Try Para
← All workflows

CAFA Notice of Removal

Draft CAFA Removal Notices in Minutes, Not Hours

12 minutes with Para

Explore this workflow

Get started with Para

Para is an AI colleague for legal teams. Send it this work by email, Teams or Slack, and it hands back the finished document.

12 minutes with Para

What you'll need

  • State Court Complaint
  • Proof of Service

Plans from $20 a month, with usage included.

Workflow

Overview

Drafting a CAFA notice of removal requires meticulous review of state court documents, manual calculation of removal deadlines, verification of complex jurisdictional requirements, and citation research across multiple legal databases. Attorneys typically spend 5-6 hours extracting case details, confirming CAFA's minimal diversity and amount-in-controversy thresholds, and ensuring compliance with federal procedural rules—all while racing against the 30-day removal deadline.

Drafting a CAFA Notice of Removal requires meticulous attention to jurisdictional requirements, strict 30-day deadlines, and complex calculations for diversity, amount in controversy, and class size. Missing critical elements or procedural requirements can result in remand to state court, wasted litigation costs, and strategic disadvantages. Manual drafting takes hours of attorney time to ensure compliance with federal statutes and local court rules.

CaseMark automates the entire CAFA removal process, generating comprehensive, court-ready notices in minutes. Simply upload your state court complaint and service documents, and receive a fully formatted notice that establishes minimal diversity, calculates the amount in controversy, addresses CAFA exceptions, and includes all required procedural elements and exhibits. Focus on litigation strategy while CaseMark handles the technical compliance.

How to hand this to Para

  1. 1. Send Para the files

    Email them, drop them in a Teams or Slack message, or upload them.

  2. 2. Para runs the CAFA Notice of Removal skill

    It works from your files and checks its citations against the record.

  3. 3. The finished document comes back

    Para returns it where you asked, usually as a DOCX, and offers the next step.

Example request · email, Teams or Slack
Para, run the CAFA Notice of Removal skill for the Garcia matter. I've attached the State Court Complaint and Proof of Service. Send the finished draft back here as a DOCX.

What you get

  • Caption and Heading

  • Introduction

  • Jurisdictional Basis under CAFA

  • Procedural History

  • Timeliness of Removal

  • Consent of Defendants

  • No Federal Question or Other Basis

  • Attachments and Exhibits

  • Prayer for Relief

  • Signature and Certification

Required documents

  • State Court Complaint

    The original complaint or petition filed in state court, including all exhibits and attachments

    PDF, DOCX

  • Proof of Service

    Summons and service documents showing when defendant(s) were served with the complaint

    PDF, DOCX

Supporting documents

  • State Court Docket Sheet

    Current register of actions showing all filings and proceedings in the state court case

    PDF

  • Amended Complaints or Pleadings

    Any amended complaints, motions, or orders that may affect removability or timing

    PDF, DOCX

  • Discovery Responses

    Discovery materials that support amount in controversy or class size calculations

    PDF, DOCX

  • Defendant Consent Documents

    Written consents from other served defendants joining in the removal

    PDF, DOCX

Why teams use it

Automatically extract case details, parties, and dates from state court filings using intelligent document analysis

Verify CAFA jurisdictional requirements with real-time citation to 28 U.S.C. § 1332(d) and supporting case law

Calculate and confirm 30-day removal deadline compliance from service dates in uploaded documents

Generate properly formatted federal court captions and procedural sections meeting local court rules

Reduce drafting time from 5+ hours to under 15 minutes while ensuring accuracy and completeness

Questions

What are the main requirements for removing a class action under CAFA?

CAFA removal requires three elements: (1) minimal diversity, meaning at least one plaintiff class member is a citizen of a different state than at least one defendant; (2) an aggregate amount in controversy exceeding $5 million, exclusive of interest and costs; and (3) a putative class of at least 100 members. The notice must be filed within 30 days of service or receipt of the paper from which removability is first ascertainable. CaseMark automatically analyzes your case documents to establish each requirement with supporting citations and calculations.

How do I calculate the amount in controversy for CAFA removal?

The amount in controversy is calculated by aggregating all potential damages claimed by all class members, including compensatory damages, statutory damages, punitive damages, and injunctive relief. You must examine the complaint's allegations, class size estimates, and individual damage claims to reach a reasonable calculation exceeding $5 million. CaseMark analyzes your complaint to extract relevant allegations, multiply individual damages by estimated class size, and provide a detailed calculation methodology that satisfies federal court scrutiny.

Do all defendants need to consent to the CAFA notice of removal?

Yes, all defendants who have been properly served must consent to removal under the unanimity rule of 28 U.S.C. § 1446(b)(2)(A). However, only served defendants need to consent—unserved defendants are not required to join. All consents must be obtained within the 30-day removal period. CaseMark generates the appropriate consent language and identifies which defendants must join, streamlining coordination among multiple defense counsel.

What happens if I miss the 30-day deadline to file a CAFA removal notice?

Missing the 30-day deadline generally waives your right to remove the case to federal court, resulting in the action remaining in state court. The deadline runs from service of the initial complaint or from receipt of an amended pleading or other paper that first makes the case removable. There is also a one-year outer limit from case commencement, with limited exceptions for bad faith. CaseMark helps you track critical deadlines and generate notices quickly to ensure timely filing and preserve your removal rights.

What documents must be attached to a CAFA notice of removal?

You must attach true and correct copies of all process, pleadings, and orders served in the state court action. Required exhibits include the state court complaint with all attachments, the summons and proof of service, and the state court docket sheet. You should also attach any amended pleadings, answers, motions, or other relevant filings, plus written consents from other defendants if they are not signing the notice directly. CaseMark automatically generates an exhibit list and organizes all attachments in proper format for federal court filing.

Related

30b6 Corporate Rep

Master 30(b)(6) Depositions in Minutes, Not Hours

30b6 Deposition

Master 30(b)(6) Depositions in Minutes, Not Hours

Abstract of Judgment

Draft Judgment Abstracts in Minutes, Not Hours