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NOTICE OF REMOVAL 

REED SMITH LLP 

A limited liability partnership formed in the State of Delaware 

Zachary C. Frampton (SBN 303225) Email: zframpton@reedsmith.com 

REED SMITH LLP

355 South Grand Avenue, Suite 2900 

Los Angeles, CA 90071-1514 

Telephone: +1 213 457 8000 

Facsimile: +1 213 457 8080 

Attorneys for Defendant 

Synchrony Bank 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

JUAN RAMON RANGEL, 

Plaintiff, 

vs. 

SYNCHRONY BANK, 

Defendant. 

Case No.: 

[Removal from the Superior Court of 

the State of California for the County 

of San Jose – Small Claims Division, 

Case No. 16SC067389] 

NOTICE OF REMOVAL

Case 5:17-cv-00177-LHK Document 1 Filed 01/12/17 Page 1 of 4
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NOTICE OF REMOVAL 

REED SMITH LLP 

A limited liability partnership formed in the State of Delaware 

Defendant Synchrony Bank (“Synchrony”), by counsel, pursuant to 28 U.S.C. 

§§ 1331, 1441 and 1446, hereby notices removal of the state court civil action known 

as Juan Ramon Rangel v. Synchrony Bank, Case No. 16SC067389, from the Superior 

Court of the State of California for the County of Santa Clara, to the United States 

District Court for the Northern District of California, and in support thereof states as 

follows. 

1. On or about November 17, 2016, Plaintiff Juan Ramon Rangel 

(“Plaintiff”) filed a Complaint against Synchrony (the “Complaint”) in the Superior 

Court of the State of California for the County of Santa Clara – Small Claims Division 

(the “State Court”). In compliance with 28 U.S.C. § 1446(a), a true and correct copy 

of all process, pleadings, and orders served upon Synchrony is attached hereto as 

Exhibit 1. 

2. On December 13, 2016, Synchrony was served by a process server 

through its registered agent, CT Corporation. 

3. Except for the notice filed with respect to this Notice of Removal, as of 

the date of this filing, no pleadings, motions, or papers other than the Complaint, have 

been filed with the State Court in this action. 

4. As set forth more fully below, this case is properly removed to this Court 

pursuant to 28 U.S.C. § 1441 because Synchrony has satisfied the procedural 

requirements for removal, and this Court has subject matter jurisdiction over this 

action pursuant to 28 U.S.C. § 1331. 

GROUNDS FOR REMOVAL

I. Synchrony Has Satisfied The Procedural Requirements For Removal.

5. Synchrony’s registered agent received the Complaint by process server 

on December 13, 2016. Therefore, this Notice of Removal is timely filed under 28 

U.S.C. § 1446(b) because Synchrony is filing its Notice of Removal within 30 days of 

its receipt of the initial pleading setting forth the claim for relief upon which such 

action is based. 

Case 5:17-cv-00177-LHK Document 1 Filed 01/12/17 Page 2 of 4
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NOTICE OF REMOVAL 

REED SMITH LLP 

A limited liability partnership formed in the State of Delaware 

6. This Court is the proper division because it embraces the Superior Court 

of the State of California for the County of Santa Clara – Small Claims Division, 

where Plaintiff’s action is pending. See 28 U.S.C. §§ 1441 and 1446(a). 

7. No previous request has been made for the relief requested herein. 

8. Pursuant to 28 U.S.C. § 1446(d), a copy of this Notice of Removal is 

being served on Plaintiff, and a copy is being filed with the State Court Clerk. 

II. Removal Is Proper Because This Court Has Subject Matter Jurisdiction.

9. Under 28 U.S.C. § 1331, United States District Courts are vested with 

jurisdiction to consider cases or controversies “arising under” the laws of the United 

States of America. See 28 U.S.C. § 1331. 

10. Removal of such cases is governed by 28 U.S.C. § 1441(b). Section 

1441(b) makes clear that a case brought in state court, raising a federal question, 

“shall be removable” to the United States District Courts “without regard to the 

citizenship or residence of the parties.” See 28 U.S.C. § 1441(b) (emphasis added). 

11. Here, Plaintiff’s Complaint purports to assert a claim against Synchrony 

for alleged violations of the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq. (the 

“FCRA”). See Complaint, at 2. 

12. Plaintiff’s Complaint alleges violations of a federal statute, the FCRA, 

and consequently “arises under” the laws of the United States. See 28 U.S.C. § 1331. 

Therefore, this Court may properly exercise jurisdiction over this claim. 

13. To the extent that any other claims in this action may arise under state 

law, supplemental jurisdiction over such claims exists pursuant to 28 U.S.C. § 1367. 

14. Given that the requirements for federal question jurisdiction are satisfied, 

this case is properly removed. 

/ / / 

/ / / 

/ / / 

/ / / 

Case 5:17-cv-00177-LHK Document 1 Filed 01/12/17 Page 3 of 4
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NOTICE OF REMOVAL 

REED SMITH LLP 

A limited liability partnership formed in the State of Delaware 

WHEREFORE, Defendant Synchrony Bank, by counsel, respectfully requests 

that the above-referenced action, originally filed in the Superior Court of the State of 

California for the County of Santa Clara – Small Claims Division, be removed to this 

Court pursuant to 28 U.S.C. §§ 1441 and 1446. 

DATED: January 12, 2017 Reed Smith LLP

By: /s/ Zachary C. Frampton 

Zachary C. Frampton 

Attorneys for Defendant 

Synchrony Bank 

Case 5:17-cv-00177-LHK Document 1 Filed 01/12/17 Page 4 of 4