In Roth v. CHA Hollywood Med. Ctr., L.P., DBA Cha, No. 2:12-cv-07559 (9th Cir. 2013), the Ninth Circuit recently held that 28 U.S.C. § 1446(b)(1) and (b)(3), which require a defendant to remove a case within thirty days of receiving from the plaintiff either an initial pleading or some other document if that pleading or document shows the case is removable, operate only as limitations on the right to remove. The Court noted that it would be “odd, even perverse, to prevent removal” where the defendant may be in a better situation to determine citizenship for purposes of diversity jurisdiction. Thus, if a pleading or other document does not reveal that a case is removable, a defendant may still remove the case outside the two thirty-day periods if it discovers, based on its own investigation, that the case is removable. It is important to keep in mind, however, that a notice of removal must be filed, in any event, within one year of the commencement of a non-Class Action Fairness Act (CAFA) action. For CAFA cases, there is no such time limit and a case can conceivably be removed at any time, outside of the two thirty-day periods, under the court’s holding in Roth v. CHA Hollywood Medical Center.