PLAINTIFF'S MOTION FOR REMAND OF IMPROPERLY REMOVED CASE
AND FOR JUST COSTS AND EXPENSES, INCLUDING ATTORNEY'S FEES,
INCURRED DUE TO THE IMPROPER REMOVAL

Oral Argument Requested

William Silverstein, the plaintiff herein, hereby moves within 30 days of removal, pursuant to § 1447(c) of Title 28 of the United States Code, for an order of this Court directing:

(1) that this case be remanded in full to Middlesex Superior Court, as its removal is expressly barred by § 1445(c) and § 1441 of Title 28, and

(2) that the defendants pay the plaintiff his just costs, and expenses, including attorneys fees, incurred as a result of the improper removal of this case.⁽¹⁾