UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

SAN ANTONIO DIVISION

CLAUDIA ARIAS § 

§ 

VS. § C.A. NO. _____________ 

§ 

WALMART, INC. § JURY DEMANDED

NOTICE OF REMOVAL OF ACTION UNDER 28 U.S.C. ' 1441

TO THE CLERK OF THE ABOVE ENTITLED COURT:

Please take notice that Defendant, Wal-Mart, Inc. hereby removes to the Court the state 

action described below.

1. On March 17, 2020, a civil action was commenced, in the 225th Judicial District

Court of Bexar County, Texas, entitled Claudia Arias v. Wal-Mart, Inc.; Cause No2020CI05627. 

A copy of Plaintiff=s Original Petition is attached hereto as Exhibit A.

2. Service of summons and complaint was made on Defendant, Wal-Mart, Inc. by

process server on March 19, 2020. Defendant, Wal-Mart, Inc. first received a copy of said 

Petition on March 25, 2020. A copy of the Citation is attached hereto as Exhibit B.

3. Defendant has filed an Original Answer, which is attached as Exhibit C, a Demand

for Jury Trial, which is attached as Exhibit D and a Notice of Filing of Removal to Federal Court, 

attached as Exhibit E. Defendant has attached all process, pleadings, and orders in the State 

Court action as required by 28 U.S.C. 1446(a). 

JURISDICTION AND VENUE 

4. The action is a civil action of which this Court has original jurisdiction under Title 28

U.S.C. ' 1332 (Diversity Jurisdiction), and is one which may be removed to this Court pursuant to 

Title 28 U.S.C. ' 1441. There is complete diversity of citizenship amongst the parties. 

Defendant Walmart, Inc. is incorporated under the laws of the state of Delaware with its principal 

place of business in Bentonville, Arkansas. As such, Defendant Walmart, Inc. is not a Texas 

5:20-cv-476

Case 5:20-cv-00476 Document 1 Filed 04/16/20 Page 1 of 4
citizen. Plaintiff is a Texas citizen, with her residence in Bexar County, Texas.

5. The amount in controversy exceeds the sum of Seventy-five Thousand Dollars 

($75,000.00), exclusive of interest and costs. See page 10 of Plaintiff=s Original Petition. 

7. Venue is proper in the Western District of Texas, San Antonio Division because 

this District and Division embrace the place in which the action is pending. 

Dated: April 16, 2020

Respectfully submitted,

Daw & Ray

A Limited Liability Partnership

 /s/ Willie Ben Daw, III 

Willie Ben Daw, III; TBN: 05594050

Email: wbdaw@dawray.com

James K. Floyd; TBN: 24047626

Email: jfloyd@dawray.com 

14100 San Pedro Ave., Suite 302

San Antonio, Texas 78232

(210) 224-3121 Telephone

(210) 224-3188 Facsimile

ATTORNEYS FOR DEFENDANT

Case 5:20-cv-00476 Document 1 Filed 04/16/20 Page 2 of 4
CERTIFICATE OF SERVICE

The undersigned does hereby certify that a true and correct copy of the above and 

foregoing instrument has been served upon all known counsel of record by electronic service on 

this the 16th day of April, 2020.

Alexander Begum

Bryan Schoeppey Email: bryan@vblawgroup.com

Villarreal & Begum, PLLC

5826 IH-10 West 

San Antonio, Texas 78201

 /s/ Willie Ben Daw, III 

Willie Ben Daw, III

Case 5:20-cv-00476 Document 1 Filed 04/16/20 Page 3 of 4
UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

SAN ANTONIO DIVISION

CLAUDIA ARIAS §

§

VS. § C.A. NO. _____________

§

WALMART, INC. § JURY DEMANDED

INDEX OF DOCUMENTS FILED WITH REMOVAL ACTION

(A) Plaintiff=s Original Petition and Discovery

(B) Citation

(C) Defendant’s Original Answer

(D) Defendant’s Demand for Jury Trial

(E) Notice of Filing of Removal to Federal Court

(F) List of Counsel of Record

Case 5:20-cv-00476 Document 1 Filed 04/16/20 Page 4 of 4