BILZIN SUMBERG BAENA PRICE & AXELROD LLP 

1450 Brickell Avenue, Suite 2300, Miami, FL 33131-3456 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

CASE NO. ___________________ 

DONALD J. TRUMP, 

 Plaintiff, 

v. 

LETITIA JAMES, 

 Defendant. 

________________________________/ 

DEFENDANT’S NOTICE OF REMOVAL 

Defendant Letitia James, Attorney General of the State of New York (“Attorney General 

James”), by and through her undersigned counsel, hereby removes this action from the Circuit 

Court of the Fifteenth Judicial Circuit in and for Palm Beach County, Florida Civil Division, Case 

No. 2022-CA-10792 (“State Court Action”), to the United States District Court for the Southern 

District of Florida pursuant to 28 U.S.C. §§ 1331, 1332, 1441, and 1446, and states as follows: 

1. On or about November 2, 2022, Plaintiff commenced the State Court Action by 

filing a Civil Cover Sheet, Summons, and Complaint in the Palm Beach County Clerk’s Office. 

2. On or about November 15, 2022, Plaintiff filed an Amended Complaint in the State 

Court Action. 

3. Along with the Amended Complaint, Plaintiff also filed an Emergency Motion for 

Temporary Injunction and Request for Judicial Notice. 

4. Although Attorney General James has not been served with any process, pleadings, 

or orders in the State Court Action, a copy of the Summons, Complaint, Amended Complaint, 

Emergency Motion for Temporary Injunction, Plaintiffs’ Notice of Filing, and Request for Judicial 

Notice filed in the State Court Action are attached as Composite Exhibit A. 

Case 9:22-cv-81780-DMM Document 1 Entered on FLSD Docket 11/16/2022 Page 1 of 4
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BILZIN SUMBERG BAENA PRICE & AXELROD LLP 

1450 Brickell Avenue, Suite 2300, Miami, FL 33131-3456 

5. The State Court Action is a civil action. The Amended Complaint appears to assert 

violations of Plaintiff’s rights under the U.S. Constitution (Count I), rights to privacy and property 

under Florida law (Count II), and rights as a trust grantor and beneficiary (Count III) as a result of 

conduct undertaken by Attorney General James in commencing and pursuing an enforcement 

action under New York Executive Law § 63(12) based upon alleged fraud and illegality by Plaintiff 

in the conduct of his New York-based business. Plaintiff’s State Court Action seeks compensatory 

and punitive damages as well as declaratory relief and to preliminarily and permanently enjoin 

Attorney General James, together with others, from requesting, demanding, obtaining, possessing, 

or disclosing a copy of Plaintiff’s revocable trust or the terms thereof, or of restraining Plaintiff’s 

ability to amend, modify or revoke the trust. 

6. Plaintiff is a citizen of Florida in accordance with his Declaration of Domicile dated 

September 27, 2019 filed in the Public Records of Palm Beach County, Florida at OR BK 30932 

PG 0239 on October 4, 2019. Plaintiff also alleges in the Amended Complaint that he is a resident 

of Florida. See Amended Complaint at ¶¶ 1, 13. 

7. Attorney General James is a citizen of New York. Count I of Plaintiff’s Amended 

Complaint is brought pursuant to 28 U.S.C. §§ 1983 and 1988. The amount in controversy exceeds 

$75,000 exclusive of interest and costs, to wit, the Amended Complaint alleges, Plaintiff “has thus 

been damages by Defendant’s unlawful conduct at trial [sic] but includes: (1) potentially as high 

as $250,000,000 in confiscation from the civil action; (2) legal fees and costs incurred in defending 

against the campaign of retaliation; (3) and other damages in an amount to be proven at trial.” See

Amended Complaint at ¶ 120; see also ¶ 9 (Plaintiff “seeks damages . . . compensatory damages 

up to $250,000,000”). Accordingly, removal is proper under 28 U.S.C. §§ 1331, 1332, 1441, and 

1446. 

8. Further, the State Court Action is pending in a state court within the Southern 

Case 9:22-cv-81780-DMM Document 1 Entered on FLSD Docket 11/16/2022 Page 2 of 4
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BILZIN SUMBERG BAENA PRICE & AXELROD LLP 

1450 Brickell Avenue, Suite 2300, Miami, FL 33131-3456 

District of Florida and removal and venue to this Court is therefore proper under 28 U.S.C. 

§ 1446(a). 

9. Removal is also timely under 28 U.S.C. § 1446(b)(1). Plaintiff’s counsel has not 

yet effected service of the State Court Action on Attorney General James, and the State Court 

Action was only first filed with the Clerk for the Circuit Court of the Fifteenth Judicial Circuit in 

Palm Beach County, Florida, Civil Division on November 2, 2022. 

10. Attorney General James will serve written notice of the removal of this action upon 

Plaintiff and Plaintiff’s attorney in the State Court Action promptly and will file such notice with 

the Clerk for the Circuit Court of the Fifteenth Judicial Circuit in Palm Beach County, Florida, 

Civil Division, as required by 28 U.S.C. § 1446(d). 

11. Attorney General James expressly reserves all defenses (including with respect to 

personal jurisdiction), ability to otherwise move with respect to the Amended Complaint, and to 

deny any liability. 

12. Attorney General James therefore respectfully notices the removal of the State 

Court Action to the United States District Court for the Southern District of Florida. 

Dated: November 16, 2022 Respectfully submitted, 

BILZIN SUMBERG BAENA PRICE 

& AXELROD LLP 

Counsel for Letitia James 

1450 Brickell Ave., Suite 2300 

Miami, Florida 33131 

Telephone: 305-374-7593 

Facsimile: 305-351-2253 

 By: /s/ Melissa Pallett-Vasquez 

 Melissa Pallett-Vasquez 

 Florida Bar No. 715816 

Jeffrey Snyder 

Florida Bar No. 21281 

Robert Turken 

Florida Bar No. 306355 

 mpallett@bilzin.com 

Case 9:22-cv-81780-DMM Document 1 Entered on FLSD Docket 11/16/2022 Page 3 of 4
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BILZIN SUMBERG BAENA PRICE & AXELROD LLP 

1450 Brickell Avenue, Suite 2300, Miami, FL 33131-3456 

 jsnyder@bilzin.com 

 rturken@bilzin.com 

 stapanes@bilzin.com 

vlopez@bilzin.com 

asolis@bilzin.com 

eservice@bilzin.com 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on November 16, 2022, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF and served via email on the below 

individuals: 

Timothy W. Weber, Esq. 

Timothy.weber@webercrabb.com 

Jeremy D. Bailie, Esq. 

Jeremy.bailie@webercrabb.com 

R. Quincy Bird, Esq. 

Quincy.Bird@webercrabb.com 

Weber, Crabb & Wein, P.A 

5453 Central Avenue 

St. Petersburg, Florida 33710 

 /s/Melissa Pallett-Vasquez 

 Melissa Pallett-Vasquez 

Case 9:22-cv-81780-DMM Document 1 Entered on FLSD Docket 11/16/2022 Page 4 of 4