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Phillip H. Stanfield, Bar #011729

Clarice A. Spicker, Bar #029964 

JONES, SKELTON & HOCHULI, P.L.C. 

40 North Central Avenue, Suite 2700 

Phoenix, Arizona 85004 

Telephone: (602) 263-1700 

Fax: (602) 200-7877 

pstanfield@jshfirm.com 

cspicker@jshfirm.com 

Attorneys for Defendants Western Express, 

Inc. and George Lee Ley 

UNITED STATES DISTRICT COURT 

DISTRICT OF ARIZONA 

FRANK CELAYA, an individual,

Plaintiff,

v. 

GEORGE LEE LEY and JANE DOE LEY, 

husband and wife; WESTERN EXPRESS, 

INC., a Tennessee corporation; ABC 

CORPORATIONS I-X; BLACK AND 

WHITE PARTNERSHIPS I-X; JOHN and 

JANE DOES I-X; and JACK and JILL DOES 

I-X, 

Defendants.

NO. 

NOTICE OF REMOVAL 

Defendants Western Express, Inc., and George Lee Ley, by and through 

undersigned counsel, file this Notice of Removal of an Arizona State Court action against 

it to the United States District Court for the District of Arizona and states as follows: 

1. On or about September 28, 2017, an action was commenced against 

Defendants in the Superior Court of the State of Arizona, in and for the County of 

Maricopa, under the caption Frank Celaya v. George Lee Ley and Jane Doe Ley, Western 

Express, Inc., et al., Case No. CV2017-054669. Plaintiff’s counsel served Defendant 

Western Express, Inc., via personal service upon Western Express, Inc.’s statutory agent, 

National Registered Agents, on September 29, 2017. Defendant George Lee Lay was 
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served via certified mail. 

2. Copies of pleadings so far filed in the State Court action are attached 

hereto as Exhibit A. 

3. Defendant Western Express, Inc., is a Tennessee corporation with its 

principal place of business in Tennessee. Defendant Ley is a resident of Texas. Upon 

information and belief, Plaintiff is a citizen of Maricopa County, Arizona, according to the 

Complaint. 

4. Plaintiff claims personal injuries as a result of Defendants’ alleged 

liability. Defendants are of the belief that Plaintiff’s injuries exceed the sum of $75,000. 

5. This Court has original jurisdiction over the civil action pursuant to 

28 U.S.C. § 1332 in that the matter in controversy exceeds the sum or value of $75,000 

exclusive of interest and costs, and the action is between citizens of different states. 

Therefore this action may be removed to this Court pursuant to the provisions of 28 

U.S.C. § 1441, et seq. 

6. Written notice of the filing of this Notice of Removal will be given to 

all adverse parties as required by law and a true and correct copy of this Notice will be 

filed with the Clerk of the Superior Court of the State of Arizona, in and for the County of 

Maricopa. 

7. A Notice of Filing Notice of Removal with the Clerk of the Yuma 

County Superior Court and a copy of the same is attached as Exhibit B. 
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DATED this 26th day of October 2017.

JONES, SKELTON & HOCHULI, P.L.C.

By: /s/ Clarice A. Spicker 

Phillip H. Stanfield 

Clarice A. Spicker 

40 North Central Avenue, Suite 2700 

Phoenix, Arizona 85004 

Attorneys for Defendants Western 

Express, Inc. and George Lee Ley 

CERTIFICATE OF SERVICE 

I hereby certify that on this 26th day of October, 2017, I caused the 

foregoing document to be filed electronically with the Clerk of Court through the 

CM/ECF System for filing; and served on counsel of record via the Court’s CM/ECF 

system. 

/s/ Becky Finnell