Case f:13-c'V-00781-BMC Document 1 Filed 02/12/13 Page
Pursuant to 28 U.S.C. § 1446(a), copies of
records, orders, process andpleadings that have been served on the Defendants, and which are known to exist, are attachedhereto as Exhibit A.
Pursuant to 28 U.S.C. § 1446(d), a copy of this Notice of Removal is being filedwith the Kings County Clerk of the Supreme Court of the State of New York. A copy of theunexecuted Notice of Filing, without attachments, is attached hereto as Exhibit
By filing this Notice of Removal, Westchester does not waive any availabledefenses.
THIS COURT HAS DIVERSITY JURISDICTION
6. This Court has original jurisdiction over this action pursuant to 28 U.S.C. §
and therefore, this action is removable to this Court pursuant to 28 U.S.C. § 1441.7. As set forth more fully below, the proper parties to this action are completelydiverse.8. Upon information and
at the time the Plaintiffs commenced the state courtaction, Plaintiff Long was an individual residing at 12 Homewood Lane, Dix Hills, New York.9. Upon information and
at the time the Plaintiffs commenced the state courtaction, Plaintiff
is an alleged business entity with its principal place of businesssupposedly located at 948 East 92nd Street, Brooklyn, New York.
At the time the Plaintiffs commenced the state court action, Westchester FireInsurance Company was a corporation organized and existing under and by virtue of the laws ofthe Commonwealth of Pennsylvania, and was duly authorized to transact surety business in theState of New York by the New York State Department of Financial Services. Westchester File'sprincipal place of business is in Philadelphia, Pennsylvania.