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Case 2:12-cv-02898-KJM-JFM Document 1 Filed 11/29/12 Page 1 of 3



Eugene B. Elliot, State Bar No. 111475
Christine Lee, State Bar No. 231617
BERTRAND, FOX & ELLIOT
The Waterfront Building
2749 Hyde Street
San Francisco, California 94109
Telephone: (415) 353-0999
Facsimile: (415) 353-0990

Attorneys for Defendant
FAIRFIELD-SUISUN UNIFIED SCHOOL
DISTRICT






UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA





Plaintiff,

VICKI L. STRICKLAND,



v.

FAIRFIELD-SUISUN UNIFIED SCHOOL
DISTRICT,





Defendant.

Case No.

NOTICE OF REMOVAL OF SOLANO COUNTY
SUPERIOR COURT CASE NO. FCS040329
UNDER 28 U.S.C. § 1441(B)
[Federal Question]




TO THE CLERK OF THE ABOVE-ENTITLED COURT:
PLEASE TAKE NOTICE that defendant FAIRFIELD-SUISUN UNIFIED SCHOOL DISTRICT

(“DISTRICT”) hereby removes to this Court the state court action described below:

1.

On August 20, 2012, Case No. FCS040329 was commenced in the Superior Court of the
State of California, in and for the County of Solano, captioned Vicki L. Strickland v. Fairfield-Suisun
Unified School District. A true and correct copy of plaintiff’s complaint is attached as Exhibit A.

2.

The complaint was served on the DISTRICT through substitute service by delivering a
copy of the complaint to the office of the DISTRICT's Superintendent and mailing a copy of the
complaint to the DISTRICT on October 20, 2012. A true and correct copy of the proof of service filed

NOTICE OF REMOVAL OF SOLANO COUNTY SUPERIOR COURT CASE NO. FCS040329
Strickland v. Fairfield-Suisun Unified School District
U.S. District Court Case No.


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Case 2:12-cv-02898-KJM-JFM Document 1 Filed 11/29/12 Page 2 of 3



by plaintiff is attached hereto as Exhibit B.

3.

This action is a civil action of which this Court has original jurisdiction under 28 U.S.C.
§1331 because it arises under the Title VII of the Civil Rights Act of 1964, as set forth in the complaint
on page 2 lines 22-25. Thus, the complaint is properly removed to this Court by the defendant
DISTRICT pursuant to 28 U.S.C. §1441(b).

4.
5.

No other named defendants have been served as of the date of filing this notice.
The DISTRICT is informed and believes that a Case Management Conference Statement
was filed by plaintiff in Solano County Superior Court. The DISTRICT has not yet been served with a
copy of the Case Management Conference Statement and for that reason does not attach it.

BERTRAND, FOX & ELLIOT

6.

Defendant demands a jury trial.


Dated: November 29, 2012








By:



/s/ Christine Lee

Eugene B. Elliot
Christine Lee
Attorneys for Defendant
FAIRFIELD-SUISUN UNIFIED SCHOOL
DISTRICT



NOTICE OF REMOVAL OF SOLANO COUNTY SUPERIOR COURT CASE NO. FCS040329
Strickland v. Fairfield-Suisun Unified School District
U.S. District Court Case No.


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Case 2:12-cv-02898-KJM-JFM Document 1 Filed 11/29/12 Page 3 of 3



CERTIFICATE OF SERVICE

I, the undersigned, declare that I am employed in the County of San Francisco, California; I am

over the age of eighteen years and not a party to the within cause; and my business address is 2749 Hyde
Street, San Francisco, California 94109.

I am readily familiar with the practice of Bertrand, Fox, & Elliot with respect to the collection and

processing of pleadings, discovery documents, motions and all other documents which must be served
upon opposing parties or other counsel in litigation.

On November 29, 2012, I served the following document:
NOTICE OF REMOVAL OF SOLANO COUNTY SUPERIOR COURT CASE NO.
FCS040329 UNDER 28 U.S.C. § 1441(B)

on the following interested parties:

Vicki L. Strickland
180 Wildberry Court
Vallejo, California 94591

Plaintiff in Pro Per

Said service was performed in the following manner:





(?) BY U.S. POSTAL SERVICE (Mail): I placed each such document in a sealed envelope
addressed at noted above, with first-class mail postage thereon fully prepaid, for collection and
mailing at San Francisco, California, following the above-stated business practice, on this date.



I declare under penalty of perjury under the laws of the State of California that the foregoing is

true and correct. Executed November 29, 2012, at San Francisco, California.






























/s/ L Roberts
L Roberts





CERTIFICATE OF SERVICE
Strickland v. Fairfield-Suisun Unified School District
U.S. District Court Case No.




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