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IN THE UNITED STATES DISTRICT COURT 

FORTH THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

CAROLS MUNOZ; and ALICIA PEREZ, ) 

Individually and as Mother and Next Friend of ) 

ALAIA MUNOZ, a Minor, ) 

) 

Plaintiff, ) 

vs. ) No.: 20-cv-2344 

) 

JOVON SANDERS, Individually and as Servant ) 

and Agent of TIRE WHOLESALERS ) Circuit Court of Cook 

COMPANY, and TIRE WHOLESALERS ) County, Illinois 

COMPANY, ) Case No. 2020 L 002810 

) 

Defendants. ) 

NOTICE OF REMOVAL 

 Defendants JOVON SANDERS, individually and as Servant and Agent of Tire 

Wholesalers Company and TIRE WHOLESALERS COMPANY, by and through their 

attorneys Foley & Mansfield, PLLP, hereby respectfully submit this Notice of Removal 

of this action from the Circuit Court of Cook County, Illinois to the United States District 

Court for the Northern District of Illinois. In support of this Notice of Removal, 

Defendants state as follows: 

1. This action was commenced against Jovon Sanders, Individually and as 

Servant and Agent of Tire Wholesalers Company and against Tire Wholesalers Company 

in the Circuit Court of Cook County, Illinois, on March 9, 2020. A copy of the complaint 

was mailed to Jovon Sanders on March 16, 2020. Neither defendant has been properly 

served with a copy of the complaint and defendants do not by filing this Notice of 

Removal waive any objections or defenses they may have to improper service of process. 

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This notice is filed within 30 days after the complaint was mailed to defendant Jovon 

Sanders. 

2. At the time the action was commenced and since then, the Plaintiffs were 

and are citizens of the County of Cook, State of Illinois. Defendant Jovon Sanders was 

and is a citizen of the County of Lake, State of Indiana. Tire Wholesalers Company was 

and is a corporation organized and existing under the laws of the State of Michigan with 

its principal place of business in Troy, Michigan. 

3. The amount in controversy exceeds $75,000, exclusive of interest and 

costs, as appears from the Plaintiffs’ complaint, a copy of which is attached hereto as 

Exhibit A. A copy of the Summons mailed to Jovon Sanders is attached hereto as Exhibit 

B. This action is a civil one in which the United States District Courts have original 

jurisdiction under 28 U.S.C. §1332. 

4. The defendant attaches to this notice copies of all process, pleadings, and 

orders that have been served on it. 

 WHEREFORE, Defendants JOVON SANDERS, individually and as Servant and 

Agent of Tire Wholesalers Company and TIRE WHOLESALERS COMPANY pray that 

this cause be removed to the United States District Court for the Northern District of 

Illinois. 

Respectfully Submitted, 

JOVON SANDERS, INDIVIDUALLY 

AND AS AGENT OF TIRE 

WHOLESALERS COMPANY, AND 

TIRE WHOLESALERS COMPANY, 

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/s/Stephen R. Vedova

One of their Attorneys 

Stephen R. Vedova #6256810 

Claire C. Kossmann #6303747 

Joseph A. Falk #6320589 

Attorneys for Defendants 

FOLEY & MANSFIELD, PLLP 

70 West Madison Street, Suite 3000 

Chicago, IL 60602 

Phone: (312) 254-3803 

Fax: (312) 254-3801 

Firm I.D. #44251 

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CERTIFICATE OF SERVICE 

I hereby certify that I electronically filed the foregoing document with the Clerk of the 

Court using the CM/ECF system which will send notification of such filing to all 

registered attorneys of record. I further certify that I will cause a copy of the foregoing 

document to be served upon the following counsel of record, postage prepaid, on the 16th 

day of April, 2020: 

Lindsey A. Seeskin 

The Horwitz Law Group 

20 N. Clark Street, Suite 3300 

Chicago, IL 60602 

(312) 641-9200 

__/s/ Stephen R. Vedova_____ 

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