Quarles & Brady LLP Firm State Bar No. 00443100 Phoenix, AZ … · 2015-07-30 · LLC et al.,...

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Quarles & Brady LLP

Firm State Bar No. 00443100 Renaissance One

Two North Central Avenue Phoenix, AZ 85004-2391

TELEPHONE 602.229.5200

Nicole France Stanton (#020452) [email protected] Eric B. Johnson (#020512) [email protected] Michael S. Catlett (#025238) [email protected] Attorneys for Defendants

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

Paula Lorona,

Plaintiff,

vs.

Arizona Summit Law School, LLC; Infilaw Corporation; Stephanie and Jason Lee; Scott and Jane Doe Thompson; John and Jane Does 1-100; Black Corporations 1-100; White Partnerships 1-100, Defendants.

Case No.: ___________________

(formerly Maricopa County Superior Court No. CV2015-000681)

NOTICE OF REMOVAL

Defendants Arizona Summit Law School, LLC, Infilaw Corporation, Stephanie

Lee, and Scott Thompson (collectively, the “Removing Defendants”) hereby give notice

of removal of the civil action captioned Paula Lorona v. Arizona Summit Law School,

LLC et al., CV2015-000681, from the Arizona Superior Court, Maricopa County (the

“State Court Action”), to the United States District Court for the District of Arizona.

Removing Defendants file this notice pursuant to 28 U.S.C. § 1446(a) and L.R.

Civ. 3.6. The United States District Court has jurisdiction over this case pursuant to 28

Case 2:15-cv-00972-NVW Document 1 Filed 05/28/15 of 3

mailto:[email protected]



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U.S.C. §§ 1331 and 1367. Undersigned counsel verifies that a complete copy of the

filings in the State Court Action, which his firm obtained from the Arizona Superior

Court, Maricopa County, is attached hereto as Exhibit “A” and the Verification of

Michael S. Catlett to Defendants' Notice of Removal is attached as Exhibit "B".

As grounds for removal of this action, the Removing Defendants state as follows:

1. Defendant Arizona Summit Law School, LLC was first served on May 5,

2015. The remaining Removing Defendants have not yet been served.

2. This Notice of Removal is filed within thirty (30) days of service of the

Amended Complaint on Arizona Summit Law School, LLC.

3. The Removing Defendants have not pled, answered, or otherwise appeared

in the State Court action. The Removing Defendants hereby reserve all defenses,

including defenses based on lack of personal jurisdiction.

4. The United States District Court has original jurisdiction over this action

under 28 U.S.C. § 1331. In her Amended Complaint, Plaintiff has asserted claims arising

under Constitution, treaties,or laws of the United States of America, including claims

under the Americans with Disabilities Act, Title VII of the Civil Rights Act of 1964, the

Family Medical Leave Act, and 34 CFR 600 et seq. Additionally, the United States

District Court has supplemental jurisdiction over all other claims under 28 U.S.C. § 1367

because they are related to the claims arising under the laws of the United States of

America such that they form part of the same case or controversy under Article III of the

United States Constitution.

5. The Removing Defendants consent to the removal of this action to the

United States District Court, District of Arizona.

6. Written notice of the filing of this Notice has been delivered to all parties

who have appeared in this action. A copy of this Notice of Removal has been filed with

the Clerk of the Court of the Superior Court, Maricopa County, Arizona. The Notice of


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Removal filed in the Superior Court is attached hereto as Exhibit “C.”

Accordingly, the Removing Defendants respectfully request that this Notice of

Removal be filed, the Superior Court Action be removed to, and proceed hereinafter, in

this Court, and that no further proceedings in this matter take place in the Arizona

Superior Court. RESPECTFULLY SUBMITTED this 28th day of May, 2015.

QUARLES & BRADY LLP 2 North Central Avenue Phoenix, AZ 85004

By /s/ Michael S. Catlett Nicole France Stanton Eric B. Johnson Michael S. Catlett

Attorneys for Defendants

CERTIFICATE OF SERVICE

I hereby certify that on May 28, 2015, I electronically transmitted the attached

document to the Clerk's Office using the CM/ECF System for filing and transmittal of a

Notice of Electronic Filing to the following CM/ECF registrants; and further certify that a

copy of the foregoing was sent this date by First-Class Mail to:

Paula C. Lorona

12705 W. Sierra Circle

El Mirage, AZ 85335

Plaintiff Pro Per

s/Valerie Corral QB\35259163.1


Case 2:15-cv-00972-NVW Document 1-1 Filed 05/28/15 Page 1 of 96

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Quarles & Brady LLP

Firm State Bar No. 00443100 Renaissance One

Two North Central Avenue Phoenix, AZ 85004-2391

TELEPHONE 602.229.5200

Nicole France Stanton (#020452)

[email protected]

Eric B. Johnson (#020512)

[email protected] Michael S. Catlett (#025238) [email protected] Attorneys for Defendants

IN THE SUPERIO COURT OF THE STATE OF ARIZONA

IN AND FOR THE COUNTY OF MARICOPA

Paula Lorona,

Plaintiff,

vs.

Arizona Summit Law School, LLC; Infilaw Corporation; Stephanie and Jason Lee; Scott and Jane Doe Thompson; John and Jane Does 1-100; Black Corporations 1-100; White Partnerships 1-100, Defendants.

Case No.: CV2015-000681

NOTICE OF REMOVAL

(Assigned to the Hon. Dawn Bergin)

You are hereby notified that on May 27, 2015, Defendants Arizona Summit Law

School, LLC, Infilaw Corporation, Stephanie Lee, and Scott Thompson (collectively,

“Defendants”) filed in the United States District Court for the District of Arizona a notice

confirming removal of this action from the Superior Court of Maricopa County, Arizona

to the United States District Court for the District of Arizona pursuant to 28 U.S.C. §§

1331 and 1367, together with a copy of the pleadings served upon it. Attached as Exhibit

“A” to this Notice is a copy of the Notice of Removal (without exhibits) to the United





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States District Court, filed pursuant to 28 U.S.C. § 1446, and all other applicable

provisions of law.

Therefore, Defendants having taken all steps to effect removal of this case, this

Court may proceed no further unless or until the case is remanded by Order of the United

States District Court. Defendants further certify that Plaintiff has been notified of this

removal and served with a copy of the Notice of Removal. See 28 U.S.C. § 1446(d). RESPECTFULLY SUBMITTED this 27th day of May, 2015.

QUARLES & BRADY LLP 2 North Central Avenue Phoenix, AZ 85004

By /s/ Michael S. Catlett Nicole France Stanton Eric B. Johnson Michael S. Catlett

Attorneys for Defendants Original efiled and Copy

mailed May 28, 2015 to:

Paula C. Lorona

12705 W. Sierra Circle

El Mirage, AZ 85335

Plaintiff Pro Per

Valerie Corral QB\35259182.1


UNITED STATES DISTRICT COURTDISTRICT OF ARIZONA

Civil Cover SheetThis automated JS-44 conforms generally to the manual JS-44 approved by the Judicial Conference of the United States in September 1974. The data is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. The information contained herein neither replaces nor supplements the filing and service of pleadings or other papers as required by law. This form is authorized for use only in the District of Arizona.

The completed cover sheet must be printed directly to PDF and filed as an attachment to the Complaint or Notice of Removal.

Plaintiff(s): Paul Lorona Defendant

(s):

Arizona Summit Law School, LLC ; Infilaw Corporation ; Stephanie Lee ; Jason Lee ; Scott Thompson

County of Residence: Maricopa County of Residence: MaricopaCounty Where Claim For Relief Arose: Maricopa

Plaintiff's Atty(s): Defendant's Atty(s):Nicole France Stanton ( Arizona Summit Law School, LLC ; Infilaw Corporation ; Stephanie Lee ; Jason Lee ; Scott Thompson )Quarles & Brady, LLP2 North Central AvenuePhoenix, Arizona 85004-2391602.229.5200

Eric B. Johnson ( Arizona Summit Law School, LLC ; Infilaw Corporation ; Stephanie Lee ; Jason Lee ; Scott Thompson )Quarles & Brady, LLP2 North Central AvenuePhoenix, Arizona 85004-2391602.229.5200

Michael S. Catlett ( Arizona Summit Law School, LLC ; Infilaw Corporation ; Stephanie Lee ; Jason Lee ; Scott Thompson )Quarles & Brady, LLP2 North Central Avenue

Page 1 of 2

5/28/2015http://www.azd.uscourts.gov/cgi-bin/generate_civil_js44.pl


Phoenix, Arizona 85004-2391602.229.5200

II. Basis of Jurisdiction: 3. Federal Question (U.S. not a party)

III. Citizenship of Principal Parties (Diversity Cases Only)

Plaintiff:- N/ADefendant:- N/A

IV. Origin : 2. Removed From State Court

V. Nature of Suit: 445 Amer. w/Disabilities - Employment

VI.Cause of Action: 28 U.S.C. §1331, 28 U.S.C. §1367, 34 CFR 600

VII. Requested in ComplaintClass Action: No

Dollar Demand:Jury Demand: No

VIII. This case is not related to another case.

Signature: Michael S. Catlett

Date: 5/28/2015

If any of this information is incorrect, please go back to the Civil Cover Sheet Input form using the Back button in your browser and change it. Once correct, save this form as a PDF and include it as an attachment to your case opening documents.

Revised: 01/2014

Page 2 of 2

5/28/2015http://www.azd.uscourts.gov/cgi-bin/generate_civil_js44.pl


QB\152522.00007\35271791.1

SUPPLEMENTAL CIVIL COVER SHEET FOR CASES REMOVED FROM ANOTHER JURISDICTION

This form must be attached to the Civil Cover Sheet at the time

the case is filed in the United States District Clerk's Office.

Additional sheets may be used as necessary. _________________________________________________________________ 1. Style of the Case: Please include all Plaintiff(s), Defendant(s), Intervenor(s), Counterclaimant(s), Crossclaimant(s) and Third Party Claimant(s) still remaining in the case and indicate their party type. Also, please list the attorney(s) of record for each party named and include their bar number, firm name, correct mailing address, and phone number (including area code).

Party Party Type Attorney(s) Bar # Address Phone Paula Lorona Plaintiff Pro Per 12705 West Sierra Circle

El Mirage, AZ 85335

Arizona Summit Law School

Defendant Nicole F. Stanton Eric B. Johnson Michael S. Catlett

020452 020512 025238

Quarles & Brady LLP 2 North Central Renaissance One Phoenix, AZ 85004

602-229-5200

Infilaw Corporation Defendant Nicole F. Stanton Eric B. Johnson Michael S. Catlett

020452 020512 025238


602-229-5200

Stephanie Lee Defendant Nicole F. Stanton Eric B. Johnson Michael S. Catlett

020452 020512 025238


602-229-5200

Jason Lee Defendant Nicole F. Stanton Eric B. Johnson Michael S. Catlett

020452 020512 025238


602-229-5200

Scott Thompson Defendant Nicole F. Stanton Eric B. Johnson Michael S. Catlett

020452 020512 025238


602-229-5200

2. Jury Demand: Was a Jury Demand made in another jurisdiction? Yes No If "Yes," by which party and on what date? 3. Answer: Was an Answer made in another jurisdiction? Yes No If "yes," by which party and on what date? 4. Served Parties: The following parties have been served at the time this case was removed:


QB\152522.00007\35271791.1

Party Date Served Method of Service

Arizona Summit Law School 5/5/2015 Process Server

Infilaw Corporation 5/5/2015 Process Server

Stephanie Lee 5/6/2015 Process Server

Jason Lee 5/6/2015 Process Server

Scott Thompson 5/5/2015 Process Server

5. Unserved Parties: The following parties have not been served at the time this case was removed:

Party Reason Not Served

6. Nonsuited, Dismissed or Terminated Parties: Please indicate changes from the style of the papers from another jurisdiction and the reason for the change:

Party Reason for change

7. Claims of the Parties: The filing party submits the following summary of the remaining claims of each party in this litigation:

Party Claim(s)

Plaintiff 28 U.S.C. §1331, 28 U.S.C. 1367, 34 CFR 600

Pursuant to 28 USC §1446(a) a copy of all process, pleadings, and orders served in another jurisdiction (State Court) shall be filed with this removal.


Quarles & Brady LLP Firm State Bar No. 00443100 Phoenix, AZ … · 2015-07-30 · LLC et al.,...

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