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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

TALLAHASSEE DIVISION

REBEKAH JONES,

Plaintiff,

CASE NO.: 4:21-CV-00054

v.

RICK SWEARINGEN, individually, and in

his official capacity as Commissioner of 

The FLORIDA DEPARTMENT OF 

LAW ENFORCEMENT; NOEL PRATTS, 

individually; and FDLE AGENT JOHN DOE,

individually. 

Defendants.

__________________________________________/

DEFENDANTS’ NOTICE OF REMOVAL

Defendants, RICK SWEARINGEN, individually, and in his official capacity 

as Commissioner of The FLORIDA DEPARTMENT OF LAW ENFORCEMENT, 

and NOEL PRATTS, individually, by and through their undersigned counsel, file 

this Notice of Removal and would show the Court as follows:

1. Rick Swearingen and Noel Pratts are the Defendants in an action in the 

Circuit Court of the Second Judicial Circuit, in and for Leon County, Florida, styled 

as: Rebekah Jones v. Rick Swearingen, individually, and in his official capacity as 

Commissioner of The Florida Department of Law Enforcement; Noel Pratts, 

individually, and FDLE Agent John Doe, Case Number 2020 CA 002349.

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2. Defendants were first served with Plaintiff’s Complaint for said action 

on 12/28/2020.

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 

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

“A,” including: Civil Cover Sheet, Complaint, Plaintiff’s Motion to Compel Return 

of Property, Summonses, Returns of Service, Plaintiff’s Notice of Hearing, Notices 

of Appearance, Defendant Swearingen’s Memorandum in Opposition to Plaintiff’s 

Motion to Compel Return of Property, and Defendants’ Motion to Dismiss Counts 

I, II, and III of Plaintiff’s Complaint. A hearing was held on Plaintiff’s Motion to 

Compel Return of Property.

4. This is an action brought by Plaintiff under 42 U.S.C. §1983 (Civil 

Action for Deprivation of Rights), and the common law of Florida against 

Defendants alleging violation of Plaintiff’s constitutional rights under the First 

Amendment, Fourth Amendment, and Fourteenth Amendment to the United States 

Constitution.

5. 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.

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WHEREFORE, Defendants, RICK SWEARINGEN, individually, and in his 

official capacity as Commissioner of The FLORIDA DEPARTMENT OF LAW 

ENFORCEMENT, and NOEL PRATTS, individually, request 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.

Respectfully submitted,

s/ J. Craig Knox

J. Craig Knox (Florida Bar #0286729)

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

jhartsfield@andrewscrabtree.com

lthornton@andrewscrabtree.com

Attorneys for Defendants, Rick Swearingen and Noel Pratts

CERTIFICATE OF FONT/WORD COUNT

I HEREBY CERTIFY this Notice of Removal contains 616 words and is 

typed in 14-point Times New Roman font.

s/ J. Craig Knox

J. Craig Knox 

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 26th day of January 2021, 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:

Richard E. Johnson, Esq.

LAW OFFICE OF RICHARD E. JOHNSON

314 West Jefferson Street

Tallahassee, FL 32301

rick@rej-law.com

Lawrence G. Walters, Esq.

WALTERS LAW GROUP

195 West Pine Avenue

Longwood, FL 32750

larry@firstamendment.com

paralegal@firstamendment.com

Lisa C. Lambert, Esq.

LAW OFFICE OF LISA C. LAMBERT

245 N. Highland Avenue NE, Suite 230-139

Atlanta, GA 30307-1936

lisa@civil-rights.attorney

Attorneys for Plaintiff, Rebekah Jones

s/ J. Craig Knox

J. Craig Knox

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