IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF OHIO 

EASTERN DIVISION 

Karl Shaw : 

120 Marconi Blvd. : 

Columbus, Ohio 43215, : 

 : 

 Plaintiff, : 

 : 

 vs. : Case No. __________________ 

 : 

City of Columbus, : Judge _____________________ 

Division of Police : 

120 Marconi Blvd. : Magistrate _________________ 

Columbus, Ohio 43215, : 

 : 

 and : 

 : 

Kimberley Jacobs, Chief : 

Columbus Division of Police : 

120 Marconi Blvd. : 

Columbus, Ohio 43215, : 

 : 

 Defendants. : 

NOTICE OF REMOVAL 

Pursuant to 28 U.S.C. §§ 1441 and 1446, Defendants the City of Columbus and 

Kimberley Jacobs hereby give notice of the removal of this action from the Court of Common 

Pleas, Franklin County, Ohio Case No. 18-cv-3229 to the United States District Court for the 

Southern District of Ohio, Eastern Division, on the following facts: 

1. Attached as Exhibit A is a Complaint that the Plaintiff filed in the Court of Common 

Pleas, Franklin County, Ohio on April 17, 2018. The Complaint asserts claimed 

under 42 U.S.C. § 2000e, within the federal question jurisdiction of this Court. 

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2. Defendants the City of Columbus and Kimberley Jacobs were served with a summons 

and copy of the Complaint on April 23, 2018. 

3. The Complaint alleges that the Plaintiff was subject to race discrimination and 

retaliation in violation of 42 U.S.C. § 2000e. He alleges that he was denied open 

assignments due to his race and in retaliation for participated in protected activity. 

4. This action is a civil action of which this Court has original jurisdiction because 

Plaintiff’s Complaint raises claims within the federal question jurisdiction of this 

Court under 28 U.S.C. § 1331, specifically his claim under 42 U.S.C. § 2000e. 

5. This action may be removed to and adjudicated by this Court, pursuant to 28 U.S.C. 

§§ 1441 and 1446, because this civil action arises under the laws of the United States. 

6. This Notice of Removal is filed and subject to and with full reservation of rights, 

including but not limited to defenses and objections to venue, improper service of 

process, and personal jurisdiction. No admission of act, law, or liability is intended 

by this Notice of Removal, and all defenses, motions, and pleas are expressly 

reserved. 

7. This Notice of Removal was filed within 30 days of actual notice and receipt by the 

Defendants of the Summons and Complaint. 

8. As required by 28 U.S.C. § 1446(d), a Notice of Filing of Removal directed to the 

state court, the Franklin County Common Pleas Court, along with this notice will be 

promptly filed in the Court of Common Pleas, Franklin County, Ohio. A true and 

accurate copy of Defendants’ Notice of Removal Directed to State Court is attached 

hereto as Exhibit B. 

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9. To the extent Plaintiff’s Complaint sets forth claims under state law, such claims are 

within this Court’s supplemental jurisdiction under 28 U.S.C. § 1367(a). 

WHEREFORE, Defendants City of Columbus and Kimberley Jacobs respectfully request 

that this matter be removed to the Southern District of Ohio, Eastern Division, and that all 

proceedings herein be conducted in the United States District Court for the Southern District of 

Ohio, Eastern Division. 

Respectfully submitted, 

CITY OF COLUMBUS, DEPARTMENT OF LAW 

ZACH KLEIN 

 /s/ Richard N. Coglianese 

Richard N. Coglianese (0066830) 

Assistant City Attorney 

77 North Front Street, 4th Floor 

Columbus, Ohio 43215 

(614) 645-7385 Phone 

(614) 645-6949 Fax 

rncoglianese@columbus.gov 

Counsel for Defendants

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CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Notice of Removal has been served by 

operation of this Court’s electronic filing system, this 16th day of May 2018 on the following: 

Frederick M. Gittes (0034111) 

Jeffrey P. Vardaro (0081819) 

The Gittes Law Group 

723 Oak Street 

Columbus, Ohio 43205 

614-222-4735 

614-221-9655 (Fax) 

Sean L. Walton, Jr. (0088401) 

Chanda L. Brown (0081076) 

Walton & Brown, LLP 

395 East Broad Street, Suite 200 

Columbus, Ohio 43215 

614-636-3476 

614-636-3453 (Fax) 

/s/ Richard N. Coglianese 

Richard N. Coglianese 

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