Epstein Secrets

: LEAD ATTORNEY ATTORNEY TO BE NOTICED Michael Ross Tein Lewis Tein 3059 Grand Avenue Suite 340 C

the burden of establishing federal jurisdiction under § 1441 rests with the party seeking removal. Carson'. Dunham. 121 U.S. 421, 425 (1887); Diaz, Sheppard, 85 F.3d 1502, 1505 (11th Cir. 1996). The right of removal is strictly construed, as it is considered a federal infringement on a state's power to

. Comp. LEXIS 1044, On August 23, 2005, the claimant underwent an independent medical examination by Dr. Mark A. Ross, physiatrist. He informed Dr. Ross about the accident, his treatment, and that he had not improved since the injury. The claimant complained of suffering constant pain, ranging from

No. 02CA43, 2003 Ohio 4836, at P28; Brouse v. Old Phoenix Natl. Bank of Medina (1985), 25 Ohio App. 3d 9, 10, fn. 1, 25 Ohio B. 38, 495 N.E.2d 42; Sheppard v. Mack (1980), 68 Ohio App.2d 95, 97, fn. 1, 427 N.E.2d 522. See, also, App.R. 16(A)(3) and (C). r P23] Additionally, [HN4] "issues not raised in

ct Court for the Dis- trict of South Carolina, G. Ross Anderson, Jr., J., certified class, and lender a

id not offer or advise Shep- pard of other railroad employment upon his release following the change in A&EC ownership. Soon after his dis- charge, Sheppard learned from an inde- pendent source of an open job as spike puller with an A&EC labor gang out of Morehead City. lie had worked out of New Bern w