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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

TALLAHASSEE DIVISION

SCHEVONNE PAIGE,

Plaintiff,

CASE NO.: 4:20-cv-83

v.

THE DISTRICT BOARD OF TRUSTEES OF

TALLAHASSEE COMMUNITY COLLEGE,

Defendant.

__________________________________________/

DEFENDANT’S NOTICE OF REMOVAL

Defendant, THE DISTRICT BOARD OF TRUSTEES OF TALLAHASSEE 

COMMUNITY COLLEGE, by and through its undersigned counsel, files this 

Notice of Removal and would show the Court as follows:

1. The District Board of Trustees of Tallahassee Community College is 

the Defendant in an action in the Circuit Court of the Second Judicial Circuit, in and 

for Leon County, Florida, styled as: Schevonne Paige v. Board of Trustees for

Tallahassee Community College, Case Number 2019 CA 001191.

2. Defendant was first served with Plaintiff’s First Amended Complaint 

for said action on January 13, 2020.

3. No further proceedings have transpired in regard to the abovereferenced action in the Circuit Court of the Second Judicial Circuit, in and for Leon 

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County, Florida, except the following documents attached to this Notice as Exhibit 

“A”: Civil Cover Sheet, Complaint, Summonses, Returns of Service, Defendant’s

Motion to Dismiss Plaintiff’s Complaint, Notice of Hearing, Notice of Cancellation 

of Hearing, Plaintiff’s First Amended Complaint, and Defendant’s Motion to 

Dismiss Plaintiff’s First Amended Complaint.

4. Defendant has not yet scheduled a hearing on its Motion to Dismiss 

Plaintiff’s First Amended Complaint.

5. This is an action brought by Plaintiff under 20 U.S.C. § 1681(a) (Title 

IX of the Education Amendments of 1972), and the common law of Florida against 

Defendant alleging assault, battery, false imprisonment, negligence, negligent 

training and supervision, and violations of Title IX.

6. This Court has original jurisdiction of this matter pursuant to 28 U.S.C. 

§ 1331, and therefore, this action may be removed to this Court pursuant to 28 U.S.C. 

§§ 1441 and 1446.

WHEREFORE, Defendant, THE DISTRICT BOARD OF TRUSTEES OF 

TALLAHASSEE COMMUNITY COLLEGE, requests this Court order that this 

action be properly removed from the Circuit Court of the Second Judicial Circuit, in 

and for Leon County, Florida, take jurisdiction of this action, and conduct all further 

proceedings in the United States District Court for the Northern District of Florida, 

Tallahassee Division.

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Respectfully submitted,

s/ Ross D. Vickers

J. Craig Knox (Florida Bar #0286729)

Ross D. Vickers (Florida Bar #121717)

ANDREWS, CRABTREE, KNOX & LONGFELLOW, LLP

1558 Village Square Boulevard, Suite 1

Tallahassee, FL 32309

Telephone: (850) 297-0090

Facsimile: (850) 297-0219

cknox@andrewscrabtree.com

rvickers@andrewscrabtree.com

jhartsfield@andrewscrabtree.com

lthornton@andrewscrabtree.com

Attorneys for Defendant, The District Board of Trustees of 

Tallahassee Community College

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 11th day of February 2020, I electronically 

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

that the foregoing document is being served this day on all counsel of record 

identified below, via Notice of Electronic Filing generated by CM/ECF, and/or by 

other means of electronic transmission:

Marie A. Mattox, Esq.

MARIE A. MATTOX, P.A.

310 East Bradford Road

Tallahassee, FL 32303

marie@mattoxlaw.com

marlene@mattoxlaw.com

michelle2@mattoxlaw.com

federalcourt@mattoxlaw.com

Attorneys for Plaintiff, Schevonne Paige

s/ Ross D. Vickers

Ross D. Vickers

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