IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLORADOCivil Action No.JOSHUA R. NOWLAN,Plaintiff,vs.CINEMARK, USA, INC., d/b/a CENTURY AURORA 16,Defendant.
COMPLAINT AND JURY DEMAND
____________________________________________________________________________Plaintiff, Joshua R. Nowlan, by his attorneys, KEATING WAGNER POLIDORI FREE,P.C. herby submits his Complaint and Jury Demand against the above captioned defendant. Asgrounds therefor, Plaintiff states and alleges as follows:
At all times relevant to this case, Plaintiff Joshua Nowlan was a resident of the State of Colorado, and he presently resides at 19782 E. Bates Drive, Aurora, CO 80013.2.
Upon information and belief, Defendant Cinemark, USA, Inc., d/b/a Century Aurora 16is a Texas corporation with its principal place of business at 3900 Dallas Parkway, Suite500, Plano, TX 75093. The theater ("theater") where the incidents forming the basis forthis Complaint was and is located at 14200-14300 E. Alameda Avenue, Aurora, CO80012 in the County of Arapahoe, State of Colorado.3.
This Court has jurisdiction over Plaintiff's claims against this Defendant pursuant to 28U.S.C. §1332, since there is complete diversity of citizenship between the parties, and
Case 1:12-cv-02517 Document 1 Filed 09/21/12 USDC Colorado Page 1 of 11