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IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

EL PASO DIVISION

GREGORIOS SAKELLAKOS, 

Plaintiff, 

v. 

VERIZON WIRELESS TEXAS L.L.C., 

Defendant. 

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CIVIL ACTION NO. 

__________________________ 

Removed from the District 

Court of El Paso County, Texas, 

41st Judicial District, Cause No. 

2020DCV1666 

DEFENDANT’S NOTICE OF REMOVAL 

PLEASE TAKE NOTICE that Defendant Verizon Wireless Texas L.L.C. (“Verizon 

Wireless”/“Defendant”) hereby removes this civil action from the 41st Judicial District 

Court of El Paso County, Texas to the United States District Court for the Western District 

of Texas, pursuant to 28 U.S.C. § 1441(a) and (b), and § 1332, based on diversity 

jurisdiction. In support of this Notice, Defendant states as follows: 

I. STATE PROCEEDING 

1. The Plaintiff, Gregorios Sakellakos (“Sakellakos” or “Plaintiff”), 

commenced a civil action against Defendant in the 41st Judicial District Court of El Paso, 

Texas on May 18, 2020, styled “Gregorios Sakellakos v. Verizon Wireless Texas L.L.C.,” 

Cause No. 2020DCV1666. As required by 28 U.S.C. § 1446(a), copies of all executed 

process in the case; pleadings asserting causes of action; all orders signed by the state 

judge; the docket sheet; a list of all counsel of record; and an index of matters being filed 

are attached hereto as Exhibits 1 through 9. 

Case 3:20-cv-00179 Document 1 Filed 06/26/20 Page 1 of 6
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II. REMOVAL IS TIMELY 

Defendant was served with process and Plaintiff’s Original Petition on May 29, 

2020. Defendant files this notice of removal within thirty (30) days of service of the 

Original Petition, making removal timely under 28 U.S.C. § 1446(b).

III. DIVERSITY JURISDICTION 

2. This Court has original jurisdiction over this action under 28 U.S.C. 

§1332(a). Therefore, the cause may be removed to this Court pursuant to 28 U.S.C. 

§1441(b). 

3. Defendant is a limited liability corporation formed under the laws of the State 

of Delaware. See Plaintiff’s Petition ¶ 3; Exhibit 1 ¶ 4, Declaration of Karen M. Shipman. 

Defendant maintains its principal place of business in the State of Florida. Exh. 1 ¶ 4. 

4. Defendant’s sole member is a limited liability corporation formed under the 

laws of the State of Delaware with its principal places of business in the State of New 

Jersey. 

5. Plaintiff is an individual and a resident of Las Cruces, New Mexico. See

Plaintiff’s Petition ¶ 2. 

6. Accordingly, complete diversity exists in this case between Plaintiff and 

Defendant. 

IV. AMOUNT IN CONTROVERSY

7. The amount in controversy in this case exceeds the $75,000 threshold of 28 

U.S.C. § 1332. Plaintiff “seeks monetary relief over $200,000.00.” Plaintiff’s Petition ¶ 

16. 

Case 3:20-cv-00179 Document 1 Filed 06/26/20 Page 2 of 6
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V. REMOVAL IS PROPER 

8. There is complete diversity between Plaintiff and Defendant, and there is 

more than $75,000 in controversy. Accordingly, this action is one over which this court 

has original jurisdiction under the provisions of 28 U.S.C. § 1332(a)-(c) and removal is 

proper pursuant to 28 U.S.C. § 1441. 

VI. NOTICE TO STATE COURT AND OPPOSING PARTY 

9. Promptly upon the filing of this Notice of Removal, Defendant is filing a 

Notice of Filing Notice of Removal with the Clerk of Court for the 41st Judicial District 

Court of El Paso County, Texas and serving a copy thereof on Plaintiff through his counsel. 

A copy of Defendants’ Notice of Filing Notice of Removal is attached hereto and 

incorporated herein for all purposes as Exhibit 9. 

VII. CONCLUSION 

Defendants respectfully request that this Court exercise its jurisdiction over this 

action, and enter such further orders and grant such further relief as may be necessary to 

secure removal herein and to prevent further proceedings in the District Courts of El Paso 

County, Texas, and further seek all other relief to which they are justly entitled. 

Case 3:20-cv-00179 Document 1 Filed 06/26/20 Page 3 of 6
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Respectfully Submitted, 

JACKSON LEWIS P.C. 

 /s/ Jamie L. Houston 

William R. Stukenberg 

Texas State Bar No. 24051397 

William.Stukenberg@jacksonlewis.com

Jamie L. Houston 

Texas State Bar No. 24097847 

Jamie.Houston@jacksonlewis.com 

1415 Louisiana, Suite 3325 

Houston, Texas 77002-7332 

Telephone: (713) 650-0404 

Facsimile: (713) 650-0405 

ATTORNEYS FOR DEFENDANT

VERIZON WIRELESS TEXAS L.L.C. 

CERTIFICATE OF SERVICE 

I certify that I filed the foregoing document in accordance with the protocols for efiling through the CM/ECF system in the United States District Court for the Western 

District of Texas, El Paso Division, on June 26, 2020, and therefore has been served upon 

all counsel of record in accordance with such e-filing protocols. 

John P. Valdez 

DAVIE & VALDEZ P.C. 

1801 N. Stanton 

El Paso, Texas 79902 

Email: john@davievaldez.com 

Attorney for Plaintiff 

 /s/ Jamie L. Houston 

Jamie L. Houston 

4817-2676-6529, v. 1

Case 3:20-cv-00179 Document 1 Filed 06/26/20 Page 4 of 6
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IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

EL PASO DIVISION

GREGORIOS SAKELLAKOS, 

Plaintiff, 

v. 

VERIZON WIRELESS TEXAS L.L.C., 

Defendant. 

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CIVIL ACTION NO. 

__________________________ 

Removed from the District Court of 

El Paso County, Texas, 41st Judicial 

District, Cause No. 2020DCV1666 

INDEX OF MATTERS FILED 

Defendant Verizon Wireless Texas L.L.C., through the undersigned, provides the 

following index: 

Exhibit 1: Declaration of Karen M. Shipman 

Exhibit 2: Docket Sheet 

Exhibit 3: Plaintiff’s Original Petition 

Exhibit 4: Case Information Sheet 

Exhibit 5: Request for Citation Issuance to Defendant Verizon Wireless Texas, LLC 

Exhibit 6: Return of Service 

Exhibit 7: Defendant’s Answer and Affirmative Defenses to Plaintiff’s Original 

Petition 

Exhibit 8: Supplement to JS Civil Cover Sheet 

Exhibit 9: Notice of Filing Notice of Removal to State Court 

Case 3:20-cv-00179 Document 1 Filed 06/26/20 Page 5 of 6
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Respectfully Submitted, 

JACKSON LEWIS P.C. 

 /s/ Jamie L. Houston 

William R. Stukenberg 

Texas State Bar No. 24051397 

William.Stukenberg@jacksonlewis.com

Jamie L. Houston 

Texas State Bar No. 24097847 

Jamie.Houston@jacksonlewis.com 

1415 Louisiana, Suite 3325 

Houston, Texas 77002-7332 

Telephone: (713) 650-0404 

Facsimile: (713) 650-0405 

ATTORNEYS FOR DEFENDANT

VERIZON WIRELESS TEXAS L.L.C. 

CERTIFICATE OF SERVICE 

I certify that I filed the foregoing document in accordance with the protocols for e-filing 

through the CM/ECF system in the United States District Court for the Western District of Texas, 

El Paso Division, on June 26, 2020, and therefore has been served upon all counsel of record in 

accordance with such e-filing protocols. 

John P. Valdez 

DAVIE & VALDEZ P.C. 

1801 N. Stanton 

El Paso, Texas 79902 

Email: john@davievaldez.com 

Attorney for Plaintiff 

 /s/ Jamie L. Houston 

Jamie L. Houston 

4817-2676-6529, v. 1

Case 3:20-cv-00179 Document 1 Filed 06/26/20 Page 6 of 6