34238666_2.DOCX

IN THE UNITED STATES DISTRICT COURTFOR THE NORTHERN DISTRICT OF GEORGIAATLANTA DIVISION

BENJAMIN BURGESS, RHONDABURGESS, HEIDI HOWARD, JOYCEMARTIN, BETH KARAMPELAS,TERRI DACY, and MICHAEL DACY,individually and on behalf of all otherssimilarly situated,Plaintiffs,v.RELIGIOUS TECHNOLOGYCENTER, INC., ASSOCIATION FOR BETTER LIVING AND EDUCATIONINTERNATIONAL, NARCONONINTERNATIONAL, and NARCONONOF GEORGIA, INC.,Defendants.)))))))))))))))))))

CIVIL ACTIONFILE NO.DEFENDANT NARCONON INTERNATIONAL’S NOTICE OF REMOVAL

In accordance with 28 U.S.C. §§ 1332, 1441, 1446, and 1453, Defendant Narconon International (“NN International”), hereby removes this action from theState Court of Gwinnett County to the United States District Court for the NorthernDistrict of Georgia, Atlanta Division. This Court has jurisdiction over this action

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- 2 -under 28 U.S.C. §1332(d)(2). As grounds for removal, NN International respectfullyshows this Court the following:

I. BACKGROUND

1. On June 4, 2013, Plaintiffs Benjamin Burgess, Rhonda Burgess, HeidiHoward, Joyce Martin, Beth Karampelas, Terri Dacy and Michael Dacy filed a ClassAction Complaint (the “Complaint”) against Defendants in the State Court of Gwinnett County, Case No. 13-C-03596-S3 (the “State Court Action”). As required by 28 U.S.C. § 1446(a), true and correct copies of all process, pleadings, and ordersfiled in the State Court Action or served upon NN International in the State CourtAction as of the date of this filing are attached hereto as Exhibit “A.”2. In the Complaint, Plaintiffs allege that NN International has engaged infalse, deceptive, and misleading business practices that caused them to suffer harm.3. As stated in the Complaint, Plaintiffs seek to represent a class of individuals defined as follows:All individuals who have paid money to one or more of theDefendants to procure drug or alcohol rehabilitation services at[Defendant Narconon of Georgia, Inc. (“NNGA”)] for themselves or others, and to cover costs associated with books, housing, and other related or ancillary goods and services.(Compl., ¶ 31).

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- 3 -4. This Court has original subject matter jurisdiction over this action and allclaims asserted against NN International under the Class Action Fairness Act of 2005(“CAFA”), 28 U.S.C. § 1332(d).5. Because this Court has subject matter jurisdiction over this action,removal of this action to this Court is proper under 28 U.S.C. §§ 1441 and 1446.6. Venue is proper in this Court under 28 U.S.C. §§ 1441(a) and 90(a)(2) because the United States District Court for the Northern District of Georgia, AtlantaDivision, is the federal judicial district and division embracing the State Court of Gwinnett County, where the State Court Action was filed.7. Plaintiffs served NN International with a Summons and copy of theComplaint on June 10, 2013. This Notice of Removal (“Notice”) is timely filed incompliance with 28 U.S.C. § 1446(b) because it is filed within 30 days of June 102013, the date of service.8. In accordance with 28 U.S.C. § 1446(d), NN International has filed this Notice with this Court, will serve a copy of this Notice upon counsel for all parties,and will file a copy in the State Court of Gwinnett County, along with a Notice of Filing of Notice of Removal. A copy of the Notice of Filing of Notice of Removal isattached hereto as Exhibit “B.”

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