IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

ADRIANA BONNER AND QUENTIN 

BONNER,JR. 

Plaintiffs, 

v. 

STERICYCLE SPECIALTY WASTE 

SOLUTIONS, INC. a.k.a STERICYCLE, 

INC. 

Defendant. 

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NOTICE OF REMOVAL 

Cause No. 3:22-543 

Defendant Stericycle, Inc. files this Notice of Removal, removing Cause No. CC-22-

00652-E from,the County Court at Law No. 5, Dallas County, Texas to this Court pursuant to 28 

U.S.C. §§ 1332 and 1441. The grounds for removal of this lawsuit are as follows: 

I. STATEMENT OF THE CASE 

Stericycle is a business-to-business services company and leading provider of compliancebased solutions that protect people and brands, promote health and well-being, and safeguard the 

environment. 

Plaintiffs allege that an unnamed Stericycle employee or agent caused a vehicle collision 

on Interstate Highway 20 west of Interstate Highway 45 on February 8, 2020 in which both 

Plaintiffs were allegedly injured. 

This Court has original jurisdiction based upon diversity of citizenship under 28 U.S.C. § 

13 3 2( a)( 1 ), because Plaintiffs and Defendant are citizens of different states and Defendant is not a 

citizen of Texas. The parties' citizenship remains diverse and has been diverse since prior to the 

NOTICE OF REMOVAL 

1303537-19727196 I 

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Case 3:22-cv-00543-C Document 1 Filed 03/08/22 Page 1 of 4 PageID 1
date that the lawsuit was filed. According to the allegations in Plaintiffs' Petition, the amount in 

controversy exceeds $75,000.00. Stericycle has timely removed this action. 

II. GROUNDS FOR REMOVAL 

A. Timeliness of Removal. 

On February 8, 2022, Plaintiffs filed the lawsuit styled Adriana Bonner and Quentin 

Bonner, Jr. v. Stericycle Specialty Waste Solutions, Inc. a.k.a. Stericycle, Inc., Cause No. CC-22-

00652-E, in the County Court at Law No. 5, Dallas County, Texas. Stericycle was served through 

its registered agent on February 12, 2022. Thus, this Notice of Removal is timely filed pursuant 

to 28 U.S.C. ~ 1446(b). 

B. Diversity of Citizenship Exists Between Plaintiffs and Defendant. 

Diversity of citizenship exists between Plaintiffs and Defendant. Therefore, this court has 

original jurisdiction pursuant to 28 U.S.C. § l 332(a)(l ). Plaintiffs are citizens ofthe state of Texas. 

(See Pl.'s Orig. Pet. at p. 2, attached as Ex. A-1). Defendant Stericycle is a citizen of the states of 

Delaware and Illinois under 28 U.S.C. §1332(c)(l) because it is a corporation incorporated under 

the laws of the state of Delaware and its principal place of business is in Bannockburn, Illinois. 

(See Pl.'s Orig. Pet. at p. 2 attached as Ex. A-1). Defendant Stericycle is not a citizen of Texas and 

was not a citizen of Texas prior to the date the lawsuit was filed. 

C. The Amount in Controversy exceeds $75,000.00. 

Plaintiffs' Petition states that Plaintiffs are seeking monetary damages 111 excess of 

$250,000. (See Petition at p. 1, attached as Ex. A-1). 

D. State Court Filings. 

In accordance with 28 U.S. C. § 1446( a) and Local Rule 81.1, the following documents are 

attached as Exhibits A - B: 

NOTICI~ OF REMOVAL 

1303537-19727196.1 

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Case 3:22-cv-00543-C Document 1 Filed 03/08/22 Page 2 of 4 PageID 2
(A) An index of all documents that clearly identifies each document and indicates the 

date the document was filed in state court with a copy of the documents filed behind the index; 

and 

(B) A copy of the docket sheet in the state court action. 

Further, pursuant to Local Rule 81.1, Defendant files contemporaneously herewith a civil 

cover sheet, a supplemental civil cover sheet and a separately signed certificate of interested 

persons, and Defendant Stericycle's filed answer in this Lawsuit prior to removal, which is 

attached hereto as Exhibit A-5. 

III. VENUE AND NOTICES 

Under 28 U.S.C. § 1441(a), venue of the removed action is proper in this Court as it is in 

the district and division embracing the place where the Lawsuit is pending. This Notice of 

Removal is being filed with the clerk of the District Court of Dallas County, Texas and is being 

served upon counsel for Plaintiffs pursuant to 28 U.S.C. §1446(d). 

IV. PRAYER 

WHEREFORE, PREMISES CONSIDERED, Defendant Stericycle, Inc. requests that this 

Court assume full jurisdiction of this cause in accordance with 28 U.S.C. § 1332(a)(l), and that 

further proceedings in the County Court at Law No. 5 of Dallas County, Texas be stayed, and prays 

for such other and further relief, in favor of Defendant, to which it may be justly entitled. 

NOTICE OF REMOVAL 

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Respectfully submitted, 

By: Isl S. Wesley Butler 

Craig A. McDougal 

State Bar No. 13569850 

cmcdougal@kilpatricktownsend.com 

S. Wesley Butler 

State Bar No. 24045593 

wbutler@),ki I patri ck town send. com 

KILPATRICK TOWNSEND & STOCKTON L.L.P. 

2001 Ross Ave., Suite 4400 

Dallas, Texas 75201 

Telephone: (214) 922-7100 

Telecopier: (214) 922-7101 

ATTORNEYS FOR DEFENDANT 

STERICYCLE, INC. 

CERTIFICATE OF SERVICE 

This is to certify that a true and correct copy of the foregoing has been served upon all 

counsel of record via electronic service, on this 8th day of March, 2022. 

Ricky Kemph 

Law Offices of Kelly T. Curran 

Midtown Office Center 

5720 LBJ Fwy., Suite 440 

Dallas, Texas 75240 

Phone ( 469) 730-3007 

Fax (469) 458-2993 

ktclawfirm@gmail.com 

NOTICE OF REMOVAL 

1303537-19727 l 96.1 

Isl S. Wesley Butler 

S. Wesley Butler 

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