UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO.: ______________________________

JOSE ANTONIO JR SOSA,

Plaintiff,

vs.

GTI INDUSTRIES, INC.,

Defendant.

NOTICE OF REMOVAL

Defendant, GTI INDUSTRIES, INC. (“Defendant”), pursuant to 28 U.S.C. §§ 1441 and 

1446, hereby removes this action from the Circuit Court of the Eleventh Judicial Circuit in and 

for Miami-Dade County, Florida to the United States District Court for the Southern District of 

Florida. The removal of this action is based upon the following:

1. On or about March 9, 2020, Plaintiff, JOSE ANTONIO JR SOSA (“Plaintiff”), 

filed a civil action against Defendant in the Circuit Court of the Eleventh Judicial Circuit in and 

for Miami-Dade County, Florida, Case No. 2020-005568-CA-01 (“Circuit Court Action”)

alleging violations of the Fair Labor Standards Act, 29 U.S.C. § 201, et seq., (“FLSA”). A copy 

of all papers currently on file in the Circuit Court Action are attached hereto as Composite 

Exhibit A, as required by 28 U.S.C. § 1446(a). 

2. On March 31, 2020, Defendant was served with a copy of the Summons and 

Complaint in the Circuit Court Action. Thus, this notice of removal is timely filed pursuant to 

28 U.S.C. § 1446(b) in that it is filed within thirty (30) days from the date of service of Plaintiff’s

Complaint.

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3. Because Plaintiff has asserted claims under federal law based on the FLSA, this 

Court has original jurisdiction over this action under 28 U.S.C. § 1331, and Defendant is entitled 

to remove this action to this Court pursuant to 28 U.S.C. § 1441(a).

6. The United States District Court for the Southern District of Florida, Miami 

Division, embraces the location where the Circuit Court Action is pending. Thus, removal to this 

Court is proper pursuant to 28 U.S.C. § 1446(a).

7. Pursuant to 28 U.S.C. § 1446(d), Defendant has provided written notice of the 

removal to Plaintiff in this action and has filed a copy of this Notice of Removal in the Circuit 

Court of the Eleventh Judicial Circuit in and for Miami-Dade County, Florida. 

WHEREFORE, Defendant, GTI INDUSTRIES, INC., hereby removes this action from 

the Circuit Court of the Eleventh Judicial Circuit in and for Miami-Dade County, Florida, to this 

Court.

Dated: this 30th day of April 2020. Respectfully submitted,

By:/s/Patrick G. DeBlasio, III

Patrick G. DeBlasio, III

Florida Bar No.: 0871737

E-mail: pdeblasio@littler.com

Alexadra Mangas

Florida Bar No.: 106874

E-mail: amangas@littler.com

LITTLER MENDELSON, P.C.

Wells Fargo Center

333 SE 2nd Avenue, Suite 2700

Miami, FL 33131

Attorneys for Defendant

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CERTIFICATE OF SERVICE

I hereby certify that on this 30th day of April 2020, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document 

is being served this day on all counsel of record or pro se parties identified on the attached 

Service List in a manner specified, either via transmission of Notices of Electronic Filing 

generated by CM/ECF or in some other authorized manner for those counsel or parties who are 

not authorized to receive electronically Notices of Electronic Filing.

/s/ Patrick G. DeBlasio, III

Patrick G. DeBlasio, III

SERVICE LIST

COUNSEL FOR PLAINTIFF

Jason S. Remer, Esq.

Florida Bar No.: 165580

E-mail: jremer@rgpattorneys.com

REMER & GEORGES-PIERRE, PLLC

14 West Flagler Street, Suite 2200

Miami, FL 33130

Tel. 305.416.5000

Fax 305.416.5005

[Via Notice of Electronic Filing] 

4820-2885-7018.2

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