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`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF ILLINOIS
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`VILLAGE OF SHILOH,
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`Plaintiff,
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`vs.
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`NETFLIX, INC., et al.
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`Defendants.
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`Case No. 3:21-CV-00807-MAB
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`PLAINTIFF VILLAGE OF SHILOH’S MOTION TO REMAND
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`Plaintiff, Village of Shiloh, with respect moves this Court to remand the above case to the
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`20th Judicial Circuit of St. Clair County, Illinois. Defendant Netflix, Inc., removed this matter on
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`July 15, 2021, alleging federal jurisdiction under the Class Action Fairness Act on 2005
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`(“CAFA”). All other Defendants have since joined in or consented to removal. Pursuant to 28
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`U.S.C. § 1447, and for the reasons set forth in the accompanying memorandum in support,
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`Village of Shiloh moves to remand this matter back to state court.
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`WHEREFORE, Village of Shiloh prays this Court will enter an order remanding this
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`matter to the 20th Judicial Circuit of St. Clair County, Illinois.
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`/s/ Thomas H. Geoghegan
`By:
`One of Plaintiff’s Attorneys
`Thomas H. Geoghegan
`Michael P. Persoon
`Will Bloom
`Despres, Schwartz & Geoghegan, Ltd.
`77 West Washington Street, Suite 711
`Chicago, Illinois 60602
`(312) 372-2511
`tgeoghegan@dsgchicago.com
`mpersoon@dsgchicago.com
`wbloom@dsgchicago.com
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`Case 3:21-cv-00807-MAB Document 45 Filed 08/16/21 Page 2 of 2 Page ID #124
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`CERTIFICATE OF SERVICE
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`I hereby certify that on August 16, 2021, a true and correct copy of the foregoing was
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`filed electronically. Service of this filing will be made on all ECF-registered counsel by
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`operation of the Court’s electronic filing system.
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`/s/ Thomas H. Geoghegan
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