CASE 0:17-cv-04712-ADM-SER Document 1-2 Filed 10/17/17 Page 1 of 2

STATE OF MINNESOTA DISTRICT COURT

COUNTY OF RAMSEY SECOND JUDICIAL DISTRICT

Osha Joseph, Case No. _________

Judge ______________
Plaintiff

vs. NOTICE OF FILING OF NOTICE

OF REMOVAL
Sgt. Bobby Donahue, Sgt. Tom Arnold,
Officer Mon Notthakun, and Officer
Marshall Titus, in their individual and
official capacities, as police officers for the
City of Saint Paul, and the City of Saint
Paul,

Defendants.

TO: Plaintiff and his attorney Adam T. Johnson, Lundgren & Johnson, P.S.C., 1700
US Bank Center, 101 Fifth Street, Saint Paul, MN 55101.

PLEASE TAKE NOTICE that the attached Notice of Removal was filed with the Clerk

of the United States District Court for the District of Minnesota on October 16, 2017,

constituting a removal of this cause from the Ramsey County District Court. A copy of the

Notice is being filed with the Ramsey County District Court Administrator. This Notice is

submitted in compliance with 28 U.S.C. 1446(d).

ACKNOWLEDGEMENT

The party upon whose belief this pleading is submitted, by and through the undersigned

hereby acknowledges that sanctions may be imposed for a violation of Minn. Stat. 549.211.
 CASE 0:17-cv-04712-ADM-SER Document 1-2 Filed 10/17/17 Page 2 of 2

Dated: October 16, 2017 SAMUEL J. CLARK

City Attorney

s/ Lawrence J. Hayes, Jr.

LAWRENCE J. HAYES, JR., #42821
Assistant City Attorney
750 City Hall and Courthouse
15 West Kellogg Boulevard
Saint Paul, MN 55102
Telephone: (651) 266-8728
Fax: (651) 266-8787
larry.hayes@ci.stpaul.mn.us
Attorneys for Defendants