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BANKERS STANDARD INSURANCE COMPANY v. EARTHCORE INDUSTRIES, LLC et al Complaint

BANKERS STANDARD INSURANCE COMPANY v. EARTHCORE INDUSTRIES, LLC et al Complaint

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Published by: ACELitigationWatch on Feb 21, 2013
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02/21/2013

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ATLANTA\285682\1
 
FOR THE UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF GEORGIAATLANTA DIVISION
Bankers Standard Insurance )Company, ))Plaintiff, ))v. ) CIVIL ACTION) FILE NO.: __________________Earthcore Industries, LLC; Icerock, )Inc.; Icerock, LLC; and West Cobb )Construction & Consulting, Inc., ))Defendants. )
COMPLAINT FOR PROPERTY DAMAGE
Plaintiff Bankers Standard Insurance Company sues Defendants EarthcoreIndustries, LLC, Icerock, Inc., Icerock, LLC and West Cobb Construction &Consulting, Inc., as follows:
THE PARTIES, JURISDICTION AND VENUE
1.
 
Plaintiff Bankers Standard Insurance Company is a Pennsylvaniacorporation with its principal place of business in Philadelphia, Pennsylvania.2.
 
Defendant Earthcore Industries, LLC is a Delaware limited liabilitycompany with its principal place of business at 6899 Phillips Industrial Boulevard,Jacksonville, Florida 32256. Defendant Earthcore Industries, LLC may be served
Case 1:13-cv-00493-WSD Document 1 Filed 02/14/13 Page 1 of 10
 
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ATLANTA\285682\1
 
with process by service upon its registered agent: Corpdirect Agents, Inc., 900 OldRoswell Lakes Parkway, Suite 310, Roswell, Georgia 30076.3.
 
Defendant Icerock, Inc. is a Florida corporation with its principalplace of business at 6899 Phillips Industrial Boulevard, Jacksonville, Florida32256. Defendant Icerock, Inc. may be served with process by service upon itsregistered agent: Gresham R. Stoneburner, at Stoneburner Berry & Simmons, P.A.,841 Prudential Drive, Suite 1400, Jacksonville, Florida 32207.4.
 
Defendant Icerock, LLC is a Florida limited liability company with aprincipal place of business at 6899 Phillips Industrial Boulevard, Jacksonville,Florida 32256. Defendant Icerock, LLC may be served with process by serviceupon its registered agent: Gresham R. Stoneburner, at Stoneburner Berry &Simmons, P.A., 841 Prudential Drive, Suite 1400, Jacksonville, Florida 32207.5.
 
Defendant West Cobb Construction & Consulting, Inc. is a Georgiacorporation with its principal place of business at 1795 Benningfield Drive,Marietta, Georgia 30064. Defendant may be served with process by service uponits CEO, CFO, and Secretary: Billy Murdock, 1795 Benningfield Drive, Marietta,Georgia 30064.6.
 
This court has jurisdiction pursuant to 28 U.S.C. § 1332 because thematter in controversy exceeds the sum of $75,000.00, exclusive of interest and
Case 1:13-cv-00493-WSD Document 1 Filed 02/14/13 Page 2 of 10
 
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ATLANTA\285682\1
 
costs, and there is complete diversity of citizenship between Plaintiff andDefendants.7.
 
Venue is proper in this judicial district pursuant to 28 U.S.C.§ 1391(a) because a substantial part of the events or omissions giving rise to theclaim occurred in this judicial district and the property at issue is situated in this judicial district.
ALLEGATIONS OF FACTS COMMON TO ALL COUNTS
8.
 
This claim arises from the November 26, 2012, fire at the home of Marshall Hunt in Atlanta, Georgia.9.
 
At the time of the fire, and at all other times material to this action, theHunt home was insured by Plaintiff Bankers Standard Insurance Company.10.
 
As a consequence of the fire, and in accordance with the terms andconditions of its policy of insurance issued to Hunt, Plaintiff Bankers Standard hasindemnified Hunt for his losses arising from the fire, and will continue toindemnify Hunt for his losses until adjustment of this loss is complete.11.
 
Pursuant to its indemnification of Hunt as required by its insurancepolicy, Plaintiff Bankers Standard is subrogated to all of Hunt’s rights, claims, andcauses of action against those parties responsible for the November 26, 2012, fireto the extent of its indemnification.
Case 1:13-cv-00493-WSD Document 1 Filed 02/14/13 Page 3 of 10

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