UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION 

CASE NO.: 

KASHWISE GLOBAL FUNDING 

SOLUTIONS INC., 

 Plaintiff, 

vs.

RIOT BLOCKCHAIN INC., 

 Defendant. 

_________________________________________/

DEFENDANT’S NOTICE OF REMOVAL 

To: The Honorable Judges of the United States District Court for the 

Southern District of Florida 

PLEASE TAKE NOTICE that Defendant, RIOT BLOCKCHAIN INC. (“Defendant”), by 

filing this Notice of Removal and related papers, removes this action from the Circuit Court, 

Seventeenth Judicial Circuit, Broward County, Florida to the United States District Court for the 

Southern District of Florida, Fort Lauderdale Division, pursuant to Fed. R. Civ. P. 81 and 28 

U.S.C. §§ 1332, 1441 and 1446. In support of this removal, Defendant states as follows: 

1. Plaintiff, KASHWISE GLOBAL FUNDING SOLUTIONS INC. (“Plaintiff”) 

filed this action in the Circuit Court, Seventeenth Judicial Circuit, Broward County, Florida, 

against Defendant on or about April 7, 2020. 

2. Included within Exhibit “A” hereto are true and correct copies of all process, 

pleadings and orders served upon Defendant. 

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3. This Court has original jurisdiction under 28 U.S.C. § 1332(a)(1) and (c)(1) 

because this is an action between citizens of different states and the amount in controversy 

exceeds $75,000.00, exclusive of interest and costs. 

4. In particular, Plaintiff is a Florida corporation with its principle place of business 

in Florida; Defendant is a Nevada corporation with its principle place of business in Colorado. 

See Complaint, ¶¶ 2-3; see also Ex. 1 to Complaint, at first sentence. Accordingly, Plaintiff is a 

citizen of the state of Florida, and Defendant is a citizen of the states of Nevada and Colorado. 

See 28 U.S.C. § 1332(c)(1). 

5. In addition, among other relief, Plaintiff seeks damages facially in excess of 

$75,000.00, exclusive of interest and costs. See Complaint, ¶¶ 4(b), 10, 16, 18, 23 and 

WHEREFORE clause. 

6. Defendant consents to the removal of this action and timely files this notice 

within 30 days after service of the Summons on Defendant. 

7. Venue is proper in this Court pursuant to 28 U.S.C. § 1441(a). 

8. Defendant will promptly file a copy of this notice with the Circuit Court, 

Seventeenth Judicial Circuit, Broward County, Florida as required by 28 U.S.C. § 1446(d). 

9. By reason of the above, this matter should be removed to this Court pursuant to 

28 U.S.C. §§ 1332, 1441 and 1446. 

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Respectfully submitted this 1st day of May, 2020. 

ROGERS TOWERS, P.A. 

/s/Christopher C. Hazelip 

Christopher C. Hazelip 

Florida Bar No.: 438049 

Samuel J. Horovitz 

Florida Bar No.: 59015 

1301 Riverplace Boulevard, Suite 1500 

Jacksonville, Florida 32207 

(904) 398-3911 (telephone) 

(904) 396-0663 (facsimile) 

Chazelip@rtlaw.com (email) 

Shorovitz@rtlaw.com (email) 

ATTORNEYS FOR DEFENDANT 

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that on May 1, 2020, I electronically filed the foregoing with the 

Clerk of Court by using the CM/ECF system and have served a copy on the following via email 

and regular U.S. Mail: 

Victor K. Rones, Esquire 

Victor K. Rones, P.A. 

16105 NE 18 Avenue 

North Miami Beach, Florida 33162 

Email: law@victorkronespa.com 

Attorney for Plaintiff 

/s/Christopher C. Hazelip 

Attorney 

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