IN THE UNITED STATE DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

KIRSY CASTILLO, 

Plaintiff, 

v. 

RYDER TRUCK RENTAL, a foreign 

corporation licensed to conduct business in the

state of Illinois; ZIZMAX EXPRESS, LLC., a 

foreign corporation licensed to conduct 

business in the state of Florida; SAYRAM 

CORP., a foreign corporation now dissolved 

but previously licensed to conduct business in 

the state of Illinois; JASUR KHULTAEV, a 

citizen of the state of New York, in his 

individual capacity and as an authorized agent 

of SAYRAM CORP.; and BAKHTIYAR 

UMAROV, individually and as Registered 

Agent for SAYRAM CORP. 

Defendants. 

Case No. 20-cv-467 

NOTICE OF REMOVAL ON BEHALF OF DEFENDANT 

RYDER TRUCK RENTAL, INC. d/b/a RYDER TRANSPORTATION SERVICES 

TO THE HONORABLE JUDGE OF THE UNITED STATES DISTRICT COURT FOR THE 

NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION: 

Pursuant to 28 U.S.C. §§ 1332, 1441 and 1446, Defendant RYDER TRUCK RENTAL, 

INC. d/b/a RYDER TRANSPORTATION SERVICES (“Ryder”) by and through its attorneys, 

GOLDBERG SEGALLA LLP, submits this Notice of Removal from the Circuit Court of Cook 

County, Illinois, County Department, in which this matter is now pending as ““Kirsy Castillo v. 

Ryder Truck Rental, a foreign corporation licensed to conduct business in the state of Illinois; 

Zizmax Express, LLC., a foreign corporation licensed to conduct business in the state of Florida; 

Case: 1:20-cv-00467 Document #: 1 Filed: 01/21/20 Page 1 of 6 PageID #:1
2 

Sayram Corp., a foreign corporation now dissolved but previously licensed to conduct business in 

the state of Illinois; Jasur Khultaev, a citizen of the state of New York, in his individual capacity 

and as an authorized agent of Sayram Corp.; and Bakhtiyar Umarov, individually and as 

Registered Agent for Sayram Corp, 2019 L 013708,” to the United States District Court for the 

Northern District of Illinois, Eastern Division. In support of this Notice, Ryder states as follows: 

Nature of Action 

1. This is an action for personal injury damages arising from an alleged auto accident which 

occurred on May 5, 2019 at the intersection of Russell Road and Old US Route 41 in the Township 

of Newport, County of Lake, and State of Illinois. Plaintiff alleges causes of action sounding in 

Respondeat Superior and Negligence against Ryder. 

2. Plaintiff commenced this action on December 12, 2019 by filing her Complaint in the 

Circuit Court of Cook County, Illinois, Law Division as: “Kirsy Castillo v. Ryder Truck Rental, a 

foreign corporation licensed to conduct business in the state of Illinois; Zizmax Express, LLC., a 

foreign corporation licensed to conduct business in the state of Florida; Sayram Corp., a foreign 

corporation now dissolved but previously licensed to conduct business in the state of Illinois; Jasur 

Khultaev, a citizen of the state of New York, in his individual capacity and as an authorized agent 

of Sayram Corp.; and Bakhtiyar Umarov, individually and as Registered Agent for Sayram Corp, 

2019 L 013708”. 

3. Pursuant to 28 U.S.C. § 1446(a), copies of all process, pleadings and orders served upon 

Ryder are attached to this Notice of Removal. 

Timeliness of Removal 

4. Defendant Ryder was first served with Summons and Complaint on December 19, 2019. 

Attached as Exhibit A is a copy of the Proof of Service and Complaint as served upon Ryder. 

Case: 1:20-cv-00467 Document #: 1 Filed: 01/21/20 Page 2 of 6 PageID #:2
3 

5. This Notice of Removal is being filed within thirty (30) days after receipt of the Complaint 

by Ryder, and is, therefore timely pursuant to 28 U.S.C. § 1446(b). 

Amount in Controversy 

6. Plaintiff brings this action to recover personal injury damages allegedly suffered during an 

auto accident which occurred on January 12, 2018. Plaintiff’s Complaint prays for damages “in 

excess of $75,000.” 

Diversity of Citizenship 

7. At the time this action was commenced, and at all times relevant, Plaintiff, Kirsy Castillo 

was and is a resident and citizen of the State of Illinois, residing in the Village of Volo and County 

of Lake. 

8. At the time this action was commenced, and at all times relevant, Defendant, Ryder Truck 

Rental was a Florida corporation with its principal place of business in Miami, Florida. 

9. Upon information and belief, Defendant, Jasur Khultaev was and is a resident and citizen 

of the State of New York. Upon information and belief, Mr. Khultaev has not yet been served. 

10. Defendant, Zizmax Express, LLC is a Florida corporation with its principal place of 

business in Kissimmee, Florida. Upon information and belief, Zizmax Express, LLC has been 

served and has provided consent to this removal. 

11. Defendant, Sayram Corp., now dissolved, was Florida corporation with its principal place 

of business in Orlando, Florida. Upon information and belief, Sayram Corp. has not yet been 

served. 

12. Defendant, Bakhtiyar Umarov is named as the Registered Agent for Sayram Corp. and is 

a citizen and resident of the State of Florida. Upon information and belief, Mr. Umarov has not 

yet been served. 

Case: 1:20-cv-00467 Document #: 1 Filed: 01/21/20 Page 3 of 6 PageID #:3
4 

13. Accordingly, pursuant to 28 U.S.C. § 1332(a), complete diversity exists between the parties 

in this action since the Plaintiff and Defendants are citizens of different states. 

Request for Removal 

14. The United States District Court for the Northern District of Illinois, Eastern Division, has 

original jurisdiction in this matter as there is diversity of citizenship between the parties and, as 

shown above, the amount in controversy exceeds $75,000. Therefore, removal is proper pursuant 

to 28 U.S.C. § 1332(a) and 28 U.S.C. § 1441(a). 

15. Contemporaneously with the filing of this Notice of Removal, Ryder has served written 

notice upon Plaintiff and the Clerk of the Circuit Court of Cook County, Illinois, that this Notice 

of Removal is being filed in the District Court for the Northern District of Illinois, Eastern 

Division. Attached hereto as Exhibit B is the Notice of Removal to the Circuit Court of Cook 

County, Illinois. 

16. Removal to the United States District Court for the Northern District of Illinois, Eastern 

Division, is proper under 28 U.S.C. §1441(a), because the state court where the suit has been 

pending is located within this district. 

WHEREFORE Defendant, Ryder Truck Rental, prays that the action captioned ““Kirsy 

Castillo v. Ryder Truck Rental, a foreign corporation licensed to conduct business in the state of 

Illinois; Zizmax Express, LLC., a foreign corporation licensed to conduct business in the state of 

Florida; Sayram Corp., a foreign corporation now dissolved but previously licensed to conduct 

business in the state of Illinois; Jasur Khultaev, a citizen of the state of New York, in his individual 

capacity and as an authorized agent of Sayram Corp.; and Bakhtiyar Umarov, individually and as 

Registered Agent for Sayram Corp, 2019 L 013708, Circuit Court of Cook County, Illinois, Law 

Case: 1:20-cv-00467 Document #: 1 Filed: 01/21/20 Page 4 of 6 PageID #:4
5 

Division,” be removed from the Circuit Court of Cook County, Illinois to the United States District 

Court for the Northern District of Illinois, Eastern Division. 

Respectfully submitted, 

GOLDBERG SEGALLA LLP 

/s/ Staci A. Williamson 

Attorney for Defendant, Ryder Truck Rental, Inc. 

d/b/a Ryder Transportation Services 

David J. O’Connell (ARDC # 6199086) 

Staci A. Williamson (ARDC # 6291064) 

GOLDBERG SEGALLA LLP 

Physical Address: 

222 W. Adams Street, Suite 2250 

Chicago, IL 60606 

Mailing Address: 

P.O. Box 957 

Buffalo, NY 14201 

Tel: (312) 572-8400 

Fax: (312) 572-8401 

doconnell@goldbergsegalla.com

swilliamson@goldbergsegalla.com

Case: 1:20-cv-00467 Document #: 1 Filed: 01/21/20 Page 5 of 6 PageID #:5
CERTIFICATE OF SERVICE 

TO: Gary A. Newland 

Erin A. Adamski 

NEWLAND & NEWLAND, LLP 

121 S. Wilke Rd., Suite 301 

Arlington Heights, IL 60005 

paralegal.newland3@gmail.com 

erin@newlandlaw.com 

I hereby certify that on January 21, 2020, I electronically filed the NOTICE OF 

REMOVAL ON BEHALF OF DEFENDANT, RYDER TRUCK RENTAL, INC. d/b/a RYDER 

TRANSPORTATION SERVICES with the United States District Court – Northern District of 

Illinois by using the CM/ECF system. 

By: /s/ Staci A. Williamson (ARDC # 6291064) 

GOLDBERG SEGALLA LLP 

Physical Address: 

222 W. Adams Street, Suite 2250 

Chicago, IL 60606 

Mailing Address: 

P.O. Box 957 

Buffalo, NY 14201 

Tel: (312) 572-8400 

Fax: (312) 572-8401 

swilliamson@goldbergsegalla.com

Attorney for Defendant, Ryder Truck Rental, Inc. 

d/b/a Ryder Transportation Services 

Case: 1:20-cv-00467 Document #: 1 Filed: 01/21/20 Page 6 of 6 PageID #:6