

Case 3:20-cv-01151-M Document 5 Filed 05/08/20 Page 1 of 3 PageID 138

IN THE UNITED STATES DISTRICT COURT

DEFENDANT’S MOTION TO REMAND AND BRIEF IN SUPPORT

Defendant Hillstone Restaurant Group, Inc. d/b/a R+D Kitchen (hereinafter

DEFENDANT’S MOTION TO REMAND AND BRIEF IN SUPPORT Page 1

removed this case to federal court.

2. Defendant no longer wishes to maintain this action in federal court, and

ROGGE DUNN GROUP, PC

ATTORNEYS FOR DEFENDANT

DEFENDANT’S MOTION TO REMAND AND BRIEF IN SUPPORT Page 2

Charla G. Aldous VIA ECF

Chelsea Priest VIA EMAIL:

DEFENDANT’S MOTION TO REMAND AND BRIEF IN SUPPORT Page 3

From: Charla Aldous <[email protected]>

To: Charla Aldous

From: Brent Walker <[email protected]>

To: Brent Walker

IN THE UNITED STATES DISTRICT COURT

ORDER REMANDING CASE TO STATE COURT

Signed this _ day of ___________, 2020.

ORDER REMANDING CASE TO STATE COURT – Solo Page

You might also like