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Case 4:21-cv-00442-AW-MAF Document 1 Filed 11/03/21 Page 1 of 4
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF FLORIDA
`TALLAHASSEE DIVISION
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`Case No.: 4:21-cv-442
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`ROBIN GROVES,
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`v.
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`PILGRIM’S PRIDE CORPORATION,
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`Plaintiff,
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`Defendant.
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`NOTICE OF REMOVAL
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`Pursuant to 28 U.S.C. §§ 1331, 1441, and 1446, Defendant Pilgrim’s Pride Corporation
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`(“Defendant”) hereby removes this action currently pending in the Circuit Court of the Second
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`Judicial Circuit, in and for Leon County, Florida to the United States District Court for the
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`Northern District of Florida, and states in support as follows:
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`1.
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`On August 22, 2021, Plaintiff Robin Groves (“Plaintiff”), filed her Complaint in
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`this civil action in the Circuit Court of the Second Judicial Circuit, in and for Leon County, Florida,
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`captioned Robin Groves v. Pilgrim’s Pride Corporation, Case No.: 21-CA-001483 (the “State
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`Court Action”). Defendant accepted and waived service of the Complaint on October 6, 2021.
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`Defendant has not yet answered the Complaint.
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`2.
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`Plaintiff’s claims arise under the Family Medical Leave Act (“FMLA”) of 1993, 29
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`U.S.C. §§ 2601-2654, as originally written, and as modified pursuant to the Families First
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`Coronavirus Response Act (“FFCRA”) and the Emergency Family Medical Leave Expansion Act
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`(“EFMLA”), Public Law 116-127; the Florida Civil Rights Act (“FCRA”) of 1992, Fla. Stat. §§
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`760.01 et seq.; and the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12101 et seq.
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`1
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`Case 4:21-cv-00442-AW-MAF Document 1 Filed 11/03/21 Page 2 of 4
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`3.
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`Plaintiff alleges that while she was employed by Defendant, she experienced
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`interference under the FFCRA; retaliation under the FFCRA; retaliation under the FMLA;
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`disability discrimination under the FCRA, and associational disability discrimination under the
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`ADA. See generally Compl.
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`4.
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`Plaintiff’s claims for interference, retaliation, and associational disability
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`discrimination fall under the Court’s federal question jurisdiction pursuant to 28 U.S.C. § 1331
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`and, therefore, this action is removable to federal court under 28 U.S.C. § 1441. The Court has
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`supplemental jurisdiction over Plaintiff’s state law claim for disability discrimination. See 28
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`U.S.C. §1367(a).
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`5.
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`This Notice is proper and timely pursuant to 28 U.S.C. § 1446(b)(1) because it has
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`been timely filed within 30 days after Defendant was properly served with a copy of the Summons
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`and Complaint.
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`6.
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`Defendant will promptly serve a copy of this Notice on counsel for Plaintiff and
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`will file a copy of this Notice with the clerk of the State Court Action, pursuant to
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`28 U.S.C. § 1446(d).
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`7.
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`This action is properly removable to the United States District Court for the
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`Northern District of Florida pursuant to 28 U.S.C. § 1331 and 28 U.S.C. § 1446(a) because the
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`Circuit Court of the Second Judicial Circuit, in and for Leon County, Florida, in which this case
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`was brought, lies within the jurisdiction of this District.
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`8.
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`By removing this action, Defendant does not waive any defenses available to it and
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`does not admit any of the allegations in Plaintiff’s Complaint.
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`9.
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`Pursuant to 28 U.S.C. § 1446(a), a copy of all process, pleadings, and orders filed
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`in the State Court Action are attached as follows: a copy of the Complaint is attached hereto as
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`2
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`DN 6206283.1
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`

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`Case 4:21-cv-00442-AW-MAF Document 1 Filed 11/03/21 Page 3 of 4
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`Exhibit A. The Civil Cover Sheet in the State Court Action is attached hereto as Exhibit B. A
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`copy of the summons for Defendant is attached hereto as Exhibit C. A receipt filed in the State
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`Court Action is attached as Exhibit D. A “Uniform Order for Active, Differential Case
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`Management” filed in the State Court Action is attached as Exhibit E. A Waiver of Service of
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`Process filed in the State Court Action is attached as Exhibit F. Defendant’s Civil Cover Sheet in
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`the instant matter is attached hereto as Exhibit G.
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`10.
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`11.
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`There are no pending motions or petitions in the State Court Action.
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`Pursuant to Local Rule 5.6, Defendant states that there no prior or similar cases
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`requiring notice.
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`DATED: November 3, 2021.
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`s/ J. Ray Poole_________________
`J. Ray Poole
`Florida Bar No.: 0983470
`Constangy, Brooks, Smith & Prophete, LLP
`200 West Forsyth Street, Suite 1700
`Jacksonville, Florida 32202
`Telephone: (904) 356-8900
`Facsimile: (904) 356-8200
`rpoole@constangy.com
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` /s/ Matthew Morrison_______
`Matthew M. Morrison (pro hac vice application
`forthcoming)
`Spencer Fane, LLP
`1700 Lincoln Street, Suite 2000
`Denver, CO 80203
`(303) 839-3788
`mmorrison@spencerfane.com
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`Attorney for Defendant
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`3
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`DN 6206283.1
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`Case 4:21-cv-00442-AW-MAF Document 1 Filed 11/03/21 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`I hereby certify that on November 3, 2021, a true and correct copy of the foregoing
`NOTICE OF REMOVAL was filed with the Clerk of the Court using the CM/ECF system and
`was sent to the following:
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`Marie A. Mattox
`MARIE A. MATTOX, P. A.
`203 North Gadsden Street
`Tallahassee, FL 32301
`Telephone: (850) 383-4800
`Marie@mattoxlaw.com
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`Counsel for Plaintiff
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` /s/ _J. Ray Poole______
`J. Ray Poole
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`4
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`DN 6206283.1
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