DEFENDANT’S NOTICE OF REMOVAL PAGE 1 

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

AMANDA HARDIN, individually § 

and as next friend of G.B., a minor § 

Plaintiffs § 

 § 

v. § CIVIL ACTION NO. ___________ 

 § 

PUNJAB TRUCKING LLC § 

FORWARD AIR, INC., and § 

KUMAR SUSHIL § 

Defendants § 

DEFENDANT’S NOTICE OF REMOVAL 

Pursuant to 28 U.S.C. 1332, 1441 and 1446, Defendant Forward Air, Inc. (“Defendant”) 

files this Notice of Removal from the 17th Judicial District Court of Tarrant County, Texas, to the 

United States District Court for the Northern District of Texas, Fort Worth Division, and 

respectfully states the following: 

State C

1. On March 2, 2022, Plaintiff Amanda Hardin, Individually and as next friend of 

G.B., a minor, (“Plaintiff”) initiated this action by filing Plaintiff’s Original Petition (the 

“Petition”), Cause No. 017-332243-22, in the 17th Judicial District Court of Tarrant County, Texas 

(the “State Court Action”) against Defendant, Punjab Trucking, LLC and Kumar Sushil. Plaintiff 

asserts claims of negligence and negligence per se against Defendant Sushil and claims of 

respondeat superior against Forward Air, Inc and Punjab Trucking LLC. Since that original filing, 

Plaintiff has non-suited Punjab Trucking LLC. Plaintiff claims injuries allegedly sustained by 

Plaintiff in an automobile accident.

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DEFENDANT’S NOTICE OF REMOVAL PAGE 2

Timeliness of Removal

2. Defendant was served with Plaintiff’s Petition on March 9, 2022. 

3. Defendant files this Notice of Removal within thirty days after receipt of service of 

Plaintiff’s Petition. Thus, pursuant to 28 U.S.C. 1446(b), Defendant’s removal of this action is 

timely.

Grounds for Removal

4. Pursuant to 28 U.S.C. 1441(a), the State Court Action may be removed to this Court 

because this Court has original jurisdiction of the claims and parties in the State Court Action 

under 28 U.S.C. 1332. The United States District Court for the Northern District of Texas, Fort 

Worth Division, is the proper venue for this action because it presides over the district and division 

within which the State Court Action was filed (Tarrant County). See 28 U.S.C. 1441(a).

5. Plaintiff is a resident and citizen of the State of Texas. See Plaintiff’s Original 

Petition, Para. IV, attached hereto as Exhibit A-2.

6. Defendant is a Tennessee corporation with its principal place of business in 

Greeneville, Tennessee. Thus, Defendant is domiciled in Tennessee. 

7. Punjab Trucking LLC was alleged to be domiciled in Arlington, Texas but since 

Defendant filed its answer, Plaintiff has nonsuited Punjab from the lawsuit. Punjab is therefore 

no longer relevant to any removal considerations. 

8. Complete diversity of citizenship therefore exists between Plaintiff and Defendant. 

9. The amount in controversy exceeds $75,000, excluding interest, costs and 

attorney’s fees. See Plaintiff’s Original Petition, Para. II, attached hereto as Exhibit A-2, indicating 

that Plaintiff seeks damages in excess of $1,000,000.00. 

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DEFENDANT’S NOTICE OF REMOVAL PAGE 3

Required Documents

10. The following documents are attached in accordance with LR81:

a. A completed civil cover sheet;

b. A supplemental civil cover sheet; and

c. A notice of removal with a copy of each of the following:

i. an index of all documents that clearly identifies each document and 

indicates the date the document was filed in state court, attached 

hereto as Exhibit A;

ii. a copy of the docket sheet in the state court action, attached hereto 

as Exhibit A-1;

iii. each document filed in the state court action, except discovery 

material, attached hereto as Exhibits A-2 through A-15; and

iv. a separately signed certificate of interested persons.

Notice of Removal

11. Pursuant to 28 U.S.C. 1446(d), written notice of the filing of this Notice of Removal 

to all adverse parties and a true and correct copy of this Notice of Removal will be filed with the 

Clerk of the 17th Judicial District Court of Tarrant County, Texas.

Request for Relief

12. Defendant requests the following relief:

a. That the Court make such orders, if any, and take such action, if any, as may 

be necessary in connection with the removal of the State Court Action to 

this Court; and

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DEFENDANT’S NOTICE OF REMOVAL PAGE 4 

b. Such other and further relief, both general and special, at law and in equity, 

to which Defendant may show itself justly entitled.

Respectfully submitted,

COX P.L.L.C 

 

 Clinton V. Cox, IV 

State Bar No. 24040738 

ccox@coxpllc.com

 Gregory R. Brenner

State Bar No. 24027052 

gbrenner@coxpllc.com 

 8144 Walnut Hill Lane, Suite 1090 

 Dallas, Texas 75231 

 Tel: (214) 444-7050 

Fax: (469) 340-1884 

ATTORNEYS FOR DEFENDANT 

FORWARD AIR, INC.

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the foregoing document 

was served on all counsel of records, in accordance with the Federal Rules of Civil Procedure on 

this the 8th day of April, 2022. 

/s/ Gregory R. Brenner 

Gregory R. Brenner 

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