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

QUESTIONS PRESENTED FOR REVIEW 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? i ; II. WHAT CONSTITUTES A GENERAL APPEARANCE? —_——nesponaants appeared before two previous judges and Bled a notte oP 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. ii ; Regardless, they are elderly and I see no reason for dragging them across the aaa so are Tine TAGS GIGS Told petiioney to Shuck 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