Scott Law Team, LLC 

Defendant’s Notice of Removal of Civil Action 

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UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 

ALEX NAVARRO, 

 Plaintiff, 

v. 

THE KEYES COMPANY, 

 Defendant. 

____________________/ 

DEFENDANT’S NOTICE OF REMOVAL OF CIVIL ACTION 

Defendant, THE KEYES COMPANY, by and through its undersigned counsel hereby 

provides Notice to this Court of the Removal of this case from the Eleventh Judicial Circuit in and 

for Miami-Dade County, Florida to this Court and states as follows: 

On August 5, 2022, Plaintiff commenced this action in the Eleventh Judicial Circuit in and 

for Miami-Dade County, Florida, Case No. 2022-014684 CA (21) entitled Alex Navarro v. The 

Keyes Company. 

Defendant, through their undersigned counsel, executed a waiver of service on August 11, 

2022. 

Defendant removes this matter under original federal question jurisdiction under 28 U.S.C. 

1441(a). 

I. STATEMENT OF THE GROUNDS FOR REMOVAL 

 This Notice of Removal is based on federal question jurisdiction pursuant to 28 U.S.C. § 1331, 

1367, 1441 and 1446. 

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II. EXHIBITS SUBMITTED IN SUPPORT OF NOTICE OF REMOVAL 

In accordance with 28 U.S.C. 1446(a) copies of all process, pleadings, papers and orders 

now on file in the state court are attached as set forth below: 

 Federal Civil Cover Sheet 

 Complaint (Exhibit 1) 

 Waiver of Service (Exhibit 2) 

III. TIMELINESS OF REMOVAL 

This Notice of Removal is based upon based upon 28 U.S.C. §§ 1331 and 1441. Those sections 

provide that an action shall be removable if the Federal Court has original jurisdiction over the 

subject matter of the Complaint. 28 U.S.C. 1441. Original jurisdiction arises where the controversy 

in the civil action involves a "federal question." 28 U.S.C. § 1331. Here there is a claim under the 

federal statute 29 U.S.C. § § 201, 207. 

IV. BASIS FOR FEDERAL QUESTION JURISDICTION 

This Court has federal question jurisdiction over this action pursuant to 28 U.S.C. § 1331 in 

the jurisdiction and venue section of the Complaint. Plaintiff alleges violation of the Fair Labor 

Standards Act, 29 U.S.C. § 207. 

V. OTHER MATTERS 

Following the filing of this Notice with the Court, written notice of the filing of same will be provided 

to the attorney for Plaintiff as required by law. 

Notice of this removal will be filed with the clerk of court of the Circuit Court in and for MiamiDade County, Florida. 

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VI. CONCLUSION 

Wherefore, this Court has original federal question of jurisdiction of the action under 28 

U.S.C. § 1331 and the action is removable pursuant to the provision of 28 U.S.C. §§ 1441 and 

1446. As such, Defendant respectfully hat this action proceed in this Court as an action properly 

removed pursuant to 28 U.S.C. § 1331, 1367, 1441 and 1446. 

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing was served by e-mail on 

September 9, 2022, on all counsel or parties of record on the Service List below. 

s/Gabriel T. Roberts 

Gabriel “Gabe” T. Roberts, Esq. 

Florida Bar No. 1018435 

Primary e-mail: groberts@scottlawteam.com 

Secondary e-mail: mail@scottlawteam.com

SCOTT LAW TEAM, LLC 

Jupiter Gardens 

250 South Central Boulevard, Suite 104-A 

Jupiter, FL 33458 

Telephone: (561) 653-0008 

Facsimile: (561) 653-0020 

Secondary Address: 101 Northpoint Parkway 

West Palm Beach, FL 33407 

           www.ScottLawTeam.com 

SERVICE LIST 

 

Martin E. Leach, Esq. 

Florida Bar No. 0037990 

FEILER & LEACH, P.L. 

Attorneys for Plaintiff 

The American Airlines Building 

901 Ponce de Leon Boulevard 

Suite # 300 

Coral Gables, Florida 33134 

Telephone (305) 441-8818 

Facsimile (305) 441-8081 

Email: mel@flmlegal.com 

erodriguez@flmlegal.com 

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