UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO. ___________________ 

KAREEM PICKERING and AARON ) 

MUHAMMED, ) 

) 

Plaintiffs, ) 

) 

v. ) 

) 

AKAL SECURITY, INC., ) 

) 

Defendant. ) 

__________________________________________) 

DEFENDANT’S NOTICE OF AND PETITION FOR REMOVAL 

Defendant, Akal Security, Inc. (“Defendant”), by and through its undersigned 

counsel and in accordance with the applicable Federal Rules of Civil Procedure and 28 U.S.C. §§ 

1331, 1367, 1441, and 1446, hereby files this Notice of and Petition for Removal (the “Notice”). 

Defendant requests that the Court remove this action filed by Plaintiffs, Kareem Pickering and 

Aaron Muhammed (“Plaintiffs”), 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, Miami Division. The removal of this action is based upon the following: 

1. On or about July 1, 2020, Plaintiffs filed their Complaint in the Circuit 

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

Pickering and Aaron Muhammed v. Akal Security, Inc. (the “Circuit Court case”). The Circuit 

Court case was assigned case number 2020-013938-CA-01. In the Complaint, Plaintiffs alleges: 

(1) race discrimination in violation of the Florida Civil Rights Act (“FCRA”) (Count I); and (2) 

national origin discrimination in violation of the FCRA (Count II). 

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2. Plaintiffs are citizens of the state of Florida. See Complaint, ⁋4.

Defendant is incorporated in New Mexico and its principle place of business is also located at 7 

Infinity Loop, Espanola, New Mexico 87532. Plaintiffs seek as damages: lost past and future 

income; loss of fringe benefits; damage to reputation, confidence and self-esteem; loss of future 

earning capacity; stress, anxiety and emotional distress; significant past and future pain and 

suffering; unspecified other financial losses; and attorney’s fees, expert fees, litigation costs and 

expenses. See Complaint, ⁋18,19, 23 and 24. Plaintiff were terminated by Defendant on

September 19, 2018. See Complaint, ⁋10. At the time of their termination, Plaintiffs were paid

an hourly rate of $30.49 in addition to a uniform allowance of $.45 per hour, H&W contribution 

of $4.90 per hour, and a pension contribution of $1.47 per hour for a total hourly compensation 

of $37.31. See page 29 of applicable Collective Bargaining Agreement, attached as Exhibit “1.” 

The lost wages alone claimed by each Plaintiff exceeds $144,762.00 to date. Id. 

3. Because Plaintiffs and Defendant are citizens of different states and the 

amount in controversy exceeds $75,000, this action is within the diversity question jurisdiction 

of the United States District Court pursuant to 28 U.S.C. § 1332. Thus, this action is removable 

pursuant to 28 U.S.C. § 1441(a) and (b). 

3. Additionally, Plaintiff effectuated service of process on Defendant on July 

14, 2020. Therefore, this Notice has been filed within thirty days after service upon Defendant 

of the pleading setting forth the claims for relief upon which this removal is based, as required by 

28 U.S.C. § 1446(b). See Plaintiffs’ July14, 2020 Return of Service attached as Exhibit “2.” 

5. As required by 28 U.S.C. § 1446(a), a copy of all process, pleadings, and 

orders served upon Defendant is attached to this Notice as Exhibit “3.” 

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6. Pursuant to 28 U.S.C. § 1446(d), Defendant will provide promptly written 

notice of the removal to all adverse parties in this action and will file a copy of this Notice with 

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

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

Miami Division, includes the judicial county in which Plaintiff filed his Complaint. Thus, 

removal is proper to this Court. 

WHEREFORE, Defendant, Akal Security, Inc., respectfully requests that the 

United States District Court for the Southern District of Florida accept the removal of this action 

from the Circuit Court and direct that the Circuit Court in and for Miami-Dade County, Florida 

has no further jurisdiction of this matter unless and until this case is remanded. 

Dated: July 29, 2020 

Respectfully submitted, 

JACKSON LEWIS P.C. 

One Biscayne Tower, Suite 3500 

2 South Biscayne Boulevard 

Miami, Florida 33131 

Telephone: 305-577-7600 

s/ Neil D. Kodsi

Neil D. Kodsi, Esq. 

Florida Bar No. 0011255 

E-mail: neil.kodsi@jacksonlewis.com

Counsel for Akal Security, Inc. 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on this 29th day of July. 2020, I electronically filed the 

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

document is being served this day on all counsel of record identified on the attached Service List 

via transmission of Notices of Electronic Filing generated by CM/ECF. 

s/ Neil D. Kodsi 

Neil D. Kodsi, Esq. 

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SERVICE LIST 

Chad E. Levy, Esq. 

E-mail: chad@levylevylaw.com 

David M. Kozad, Esq. 

E-mail: david@levylevylaw.com 

Law Offices of Levy & Levy, P.A. 

1000 Sawgrass Corporate Parkway, Suite 588 

Sunrise, Florida 33323 

Telephone: 954-763-5722 

Counsel for Plaintiffs 

Neil D. Kodsi, Esq. 

E-mail: neil.kodsi@jacksonlewis.com 

JACKSON LEWIS P.C. 

One Biscayne Tower, Suite 3500 

2 South Biscayne Boulevard 

Miami, Florida 33131 

Telephone: 305-577-7600 

Counsel for Akal Security, Inc. 

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