NOTICE OF REMOVAL

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John F. Hyland (SBN 178875)

jhyland@rukinhyland.com 

Rebecca H. Stephens (SBN 299234)

rstephens@rukinhyland.com

RUKIN HYLAND LLP

100 Pine Street, Suite 2150

San Francisco, California 94111

Telephone: (415) 421-1800

Facsimile: (415) 421-1700

Attorneys for Defendants

San Bruno Inn, LLP, 

Camino Royale Investment Corporation, and

Suresh M. Ghandi

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

ARUN KUMAR,

Plaintiff,

v.

SAN BRUNO INN, A CALIFORNIA LIMITED 

PARTNERSHIP; CAMINO ROYALE 

INVESTMENT CORPORATION; RAMADA 

WORLDWIDE, INC; and SURESH M. 

GHANDI, and DOES 1-20, inclusive,

Defendants.

Case No. 176CIV00056

DEFENDANTS’ NOTICE OF REMOVAL

(28 U.S.C. §§ 1331, 1441, 1446; 29 U.S.C. 

§207)
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NOTICE OF REMOVAL

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TO THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF 

CALIFORNIA AND TO PLAINTIFF AND HIS ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE THAT, pursuant to 29 U.S.C. sections 1441 et seq., Defendants San 

Bruno Inn, LLP, Camino Royale Investment Corporation, and Suresh M. Ghandi (“Defendants”) 

hereby remove the above-entitled action from the Superior Court of the State of California in and 

for the County of San Mateo to the United States District Court for the Northern District of 

California, with joinder in such removal by Defendant Ramada Worldwide, Inc.

In support of this removal, Defendants state the following:

I. PLEADINGS, PROCESS, AND ORDERS 

1. On January 5, 2017, Plaintiff Arun Kumar filed a Complaint in the Superior Court 

of the State of California for the County of San Mateo, entitled: Arun Kumar v. San Bruno Inn, a 

California Limited Partnership; Camino Royale Investment Corporation; Ramada Worldwide, 

Inc.; and Suresh M. Ghandi, and DOES 1-20, inclusive. (Case No. 176CIV00056) (“Complaint”). 

Defendants attach a true and correct copy of the Complaint, including the Summons, as Exhibit A.

2. The Complaint alleges nine purported causes of action against Defendants: (1) 

Failure to Pay Wages – Fair Labor Standards Act (“FLSA”) (against all defendants); (2) Failure to 

Pay All “Straight” Wages and Overtime Earned – California Labor Code and IWC Wage Orders 

(against San Bruno Inn, LLP and Camino Royale Investment Corporation); (3) Liquidated 

Damages – FLSA and California Labor Code (against all defendants); (4) Failure to Provide Meal 

and Rest Periods –California Labor Code (against San Bruno Inn, LLP and Camino Royale 

Investment Corporation); (5) Waiting Time Penalties – California Labor Code (against San Bruno 

Inn, LLP and Camino Royale Investment Corporation); (6) Failure to Provide an Accurate Wage 

Statement – California Labor Code (against San Bruno Inn, LLP and Camino Royale Investment 

Corporation); (7) Civil Penalties – California Labor Code (against San Bruno Inn, LLP and

Camino Royale Investment Corporation); (8) Unlawful, Unfair and Fraudulent Business Practices –

Business and Professions Code (against San Bruno Inn, LLP and Camino Royale Investment 

Corporation); and (9) Failure to Produce Documentation – California Labor Code (against San 

Bruno Inn, LLP and Camino Royale Investment Corporation). (See Complaint ¶¶ 40-112.)
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NOTICE OF REMOVAL

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3. Plaintiff served a copy of the summons and complaint on Defendants Camino 

Royale Investment Corporation and Suresh M. Ghandi on January 23, 2017, via personal delivery. 

Plaintiff served a copy of the summons and complaint on Defendant San Bruno Inn, LLP, on 

February 16, 2017, via personal delivery.

4. Defendants filed and served their Answer to the Complaint on February 21, 2017. 

Defendants have attached true and correct copies of the Answers as Exhibit B.

5. Exhibits A and B, along with the answer filed by Defendant Ramada Worldwide, 

Inc. (attached as an Exhibit C), comprise all process, pleadings and orders filed in this case.

II. DEFENDANTS’ TIMELY REMOVE THIS ACTION

6. Without conceding the timeliness of Plaintiff’s service of the Summons and 

Complaint for purposes of 28 U.S.C. section 1446(b), Defendants file this Notice of Removal 

within thirty days of January 23, 2017, the date on which Plaintiff served the summons and 

complaint on these Defendants and, therefore, Defendants timely remove the case to this Court 

pursuant to 28 U.S.C. section 1446(b).

III. ORIGINAL SUBJECT MATTER JURISDICTION EXISTS

7. Defendants may properly remove this action because the Court has original 

jurisdiction over the claims asserting purported violations of the Fair Labor Standards Act (FLSA) 

set forth in Plaintiff’s first and third causes of action in the Complaint. See 28 U.S.C. §§ 1331, 

1441(a). Defendants may also properly remove Plaintiff’s state law causes of action pursuant to 28 

U.S.C. section 1441(c). 

IV. THE OTHER PREREQUISITES FOR REMOVAL HAVE BEEN SATISFIED

8. Plaintiff originally filed this case in the Superior Court of the State of California, 

San Mateo County. (See Exhibit A.) Venue therefore properly lies in the Northern District of 

California pursuant to 28 U.S.C. sections 84(a), 1441, and 1446(a). 

9. As required by 28 U.S.C. section 1446(d), Defendants will provide notice of this 

removal to Plaintiff through his attorney of record and will file notice with the Superior Court of 

the State of California, County of San Mateo.

10. Defendants have not previously filed in this action a notice of removal.
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NOTICE OF REMOVAL

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WHEREAS, Defendants respectfully request that this action be removed from the Superior 

Court of the State of California in and for the County of San Mateo to the United States District 

Court for the Northern District of California, and that all future proceedings in this matter take 

place in the United States District Court for the Northern District of California.

Dated: February 22, 2017 RUKIN HYLAND LLP

By:____/s/ John F. Hyland____________

John F. Hyland

Rebecca Stephens

Attorneys for Defendants and Removing Parties

San Bruno Inn, LLP, 

Camino Royale Investment Corporation,

and Suresh M. Ghandi