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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA

TALLAHASSEE DIVISION

CASE NO.

LYNDA BROADWAY,

Plaintiff,

v.

TALLAHASSEE AUTO INVESTORS I,

LLC d/b/a ALL AMERICAN FORD,

Defendant.

_______________________________/

NOTICE OF REMOVAL

PLEASE TAKE NOTICE THAT Defendant, Tallahassee Auto Investors I, LLC d/b/a 

All American Ford, has removed this cause to the United States District Court for the Northern

District of Florida pursuant to 28 U.S.C. §§1332 and 1441. The grounds for removal are:

1. On or about September 3, 2010, Plaintiff, Lynda Broadway, filed a civil action 

against All American in the Circuit Court of the Second Judicial Circuit, in and for Leon County, 

Florida, entitled Lynda Broadway v. Tallahassee Auto Investors I, LLC d/b/a All American Ford, 

Case No. 10-CA-003081. The Summons and Verified Complaint were served on Defendant on 

September 21, 2010. Other than the September 21, 2010 service, no proceedings have been had 

in this matter.

2. True and correct copies of all process and pleadings served upon Defendant are 

attached hereto as the following exhibits:

Exhibit A – Complaint and Summons

3. This Notice of Removal is filed within 30 days of Defendant’s receipt of a copy 

of the Complaint, pursuant to 28 U.S.C. § 1446(b). 

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4. This Notice of Removal is timely under the provisions of 28 U.S.C. §1446(b).

5. This is a case over which this Court has original jurisdiction pursuant to 28 U.S.C. 

§1331, and which may be removed to this Court by the defendant pursuant to 28 U.S.C. 

§1441(b), in that it is a civil action in which a federal question arises under the laws of the 

United States. In particular, the Complaint asserts claims under 29 U.S.C. §621 et seq., The Age 

Discrimination in Employment Act, and Title VII of the Civil Rights Act of 1964, 42 U.S.C. 

§ 2000 et seq. Therefore, this is a civil action over which this Court has original jurisdiction. 

6. Pursuant to 28 U.S.C. §1446(d), Defendant, concurrently with the filing of this 

Notice of Removal, served written notice thereof to all adverse parties and has filed a copy of 

this Notice with the Clerk of the Second Judicial Circuit, Leon County, Florida, from which this 

case was removed. A copy of the Notice of Filing Notice of Removal is attached hereto as 

Exhibit “B.” 

WHEREFORE, Defendant prays that the above-described action pending in the Circuit 

Court of the Second Judicial Circuit, in and for Leon County, Florida, be removed therefrom to 

this Court.

Date: October 21, 2010

FISHER & PHILLIPS LLP By: s/David A. Buchsbaum

450 East Las Olas Boulevard David A. Buchsbaum

Suite 800 (Fla. Bar No. 117961)

Fort Lauderdale, Florida 33301 Philip R. Marchion

Telephone: (954) 525-4800 (Fla. Bar No. 23773)

Facsimile: (954) 525-8739

Attorneys for Defendant

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CERTIFICATE OF SERVICE

I hereby certify that on October 21, 2010, I electronically filed the foregoing NOTICE 

OF REMOVAL document with the Clerk of Court using CM/ECF. I also certify that the 

foregoing document is being served this day to all counsel of record identified on the attached 

service list in the manner specified, either via transmission of Notices of Electronic Filing 

generated by CM/ECF and/or via U.S. Mail.

s/David A. Buchsbaum

David A. Buchsbaum

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SERVICE LIST

Marie A. Mattox, Esquire

Maria A. Mattox, PA

310 East Bradford Road

Tallahassee, FL 323031

Attorney for Plaintiff 

Via U.S. Mail

David A. Buchsbaum

dbuchsbaum@laborlawyers.com

Philip R. Marchion

pmarchion@laborlawyers.com

FISHER & PHILLIPS LLP

450 East Las Olas Boulevard

Suite 800

Ft. Lauderdale, Florida 33301

Telephone: (954) 525-4800

Facsimile: (954) 525-8739

Attorneys For Defendant

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