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UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

MAE DOROTHY WRIGHT, §

§

 Plaintiff, §

§

v. §

§

Civil Action No. 3:22-cv-899

RUSHMORE LOAN MANAGEMENT 

SERVICES, LLC and REO TRUST 

2017-RPL1,

§

§

§

§

 Defendants. §

DEFENDANTS’ NOTICE OF REMOVAL

Pursuant to 28 U.S.C. §§1331 and 1441, Defendants Rushmore Loan Management 

Services, LLC (“Rushmore”) and REO Trust 2017-RPL1 (“REO”) (collectively “Defendants”)

remove this action from the 160th Judicial District Court of Dallas County, Texas, to the United 

States District Court for the Northern District of Texas, Dallas Division, and in support thereof 

would show unto the Court the following:

I. STATE COURT ACTION

1. On April 1, 2022, Plaintiff Mae Dorothy Wright (“Plaintiff” or “Wright”) filed 

her Original Petition (the “Complaint”), Mae Dorothy Wright v. Rushmore Loan Management 

Services, LLC and REO Trust 2017-RPL1, Cause No. DC-22-03474, in the 160th Judicial 

District Court of Dallas County, Texas.

2. Pursuant to 28 U.S.C. §1446(d), this Notice of Removal will be filed with the 

160th Judicial District Court of Dallas County, Texas, and a copy of this Notice of Removal will 

also be served on all parties. Pursuant to Fed. R. Civ. P. 7.1 and L.R. 81.1, Defendants have filed 

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contemporaneously with this Notice a civil cover sheet, supplemental cover sheet, state court 

docket, state court file, and a certificate of interested persons.

3. In the State Court Action, Plaintiff alleges causes of action centered around the

foreclosure of the real property commonly known as 8040 Komalty Drive, Dallas, Texas 75217

(the “Property”). Plaintiff brought her lawsuit against Defendants for violation of the Real Estate 

Settlement Procedures Act 1 (“RESPA”) under 12 C.F.R. §1024.41, et seq. and negligent 

undertaking.

4. Pursuant to 28 U.S.C. §1446(a), copies of all process, pleadings, orders, and other 

papers filed in the 160th Judicial District Court and obtained by Defendants are attached hereto.

5. In support of this removal and as required by Local Rule 81.1, please find 

attached as follows:

Exhibit A: Civil Cover Sheet;

Exhibit B: Supplemental Civil Cover Sheet;

Exhibit C: State Court Civil Docket Sheet;

Exhibit D: State Court File.

II. TIMELINE FOR NOTICE OF REMOVAL

6. Defendants Rushmore and REO have not been served in this matter. Less than 

thirty (30) days have passed since Defendants received unofficial notice of this lawsuit, and thus,

removal is timely. 28 U.S.C. §1446(b)(1).

III. BASIS FOR REMOVAL: FEDERAL QUESTION JURISDICTION

7. The Court has original jurisdiction over this action pursuant to 28 U.S.C. §1331 

because it involves questions of federal law. Specifically, Plaintiff alleges claims and damages 

related to RESPA, 12 C.F.R. §1024, et seq.

1 See Plaintiff’s Complaint at ¶ 20-24.

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IV. VENUE

8. Venue for this Removal is proper in the United States District Court for the 

Northern District of Texas, Dallas Division, because this district and division includes Dallas

County, Texas, which is the location of the pending state court action. 28 U.S.C. §1441(a).

V. CONCLUSION

WHEREFORE Defendants Rushmore Loan Management Services, LLC and REO Trust 

2017-RPL1 remove this action from the 160th Judicial District Court of Dallas County, Texas, to 

the United States District Court for the Northern District of Texas, Dallas Division, so that this 

Court may assume jurisdiction over the cause as provided by law.

Respectfully submitted,

By: /s/ Shelley L. Hopkins

Shelley L. Hopkins

State Bar No. 24036497

HOPKINS LAW, PLLC

3 Lakeway Centre Ct., Suite 110

Austin, Texas 78734

(512) 600-4320

BARRETT DAFFIN FRAPPIER

TURNER & ENGEL, LLP - Of Counsel

ShelleyH@bdfgroup.com

shelley@hopkinslawtexas.com

Robert D. Forster, II

State Bar No. 24048470

BARRETT DAFFIN FRAPPIER

TURNER & ENGEL, LLP

4004 Belt Line Road, Ste. 100

Addison, Texas 75001

(972) 386-5040

(972) 341-0734 (Facsimile)

RobertFO@bdfgroup.com

ATTORNEYS FOR DEFENDANTS

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CERTIFICATE OF SERVICE

I hereby certify that on this 21st day of April 2022, I electronically filed the foregoing 

with the Clerk of the Court using the CM/ECF filing system, and will send a true and correct 

copy to the following:

VIA ECF:

D. Kimberli Wallace

D. Kimberli Wallace, PLLC

1560 E. Southlake Blvd., Suite 100

Southlake, Texas 76092

kwallace@kwlawfirm.net

ATTORNEYS FOR PLAINTIFF

/s/ Shelley L. Hopkins

Shelley L. Hopkins

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