UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

STEPHANIE VALASQUEZ §

§

Plaintiff, §

§

§

v. § CIVIL ACTION NO. ___________

DART TRANSIT COMPANY and 

THOMAS RASHAD

§

§

(removed from 67th District 

Court, Tarrant County, Texas, 

Cause No. 067-331797-22)

§

Defendant. §

DEFENDANTS DART TRANSIT COMPANY AND THOMAS RASHAD’S 

NOTICE OF REMOVAL

TO THE HONORABLE UNITED STATES DISTRICT JUDGE:

Notice is hereby given that, pursuant to 28 U.S.C. §§ 1332, 1441, and 1446, 

Defendants Dart Transit Company (“Dart”), and Rasan Thomas (improperly named 

as Thomas Rashad) (“Thomas”) hereby remove this action from the 67th Judicial District Court in Tarrant County, Texas to the United States District Court for the 

Northern District of Texas, Fort Worth Division, and would respectfully show the 

Court as follows:

I. PARTIES

1. Plaintiff Stephanie Valasquez (“Valasquez”) is an individual residing in Tarrant County, Texas. For purposes of diversity, Valasquez is a citizen of Texas.

4:22-cv-177

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2. Defendant Dart Transit Company is a Minnesota corporation that, at all relevant times, has maintained its principal place of business in Minnesota. For purposes 

of diversity, Dart is a citizen of Minnesota.

1

3. Defendant Rasan Thomas (improperly named as Thomas Rashad) is an individual residing in Mississippi. For purposes of diversity, Thomas is a citizen of Mississippi.

II. STATE COURT ACTION

4. This matter arises from a motor vehicle accident that occurred on April 27, 

2021, in Tarrant County, Texas. As a result of the accident, Plaintiff is bringing 

claims of negligence and gross negligence against Defendants. 

5. On February 3, 2022, Plaintiff filed her Original Petition in the 67th Judicial 

District Court in Tarrant County, Texas, styled Stephanie Valasquez v. Dart Transit 

Company and Thomas Rashad, cause no. 067-331797-22 (the “State Court Action”).

6. Dart was served with process on February 10, 2022. Melton Truck Lines filed 

its Original Answer on March 4, 2022.

7. Thomas was served with process on February 10, 2022. Thomas filed his Original Answer on March 4, 2022.

8. With this Notice of Removal, Defendants remove the State Court Action to this 

Court on the basis of diversity jurisdiction, as more fully described below.

1 28 U.S.C. § 1332(c)(1).

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III. BASIS FOR REMOVAL

9. The State Court Action is removable pursuant to 28 U.S.C. § 1441(a)-(b) and 

28 U.S.C. § 1332(a)(1). This matter is a civil dispute between citizens of different 

states. There is and was at all relevant times (including at the time of filing of the 

States Court Action, service of the Original Petition, and the filing of this Notice of 

Removal), complete diversity between the parties in this action.

10. The amount in controversy in this lawsuit exceeds $75,000, exclusive of interest and costs, as evidenced by the paragraph 18, page 5 of Plaintiff’s Original Petition. 

In her Original Petition, Plaintiff seeks to recover monetary relief over $1,000,000.

11. Accordingly, because Plaintiff and the Defendants are citizens of different 

states and the amount in controversy exceeds $75,000, this Court has original jurisdiction and removal of this matter to federal court is proper.

12. Venue is proper in this Court under 28 U.S.C. § 1441(a) because the district 

and division of this Court includes Tarrant County, Texas, the location where Plaintiff filed her State Court Action.

IV. COMPLIANCE WITH REMOVAL REQUIREMENTS

13. This Notice of Removal is timely filed under 28 U.S.C. § 1446. This Notice of 

Removal is filed within thirty days of February 10, 2022, the date Defendants were 

first served with process and a copy of Plaintiff’s Original Petition in the State Court 

Action. This Notice of Removal is filed within one year of the filing of the Original 

Petition. 

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14. In accordance with 28 U.S.C. § 1446(d), written notice of this removal will be 

promptly given to Plaintiff, through her counsel of record, and a copy of this Notice 

will be filed with the clerk of court where the State Court Action is pending. 

15. By filing this Notice of Removal, Defendants do not intend to waive any defenses they may have to Plaintiff’s claims.

V. CONCLUSION

Defendants Dart Transit Company and Rasan Thomas (improperly named as 

Thomas Rashad), therefore, request the Court accept jurisdiction over this lawsuit 

for the reasons set forth above and grant them such other and further relief at law 

and in equity to which they may be justly entitled.

Respectfully submitted, 

/s/ Mark S. Scudder

MARK S. SCUDDER

State Bar No. 17936300

RYAN T. FUNDERBURG

State Bar No. 24101776

QUILLING, SELANDER, LOWNDS, 

WINSLETT & MOSER, P.C. 

2001 Bryan Street, Suite 1800

Dallas, TX 75201

214.871.2100

214.871.2111 Facsimile

mscudder@qslwm.com

rfunderburg@qslwm.com

ATTORNEYS FOR DEFENDANTS 

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CERTIFICATE OF SERVICE

On March 9, 2022, I electronically submitted the foregoing document with the 

clerk of court for the U.S. District Court, Northern District of Texas, using the electronic case filing system of the court. I hereby certify that I have served all counsel of 

record electronically or by another manner authorized by Federal Rule of Civil Procedure 5(b)(2). 

/s/ Mark S. Scudder

MARK S. SCUDDER

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