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Lloyd Winawer (State Bar No. 157823) lwinawer oodwin rocter.com GOOD PROCTER LLP Los Angeles, CA 90067 Telephone: 310-788-5177 Facsimile: 310-286-0992
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Brian E. Pastuszenski (Pro Hac Vice Pending) bpastuszenski @ goodwinprocter.com Inez H . Friedman- Boyce (Pro Hac Vice Pending) oodwinprocter.com _ ifriedmanb^oyce GOODWIN PROCTER LLP 53 Exchange lace Boston, MA 0P 2109

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Telephone : 617-570-1000 Facsimile : 617-523-1231
Attorneys for Defendants

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COUN"I'RYWI13E HOME LOANS SERVICING LP, CWALT, INC., ALTERNATIVE LOAN TRUSTS (listed in the case caption), COUNTRYWIDE HOME LOANS, INC., COUNTRYWIDE SECURITIES CORPORATION, STANFORD L. KURLAND ERIC P. SIERACKI, DAVID A. SPECTOR, N. JOSHUA ADLER, RANJIT KRIPALANI, and JENNIFER S. SANDEFUR

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UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA DAVID H. LUTHER Individually and On
Behalf of All Others §imilarly Situated,

Case No.
t CV 0 7 0 8 1 6 5 G H K `S

Plaintiff, NOTICE OF REMOVAL
vs. COUNTRYWIDE HOME LOANS SERVICING LP, CWALT, INC. ALTERNATIVE LOAN TRUST 2005-J1, ALTERNATIVE LOAN TRUST 2005- , ALTERNATIVE LOAN TRUST 2005-J4 , ALTERNATIVE LOAN TRUST 2005-J5, ALTERNATIVE LOAN TRUST 2005-J6, ALTERNATIVE LOAN TRUST 2005-J7, ALTERNATIVE LOAN TRUST 2005-J8, ALTERNATIVE LOAN TRUST 2005-J9, ALTERNATIVE LOAN TRUST 2005-J10, ALTERNATIVE LOAN TRUST 2005-J 11, ALTERNATIVE LOAN TRUST 2005-J12, [Caption continued on following page]
NOTICE OF REMOVAL

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ALTERNATIVE LOAN TRUST 2005-J13, ALTERNATIVE LOAN TRUST 2005-J 14, ALTERNATIVE LOAN TRUST 2005-AR1, ALTERNATIVE LOAN TRUST 2005-IM1, ALTERNATIVE LOAN TRUST 2005-1CB, ALTERNATIVE LOAN TRUST 2005-2, ALTERNATIVE LOAN TRUST 2005-3CB, ALTERNATIVE LOAN TRUST 2005-4, ALTERNATIVE LOAN TRUST 2005-6CB, ALTERNATIVE LOAN TRUST 2005-7CB, ALTERNATIVE LOAN TRUST 2005-9CB, ALTERNATIVE LOAN TRUST 2005-10CB, ALTERNATIVE LOAN TRUST 2005-11 CB, ALTERNATIVE LOAN TRUST 2005-13CB, ALTERNATIVE LOAN TRUST 2005-14, ALTERNATIVE LOAN TRUST 2005-16, ALTERNATIVE LOAN TRUST 2005-17, ALTERNATIVE LOAN TRUST 2005-18CB, ALTERNATIVE LOAN TRUST 2005-19CB, ALTERNATIVE LOAN TRUST 2005-20CB, ALTERNATIVE LOAN TRUST 2005-21 CB, ALTERNATIVE LOAN TRUST 2005-22T1, ALTERNATIVE LOAN TRUST 2005-23CB, ALTERNATIVE LOAN TRUST 2005-24, ALTERNATIVE LOAN TRUST 2005-25T1, ALTERNATIVE LOAN TRUST 2005-26CB, ALTERNATIVE LOAN TRUST 2005-27, ALTERNATIVE LOAN TRUST 2005-28CB, ALTERNATIVE LOAN TRUST 2005-30CB, ALTERNATIVE LOAN TRUST 2005-31, ALTERNATIVE LOAN TRUST 2005-32T1, ALTERNATIVE LOAN TRUST 2005-33CB, ALTERNATIVE LOAN TRUST 2005-34CB, ALTERNATIVE LOAN TRUST 2005-35CB, ALTERNATIVE LOAN TRUST 2005-36 ALTERNATIVE LOAN TRUST 2005-37'1, ALTERNATIVE LOAN TRUST 2005-38, ALTERNATIVE LOAN TRUST 2005-40CB, ALTERNATIVE LOAN TRUST 2005-41, ALTERNATIVE LOAN TRUST 2005-42CB, ALTERNATIVE LOAN TRUST 2005-43, ALTERNATIVE LOAN TRUST 2005-44, ALTERNATIVE LOAN TRUST 2005-45, ALTERNATIVE LOAN TRUST 2005-46CB, ALTERNATIVE LOAN TRUST 2005-47CB, ALTERNATIVE LOAN TRUST 2005-48T1, ALTERNATIVE LOAN TRUST 2005-49CB, ALTERNATIVE LOAN TRUST 2005-50CB, ALTERNATIVE LOAN TRUST 2005-51, ALTERNATIVE LOAN TRUST 2005-52CB, ALTERNATIVE LOAN TRUST 2005-53T2, ALTERNATIVE LOAN TRUST 2005-54CB, ALTERNATIVE LOAN TRUST 2005-55CB, [Captioned continued on next page]

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ALTERNATIVE LOAN TRUST 2005-56, ALTERNATIVE LOAN TRUST 2005-57CB, ALTERNATIVE LOAN TRUST 2005-58 ALTERNATIVE LOAN TRUST 2005-60t 1, ALTERNATIVE LOAN TRUST 2005-6 1, ALTERNATIVE LOAN TRUST 2005-62, ALTERNATIVE LOAN TRUST 2005-63, ALTERNATIVE LOAN TRUST 2005-64CB, ALTERNATIVE LOAN TRUST 2005-65CB, ALTERNATIVE LOAN TRUST 2005-67CB, ALTERNATIVE LOAN TRUST 2005-69, ALTERNATIVE LOAN TRUST 2005-70CB, ALTERNATIVE LOAN TRUST 2005-71, ALTERNATIVE LOAN TRUST 2005-72, ALTERNATIVE LOAN TRUST 2005-73CB, ALTERNATIVE LOAN TRUST 2005-74T1, ALTERNATIVE LOAN TRUST 2005-75CB, ALTERNATIVE LOAN TRUST 2005-76 ALTERNATIVE LOAN TRUST 2005-772T1, ALTERNATIVE LOAN TRUST 2005-79CB, ALTERNATIVE LOAN TRUST 2005-80CB, ALTERNATIVE LOAN TRUST 2005-8 1, ALTERNATIVE LOAN TRUST 2005-82, ALTERNATIVE LOAN TRUST 2005-83CB, ALTERNATIVE LOAN TRUST 2005-84, ALTERNATIVE LOAN TRUST 2005-85CB, ALTERNATIVE LOAN TRUST 2005-86CB, ALTERNATIVE LOAN TRUST 2006-HY3, ALTERNATIVE LOAN TRUST 2006-HY 10, ALTERNATIVE LOAN TRUST 2006-HY11, ALTERNATIVE LOAN TRUST 2006-HY12, ALTERNATIVE LOAN TRUST 2006-HY13, ALTERNATIVE LOAN TRUST 2006-J1, ALTERNATIVE LOAN TRUST 2006-J2, ALTERNATIVE LOAN TRUST 2006-J3, ALTERNATIVE LOAN TRUST 2006-J4, ALTERNATIVE LOAN TRUST 2006-J5, ALTERNATIVE LOAN TRUST 2006-J6, ALTERNATIVE LOAN TRUST 2006-J7, ALTERNATIVE LOAN TRUST 2006-J8, ALTERNATIVE LOAN TRUST 2006-OA 0, ALTERNATIVE LOAN TRUST 2006-OA 1, ALTERNATIVE LOAN TRUST 2006-OA12, ALTERNATIVE LOAN TRUST 2006-OA16, ALTERNATIVE LOAN TRUST 2006-OA17, ALTERNATIVE LOAN TRUST 2006-OA18, ALTERNATIVE LOAN TRUST 2006-OA19, ALTERNATIVE LOAN TRUST 2006-OA21, ALTERNATIVE LOAN TRUST 2006-OA22, ALTERNATIVE LOAN TRUST 2006-OA3, ALTERNATIVE LOAN TRUST 2006-OA6, ALTERNATIVE LOAN TRUST 2006-OA7, ALTERNATIVE LOAN TRUST 2006-OA8, [Caption continued on next page]
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ALTERNATIVE LOAN TRUST 2006-OA9, ALTERNATIVE LOAN TRUST 2006-OC1, ALTERNATIVE LOAN TRUST 2006-OC10, ALTERNATIVE LOAN TRUST 2006-OC11, ALTERNATIVE LOAN TRUST 2006-OC2, ALTERNATIVE LOAN TRUST 2006-OC3, ALTERNATIVE LOAN TRUST 2006-OC4, ALTERNATIVE LOAN TRUST 2006-OC5, ALTERNATIVE LOAN TRUST 2006-OC6, ALTERNATIVE LOAN TRUST 2006-OC7, ALTERNATIVE LOAN TRUST 2006-OC8, ALTERNATIVE LOAN TRUST 2006-OC9, ALTERNATIVE LOAN TRUST 2006-2CB, ALTERNATIVE LOAN TRUST 2006-4CB, ALTERNATIVE LOAN TRUST 2006-6CB, ALTERNATIVE LOAN TRUST 2006-7CB ALTERNATIVE LOAN TRUST 2006-11Ch, ALTERNATIVE LOAN TRUST 2006-12CB, ALTERNATIVE LOAN TRUST 2006-14CB, ALTERNATIVE LOAN TRUST 2006-15CB, ALTERNATIVE LOAN TRUST 2006-16CB, ALTERNATIVE LOAN TRUST 2006-18CB, ALTERNATIVE LOAN TRUST 2006-19CB, ALTERNATIVE LOAN TRUST 2006-20CB, ALTERNATIVE LOAN TRUST 2006-21 CB, ALTERNATIVE LOAN TRUST 2006-23CB, ALTERNATIVE LOAN TRUST 2006-24CB, ALTERNATIVE LOAN TRUST 2006-25CB, ALTERNATIVE LOAN TRUST 2006-26CB, ALTERNATIVE LOAN TRUST 2006-27CB, ALTERNATIVE LOAN TRUST 2006-28CB, ALTERNATIVE LOAN TRUST 2006-32CB, ALTERNATIVE LOAN TRUST 2006-33CB, ALTERNATIVE LOAN TRUST 2006-34, ALTERNATIVE LOAN TRUST 2006-35CB, ALTERNATIVE LOAN TRUST 2006-39CB, ALTERNATIVE LOAN TRUST 2006-41 CB, ALTERNATIVE LOAN TRUST 2006-42, ALTERNATIVE LOAN TRUST 2006-9T1, ALTERNATIVE LOAN TRUST 2006-5T2, ALTERNATIVE LOAN TRUST 2006-1311, ALTERNATIVE LOAN TRUST 2006-1711, ALTERNATIVE LOAN TRUST 2006-2911, ALTERNATIVE LOAN TRUST 2006-30T1, ALTERNATIVE LOAN TRUST 2006-36T2, ALTERNATIVE LOAN TRUST 2006-40T1, ALTERNATIVE LOAN TRUST 2006-45T1, ALTERNATIVE LOAN TRUST 2006-46, ALTERNATIVE LOAN TRUST 2007-2CB, ALTERNATIVE LOAN TRUST 2007-4CB, ALTERNATIVE LOAN TRUST 2007-6, ALTERNATIVE LOAN TRUST 2007-8CB, ALTERNATIVE LOAN TRUST 2007-10CB
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ALTERNATIVE LOAN TRUST 2007-15CB, ALTERNATIVE LOAN TRUST 2007-AL 1, ALTERNATIVE LOAN TRUST 2007-HY2, ALTERNATIVE LOAN TRUST 2007-HY3, ALTERNATIVE LOAN TRUST 2007-HY4, ALTERNATIVE LOAN TRUST 2007-JI, ALTERNATIVE LOAN TRUST 2007-J2, ALTERNATIVE LOAN TRUST 2007-OA2, ALTERNATIVE LOAN TRUST 2007-OA3, ALTERNATIVE LOAN TRUST 2007-OA4, ALTERNATIVE LOAN TRUST 2007-OA6, ALTERNATIVE LOAN TRUST 2007-OA7, ALTERNATIVE LOAN TRUST 2007-OH1, ALTERNATIVE LOAN TRUST 2007-IT1, ALTERNATIVE LOAN TRUST 2007-3T1, ALTERNATIVE LOAN TRUST 2007-7T2, ALTERNATIVE LOAN TRUST 2007-9T1, ALTERNATIVE LOAN TRUST 2007-1 IT1, ALTERNATIVE LOAN TRUST 2007-12T1, ALTERNATIVE LOAN TRUST 2007-13, ALTERNATIVE LOAN TRUST 2007-14T2, COUNTRYWIDE HOME LOANS, INC., COUNTRYWIDE SECURITIES CORPORATION, MORGAN STANLEY & CO. INCORPORATED, UBS SECURITIES LLC DEUTSCHE BANK SECURITIES INC., CITIGROUP GLOBAL MARKETS INC., LEHMAN BROTHERS INC., GREENWICH CAPITAL MARKETS, INC., EDWARD D. JONES & CO., L.P., J.P. MORGAN SECURITIES INC., CREDIT SUISSE FIRST BOSTON, GOLDMAN SACHS & CO., BANC OF AMERICA SECURITIES LLC, BARCLAYS CAPITAL INC., BEAR STEARNS & CO. INC., STANFORD L. KURLAND, ERIC P. SIERACKI, DAVID A. SPECTOR, N. JOSHUA ADLER RANJIT KRIPALAN'I, JENNIFER S. SANDEFUR
and DOES 1 through 20, inclusive,

Defendants.

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Defendants Countrywide Home Loans Servicing LP, CWALT, Inc., Alternative
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Loan Trusts (listed in the case caption), Countrywide Home Loans, Inc., Countrywide Securities Corporation , Stanford L. Kurland, Eric P. Sieracki, David A. Spector, N. Joshua Adler, Ranjit Kripalani, and Jennifer S. Sandefur (collectively, the "Countrywide Defendants"),' specially appearing solely for the purpose of submitting

this notice of removal and preserving and not waiving any defenses they may have based on lack of personal jurisdiction or service of process, or any other defenses, by their attorneys, hereby remove the above-captioned case pending in the Superior Cou of the State of California, County of Los Angeles, to the United States District Court for the Central District of California. Removal is based on 28 U.S.C. §§ 1332 and 1441, as amended in relevant part by the Class Action Fairness Act of 2005 ("CAFA"), and authorized by 28 U.S.C. § 1453. As grounds for removal, the Countrywide Defendants state as follows: 1. On November 14, 2007 plaintiff David H. Luther filed this putative state

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court class action (the "State Court Action") by filing a complaint entitled David H. Luther v. Countrywide Home Loans Servicing LP et al. (the "Class Action Complaint") in the Superior Court of the State of California , County of Los Angeles and on behalf of all persons or entities who acquired mortgage pass-through certificates issued by defendant CWALT, Inc. ("CWALT") and sold nationally in public offerings registered with the U.S. Securities and Exchange Commission under Section [5] of the Securities Act of 1933 . This case was assigned docket number BC380698.

` The other, separately represented defendants in this matter are Morgan Stanley & Co. Incorporated UBS Securities LLC, Deutsche Bank Securities Inc., Citiaroup Global Markets Inc ., Lehman Brothers Inc., Greenwich Capital Markets, Inc., dward D. Jones & Co , L.P., J.P. Morgan Securities Inc., Credit Suisse First Boston (now known as Credit Suisse Securities (USA) LLC), Goldman Sachs & Co., Banc of America Securities LLC, Barclays Capital Inc., and Bear Sterns & Co. Inc. These defendants have consented to the removal of this matter and have authorized Defendants to represent that they are concurrently filing a Notice of Consent to Removal.
OF REMOV.

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2.

The Class Action Complaint alleges, among other things, that certain public

offering registration statements filed by CWALT with the U.S. Securities and Exchange Commission between January 2005 and June 2007 contained misstatements, and asserts causes of action under Sections 11, 12(a)(2), and 15 of the Securities Act of 1933, 15 U.S.C. §§ 77k, 771(a)(2), and 77o.
3. Pursuant to 28 U.S.C. §§ 1446(a) and 1441(a), this Notice of Removal is

being filed in the United States District Court for the Central District of California. STATUTORY REQUIREMENTS - CLASS ACTION FAIRNESS ACT 4. This Court has Jurisdiction . Pursuant to 28 U.S.C. § 1332, as amended by

CAFA, a putative "class action" commenced after February 18, 2005 - i.e., the

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effective date of CAFA - may be removed to the appropriate United States District Court if. (a) the amount in controversy exceeds the sum or value of $5,000,000, exclusive of interest and costs; and (b) any member of the putative class is a citizen of a state different from any defendant. 28 U.S.C. § 1332(d)(2)(A). 5. CAFA is applicable to the State Court Action because the Action was

commenced on or about November 14, 2007 - i.e., after the effective date of CAFA. 28 U.S.C. §§ 1332, 1453.

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6.

In addition, the State Court Action is a "class action" within the meaning of

CAFA because Plaintiff seeks to represent a class of persons in a "civil action filed under" California's class action statute, Cal. Code Civ. Proc. § 382 - Le., a "rule of judicial procedure authorizing an action to be brought by 1 or more representative persons as a class action." 28 U.S.C. §§ 1332(d)(1)(B), 1453(a). 7. Amount in Controversy . There is more than $5,000,000 in controversy in

24 the State Court Action. Under 28 U.S.C. § 1332(d), as added by CAFA, the amount in
25 controversy in a putative class action is determined by aggregating the amount at issue 26 in the claims of all members of the putative class. 28 U.S.C. § 1332(d)(6). Here, the 27 Class Action Complaint alleges that the defendants made false and misleading
28 statements in connection with the issuance of approximately $300 billion in mortgage 11
NOTICE OF REMOVAL

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certificates, and that the value of the certificates has declined su 2 subsequent to and due to the defendants' alleged violations. See Class Action 3 Complaint 1158, 86 and Prayer for Relief. While the Countrywide Defendants deny
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4 that Plaintiff or any putative class member is entitled to recover any amount, and 5 specifically deny that Plaintiff or any putative class member is entitled to the relief in 6 the various forms sought, these allegations plainly make the aggregate amount in 7 controversy in this State Court Action more than $5,000,000, exclusive of interest and 8 costs. 28 U.S.C. § 1332(d)(2). 9 8. Citizenship of Parties . The requisite diversity of citizenship exists under 28 to U.S.C. §§ 1332(d)(2) and (d)(7). To establish diversity jurisdiction under CAFA, it is 11 sufficient that any one member of the putative class is a citizen of a state different from
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N a 12 any one defendant, in contrast to the complete diversity requirement of typical diversity e 13 jurisdiction. 28 U.S.C. § 1332(d)(2)(A). Among the defendants in the State Court 40 14 Action, there are citizens of California, Connecticut, Delaware, Missouri, Nevada, New
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20 9. No CAFA Exceptions Apply. Although the Countrywide Defendants deny

21 11 that it is their burden to show that CAFA' s exceptions to jurisdiction in 28 U.S.C. §§

22 1332 (d)(4), (5) and (9) do not apply, none does.
23 24 a. First, the exceptions in 28 U.S.C. §§ 1332(d)(4)(A) and (B) do not

apply because they are limited to cases where, among other things, more than two-

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thirds of the putative class members are citizens of the State in which the action was originally filed. 28 U.S.C. §§ 1332(d)(4)(A) and (B). There is no basis for concluding that two-thirds of the members of the proposed class are citizens of California;
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Second, the exception in Section 1332(d)(5)(A) does not apply

because the Defendants are individuals and corporate and other private entities, not States, State officials , or other governmental entities. 28 U.S .C. § 1332(d)(5)(A); c. Third, the exception in Section 1332(d)(5)(B) does not apply

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because the number of putative class members is alleged to be in excess of 100. 28
U.S.C . § 1332(d)(5)(B). Specifically, the Complaint alleges that there are "thousands" of members of the putative class. See Class Action Complaint at ¶ 39; and d. Finally, the exceptions in Section 1332(d)(9) do not apply because

this case does not solely involve a claim: (1) concerning a "covered security" under Section 16(f)(3) of the Securities Exchange Act of 1933; (2) relating to the internal affairs or governance of a corporation or other form of business enterprise and arising by virtue of the laws of the state in which such corporation or business enterprise is organized; or (3) relating to the rights, duties (including fiduciary duties), and to obligations relating to or created by or pursuant to any security. 28 U.S.C. §

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1332(d)(9).
PROCEDURAL REQUIREMENTS 10. Removal to Proper Court. This Court is part of the " district and division embracing the place where" this action was filed - Los Angeles County Superior Court. 28 U.S .C. § 1446(a).

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11. Consent to Removal. As shown below, and although it is not necessary, all defendants consent to removal.
12. Removal is Timely . Defendants received by service the Summons and Complaint no earlier than November 14, 2007. Receipt of the Summons and

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Complaint was the first notice of the State Court Action or federal jurisdiction
received by Defendants. This Notice of Removal is being filed with the United States District Court for the Central District of California on December 14, 2007, within 30 days after receipt by defendants Countrywide Home Loans Servicing LP, CWALT, Inc ., Countrywide Home Loans, Inc., and Countrywide Securities Corporation,
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through service or otherwise, of the Summonses and Complaint. See 28 U.S.C. § 1446(b). 13. Pleadings and Process. In accordance with 28 U.S.C. § 1446(a), attached hereto as Exhibit A are file-stamped copies of all process, pleadings and orders served upon the Countrywide Defendants in the State Court Action, namely the Summons, Complaint, Civil Case Cover Sheet, Civil Case Cover Sheet Addendum and Statement
of Location, Proofs of Service of the Summons and Complaint on defendants Home Loans Servicing LP, CWALT, Inc., Countrywide Home Loans , Inc., and Countrywide

Securities Corporation, and Court Order - Notice of Status Conference. See 28 U.S.C. § 1446(a). 14. Notice . The Countrywide Defendants will promptly serve a copy of the Notice of Removal on Plaintiff's counsel and file with the Clerk of the Superior Court of the State of California, County of Los Angeles, a Notice of Filing of Notice of Removal pursuant to 28 U.S.C. § 1446(d).
15. Signature . This Notice of Removal is signed pursuant to Fed. R. Civ. P. 11. See 28 U.S.C. § 1446(a). 16. Bond and Verification . Pursuant to Section 1016 of the Judicial Improvements and Access to Justice Act of 1988, no bond is required in connection with this Notice of Removal. Pursuant to Section 1016 of the Act, this Notice need

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NOTICE OF REMOV

17. Based upon the foregoing, this Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1332, as amended by CAFA, and the claims may be removed

to this Court under 28 U.S.C. § 1453.

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WHEREFORE, this action should proceed in the United States District Court for the Central District of California, as an action properly removed thereto.
Dated: December 14, 2007

Respectfully submitted,
Defendants COUNTRYWIDE HOME LOANS SERVICING LP, CWALT, INC., ALTERNATIVE LOAN TRUSTS (listed in the case caption) COUNTRYWIDE HOME LOANS, INC., COUNTRYWIDE SECURITIES CORPORATION, STANFORD L. KURLAND ERIC P. SIERACKI, DAVID A. S^PECTOR, N. JOSHUA ADLER, RANJIT KRIPALANI, and JENNIFER S. SANDEFUR

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Lio. wmawer lw' er^goodwin_procter.com GO DA N PROCTER LLP 10250 Constellation Blvd., 21 Floor Los Angeles CA 90067 Telephone: 310-788-5177 Facsimile: 310-286-0992 GOODWIN PROCTER LLP
Brian E. Pastuszenski (Pro Hac Vice Pending) bpastuszenski@goodwinprocter.com Inez H. Friedman-Boyce (Pro Hac Vice Pending) ifriedmanboyce@goodwinprocter.com 53 Exchange Place

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Boston, MA 02109 Telephone : 617-570-1000 Facsimile: 617-523-1231

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E OF REMOVAL