RAMIREZ_PetitionFOR A WRIT OF CERTIORARI_2_6_2017
1 IN THE SUPREME COURT OF THE UNITED STATES ________________________________________ CARLOS RAMIREZ — PETITIONER VS. BAUSCH AND LOMB, INC. — RESPONDENT ________________________________________ PETITION FOR WRIT OF CERTIORARI ________________________________________ OPINIONS BELOW The orders of the United States Court of Appeals for the Eleventh Circuit appear at Appendix pages 1, 2, and 3 to the petition and are unpublished. The opinion of the United States District Court for the Middle District of Florida appears at Appendix pages 5 to the petition and is unpublished.
2 JURISDICTION The Eleventh Circuit did not consider Ramirez’s unopposed motion to accept the appendix below as timely filed, and therefore did not enter an order on that motion. See A. 26, 27, 34, 35, 44. The Eleventh Circuit dismissed this case on April 20, 2016. A. 1, 34, 52. It denied Ramirez’s first motion to reinstate the appeal on July 14, 2016. A. 2, 52. It denied his second motion to reinstate the appeal on September 7, 2016. A. 3, 52. On December 9, 2016, Justice Thomas granted an extension of time to file the petition for a writ of certiorari to and including February 4, 2017 (a Saturday) in Application № 16A532. This petition was mailed on the following Monday, February 6, 2017, and it is therefore timely. See Rule 30.1. The jurisdiction of this Court is invoked under 28 U.S.C. § 1254(1). PROVISIONS INVOLVED The following statutes are involved in this case and are set out in the appendix: sections 610, 951, 956, 963, 1254, and 2072 of Title 28 of the United States Code. STATEMENT OF THE CASE Carlos Ramirez sued Bausch & Lomb, Inc., in Florida state court. 1 See A. 55. He alleged a claim under the Florida Civil Rights Act and a Florida common-law claim of negligent supervision, training, or retention. Bausch & Lomb removed to the United States District Court for the Middle District of Florida 2 under 1 2 № 2010-CA-11240 (Fla. 13th Jud. Cir. Ct., in and for Hillsborough County). № 8:10-cv-02003-MSS-TGW (Hon. Mary S. Scriven).
- Page 1 and 2: № ____________________ IN THE SUP
- Page 3 and 4: ( ii) CONTENTS PETITION CONTENTS Qu
- Page 5 and 6: ( iv) Clerk Correspondence re Entry
- Page 7: ( vi) ELEVENTH CIRCUIT LOCAL RULES
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- Page 13 and 14: 6 ARGUMENT This Court should grant
- Page 15 and 16: 8 appendix, but the clerk simply di
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- Page 21 and 22: 14 Scotia v. United States, 487 U.S
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1<br />
IN THE<br />
SUPREME COURT <strong>OF</strong> THE UNITED STATES<br />
________________________________________<br />
CARLOS <strong>RAMIREZ</strong> — PETITIONER<br />
VS.<br />
BAUSCH AND LOMB, INC. — RESPONDENT<br />
________________________________________<br />
PETITION FOR <strong>WRIT</strong> <strong>OF</strong> <strong>CERTIORARI</strong><br />
________________________________________<br />
OPINIONS BELOW<br />
The orders of the United States Court of Appeals for the Eleventh Circuit appear at<br />
Appendix pages 1, 2, and 3 to the petition and are unpublished.<br />
The opinion of the United States District Court for the Middle District of Florida<br />
appears at Appendix pages 5 to the petition and is unpublished.
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