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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

SANDRO RUIZ § 

Plaintiff, § 

 § 

vs. § C.A. No. 4:22-cv-00793 

 § JURY DEMANDED 

GURPREET BHAMBRA and § 

SIMRUT TRUCKING INC. § 

Defendants. § 

DEFENDANTS’ NOTICE OF REMOVAL

TO THE HONORABLE JUDGE OF SAID COURT:

COME NOW, Defendants GURPREET BHAMBRA and SIMRUT TRUCKING INC.

(collectively, “Defendants”), and pursuant to 28 U.S.C. §§ 1441 and 1446, hereby give notice of 

removal of this case from the 48th Judicial District Court of Tarrant County, Texas to the United 

States District Court for the Northern District of Texas, Fort Worth Division. In support thereof, 

Defendants would show the Court as follows: 

I.

BACKGROUND

 1. This is a personal injury case stemming from a motor vehicle accident that occurred 

on or about March 11, 2022 in Tarrant County, Texas. 

 2. On July 29, 2022, Plaintiff Sandro Ruiz (hereafter “Plaintiff”) filed a civil action 

against Defendants in the 48th Judicial District Court of Tarrant County, Texas; Cause No. 048-

335072-22. Citation for Simrut Trucking Inc. was issued on August 1, 2022. Plaintiff did not 

request a citation for Gurpreet Bhambra.

 3. Simrut Trucking Inc. was served via process server on August 9, 2022. This was 

the first time this Defendant received a copy of Plaintiff’s Original Petition. 

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 4. Gurpreet Bhambra was never served. He never received a copy of Plaintiff’s 

Original Petition. Despite the undersigned’s diligent efforts, he has been unable to make contact 

with Mr. Bhambra as of the date of this filing. The undersigned is filing this Notice to ensure he 

complies with all possible removal deadlines.

 5. On September 7, 2022, both Defendants filed an Answer in state court, including 

Gurpreet Bhambra who never received formal service of process. 

II.

VENUE

 6. Venue is proper pursuant to 28 U.S.C. § 1446(a) because this Court occupies the 

district and division in which Plaintiff’s lawsuit was filed. 

III.

BASIS FOR REMOVAL

 7. Removal to this Court is proper pursuant to 28 U.S.C. § 1332(a) because there is 

complete diversity of citizenship and the alleged amount in controversy exceeds $75,000.00. 

8. Diversity jurisdiction exists because: 

a. At the time the case was filed and at the time of removal, Plaintiff was a 

resident of Texas. 

b. At the time the case was filed and at the time of removal, Defendant 

Gurpreet Bhambra was a resident of, and domiciled in, Canada. 

c. At the time the case filed and at the time of removal, Defendant Simrut 

Trucking Inc. was a foreign corporation. Their principal office is located in 

Canada. They do not maintain a principal office in Texas. 

 9. Plaintiff’s Original Petition states he is seeking “monetary relief over 

$250,000.00.” Because this amount exceeds $75,000.00, this Court has original jurisdiction. 

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 10. However, Plaintiff’s Original Petition also states that “the amount in controversy 

in this matter does not exceed $75,000.00.” Plaintiff alleges to have suffered “extensive and 

permanent injuries.” He is seeking damages for past and future medical expenses, past and future 

pain and suffering, past and future mental anguish, past and future physical impairment, past and 

future disfigurement, lost wages, loss of earning capacity, and punitive damages. By a 

preponderance of evidence, Plaintiff’s alleged damages are in excess of $75,000.00. Therefore, 

this Court has original jurisdiction. 

 11. This Notice of Removal was filed within thirty (30) days after Simrut Trucking Inc.

received a copy of Plaintiff’s Original Petition, i.e., the initial pleading setting forth the claim for 

relief upon which such action or proceeding is based. It is therefore timely pursuant to 28 U.S.C. 

§ 1446(b)(1). Gurpreet Bhambra consents and/or joins in the removal. 

IV.

JURY DEMAND

 12. Both Plaintiff and Defendants filed jury demands in the state court action. 

V.

DOCUMENTS FILED WITH THIS NOTICE

 13. Pursuant to the Northern District of Texas Local Rule 81.1, Defendants file the 

following documents with the Court: 

Exhibit A An index of all documents filed with this notice (pursuant to Local 

Rule 81.1(a)(4)(A)); 

Exhibit B The docket sheet in the state court case (pursuant to Local Rule 

81.1(a)(4)(B));

Exhibit C Plaintiff’s Original Petition filed in state court on July 29, 2022 

(pursuant to Local Rule 81.1(a)(4)(C)); 

Exhibit D Proof of service filed in state court on August 19, 2022 (pursuant to 

Local Rule 81.1(a)(4)(C)); 

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Exhibit E Defendants’ Original Answer filed in state court on September 7, 

2022 (pursuant to Local Rule 81.1(a)(4)(C)); 

Exhibit F Defendants’ Jury Demand filed in state court on September 7, 2022 

(pursuant to Local Rule 81.1(a)(4)(C)); 

Exhibit G A copy of the Notice of Removal to Federal Court to be filed with 

the state court on September 7, 2022; and 

Exhibit H A Certificate of Interested Parties (pursuant to Local Rule 

81.1(a)(4)(D)). 

VI.

CONCLUSION

BASED ON THE FOREGOING, Defendants GURPREET BHAMBRA and SIMRUT 

TRUCKING INC. hereby remove this case from the 48th Judicial District Court of Tarrant County, 

Texas to this Court. 

Respectfully submitted,

 

 BUSH & RAMIREZ, PLLC

 /s/John A. Ramirez 

John A. Ramirez

TBN: 00798450; Federal ID No.: 21280 

 5615 Kirby Drive, Suite 900

Houston, Texas 77005

 Telephone: (713) 626-1555

 Facsimile: (713) 622-8077 

 Email: jramirez.atty@bushramirez.com

 

ATTORNEY FOR DEFENDANTS, 

GURPREET BHAMBRA and

SIMRUT TRUCKING INC. 

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CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing instrument has been sent to all interested counsel 

by facsimile and/or electronic service on this 7th day of September, 2022.

 Kiernan McAlpine 

Daspit Law Firm

440 Louisiana St., Suite 1400 

Houston, Texas 77002 

Via E-Filing & Email: e-service@daspitlaw.com

 /s/John A. Ramirez 

John A. Ramirez

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