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UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISRICT OF TEXAS 

WACO DIVISION

JESSE W. BODLEY, INDIVIDUALLY § 

AND AS PERSONAL REPRESENTATIVE § 

OF THE ESTATE OF WAYLON RENARD § 

BODLEY, DECEASED § 

 § 

V. § CIVIL ACTION NO. 6:20-CV-230 

 § 

ADAM AUTO HAULING, LLC § 

AND KARRAR F. SAHIB § 

NOTICE OF REMOVAL 

Defendants Adam Auto Hauling, LLC and Karrar F. Sahib (“Defendants”) file this 

Notice of Removal pursuant to 28 U.S.C. § 1332(a) to remove the present action to the 

United States District Court for the Western District of Texas, Waco Division, and state 

as follows: 

INTRODUCTION 

1. This lawsuit was initiated on February 4, 2020 when Plaintiff Jesse W. 

Bodley, Individually and as Personal Representative of the Estate of Waylon Renard 

Bodley, Deceased (“Plaintiff”), filed his Original Petition in Cause No. 20-0051CV in the 

369th Judicial District Court of Leon County, Texas against Defendants.1 The suit arises 

from a vehicular accident that occurred on or about March 31, 2018 in Leon County, 

Texas, resulting in the death of Waylon Renard Bodley (the “Incident”). 

 

1 See Plaintiff’s Original Petition, attached within Exhibit “B” and incorporated herein, at page 2. 

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2. Both Defendants Adam Auto Hauling, LLC and Karrar F. Sahib were 

served with Plaintiff’s Original Petition on February 28, 2020 in person and via certified 

mail. Defendants filed their Answer on March 23, 2020.2 

GROUNDS FOR REMOVAL—DIVERSITY OF CITIZENSHIP 

3. Removal is proper because there is complete diversity of citizenship 

between the parties and the alleged amount in controversy exceeds $75,000, exclusive 

of interest and costs. See 28 U.S.C. § 1332(a)(1). Plaintiff’s Original Petition states that 

Plaintiff seeks monetary relief over $1,000,000.00.3

4. Plaintiff Jesse W. Bodley is a resident and citizen of Texas.4 

5. Defendant Adam Auto Hauling, LLC was at all material times hereto 

(including as of the date of the Incident through the present) and remains a foreign 

corporation organized and existing under the laws of the State of Ohio with its principal 

place of business in Powell, Ohio.5 

6. Defendant Karrar F. Sahib also was at all material times hereto (including 

as of the date of the Incident through the present) and remains a resident of the State of 

Ohio, residing in Powell, Ohio.6 

VENUE IN THE WESTERN DISTRICT IS PROPER 

7. Plaintiff filed this action in Leon County, Texas. The Waco Division of the 

Western District of Texas encompasses Leon County, Texas. See 28 U.S.C § 124(c)(2). 

 

2 See Defendants Adam Auto Hauling, LLC and Karrar F. Sahib’s Original Answer to Plaintiff’s Original 

Petition, attached within Exhibit “B” and incorporated herein. 

3 See Exhibit B, Plaintiff’s Original Petition, page 7. 

4 Id., page 2. 

5 See Articles of Organization of Adam Auto Hauling, LLC, attached as Exhibit D and incorporated herein. 

6 See Declaration of Karrar F. Sahib, attached as Exhibit E and incorporated herein. 

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Thus, this district and division embrace the place where the state court action is 

pending. See 28 U.S.C. §1441(a). 

PROCEDURAL REQUIREMENTS FOR REMOVAL 

8. Defendants were served on February 28, 2020. This Notice of Removal is 

filed on March 26, 2020. Accordingly, this Notice of Removal is timely filed within 30 

days of when Defendants received Plaintiff’s Original Petition and within one year of the 

commencement of this suit. See 28 U.S.C. § 1446(b). 

NOTICE TO STATE DISTRICT COURT AND PLAINTIFF 

9. Defendants’ Notice of Removal has been served upon Plaintiff through his 

counsel by Notice of Filing/E-File along with email service. Defendants’ Notice of 

Removal is being promptly filed with the Clerk of the 369th Judicial District Court of Leon 

County and serves immediately to confer exclusive jurisdiction of this cause upon this 

Court, and divests the state court of all jurisdiction over these proceedings and claims. 

10. The filing fee has been paid to the Clerk. 

11. This Notice of Removal is filed subject to and without waiver of any 

defenses or objections to Plaintiff’s Original Petition as allowed by the Federal Rules of 

Civil Procedure or by any applicable law. 

INDEX OF EXHIBITS FILED 

12. Pursuant to 28 U.S.C. § 1446(a), this Notice of Removal is accompanied 

by the following documents: 

Exhibit A: An index of matters being filed; 

Exhibit B: The state court docket sheet, all executed process in the case, all 

pleadings asserting causes of action and all answers to such 

pleadings; 

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Exhibit C: A list of all counsel of record, including addresses, telephone 

numbers, and parties represented; 

Exhibit D: A copy of Adam Auto Hauling, LLC’s Articles of Organization; 

Exhibit E: Declaration of Karrar F. Sahib; and 

Exhibit F: Civil Cover Sheet. 

CONCLUSION 

Defendants Adam Auto Hauling, LLC and Karrar F. Sahib pray that this action be 

removed to this Court, that this Court accept jurisdiction of this action in its entirety, and 

that this action be placed on the docket of the Court for further proceedings as though 

this action had been initially instituted in this Court. 

Respectfully submitted, 

By: /s/ Elizabeth “Lisa” Massey 

ELIZABETH “LISA” MASSEY 

 Attorney in Charge 

Texas State Bar No. 24039039 

Federal I.D. No. 21558 

lmassey@hartlinebarger.com 

 Hartline Barger, LLP 

 1980 Post Oak Blvd., Suite 1800 

Houston, TX 77056 

(713) 759-1990 Telephone 

 (713) 652-2419 Facsimile 

ATTORNEYS FOR DEFENDANTS 

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing instrument was 

forwarded to all known counsel of record pursuant to the Texas Rules of Civil Procedure 

on this 26th day of March, 2020. 

 

/s/ Elizabeth “Lisa” Massey 

 ELIZABETH “LISA” MASSEY 

 

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