I. NOTICE OF REMOVAL:
According to the plain language meaning of 28 U.S. Code §1446, the notice of
removal of a civil action or proceeding shall be filed within 30 days after the
receipt by the defendant, through service or otherwise, of a copy of the initial
pleading setting forth the claim for relief upon which such action or
proceeding is based, or within 30 days after the service of summons upon the
defendant if such initial pleading has then been filed in court and is not
required to be served on the defendant, whichever period is shorter.
The initial complaint in this case was admittedly received via US Priority
Mail on 05/24/2019, under U.S. Code §1446 a notice of removal had to be filed
within 30 days or by 06/23/2019, however the notice of removal was not filed
until the date of respondent 's first appearance on 07/08/2019 to file the actual
notice of removal.
The question is when does the deadline to file for Notice of Removal
begin, is it upon receipt of the complaint as per the plain language
meaning of U.S. Code §1446 or must the summons also be received?

II. WHAT CONSTITUTES A GENERAL APPEARANCE?
Respondents appeared before two previous judges and filed a notice of
removal, two peremptory challenges, an objection and a declaration prior to
filing the motion to quash. A demurrer and a motion to strike were filed
together with the motion to quash.
Petitioner argued in his objection and at the hearing on the motion to quash
that general appearances had. occurred. The Superior Court only addressed
the notice of removal and found that it was not a general appearance. The
Court of Appeals addressed the notice of removal and peremptory challenges.
Neither of the courts addressed the status of the declaration and objection or
the motion to strike and demurrer but the appearances, although thus far
undetermined by the courts apparently meet the requirements of a general
appearance.
The question is: What constitutes a General Appearance and did one
occur before or concurrently with the motion to quash being filed?

III. SHOULD THE JUDGE HAVE RECUSED HIMSELF?
The Constitution requires a hearing that is fair and impartial.
At the hearing on the motion to quash Judge Green overtly expressed his age
related bias by stating "Can I call an 80- Year old elderly when I'm 72. Well.
Regardless, they are elderly and I see no reason for dragging them across the
country to be here ." The Judge also told petitioner to shush thereby
preventing petitioner from making a full and fair argument.
The question is: Was the level of age related bias and impartiality
expressed by the judge sufficient for him to have recused himself
and should the Court of Appeals have addressed this issue?

IV. PROCEDURAL DUE PROCESS
On 05/29/2020 Appellant 's brief was filed and to support it's arguments
contained citations to relevant laws, rules and cases but the table of contents
did not fist citations to the clerk 's record as per court requirements. The
docket sheet noted that the brief did not comply to citations to the clerk 's
record so permission to file was needed. Permission was granted on 06/18/20
but then the court later used the defect as an excuse not to fully address
petitioner 's arguments.
The question is: Is

When does the deadline to file for Notice of Removal begin?