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UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF ILLINOIS
Civil Action No.
STATEMENT OF CLAIMJurisdictionAndVenue
1.This Court has original jurisdiction
in person am
according to 28 USC Section 1330 (a)and pursuant to 28 USC Section 1367(a), in that are so related to claims within the original jurisdiction of the district court that they form part of the same case or controversy under Article III of the United States Constitution.2.Venue is proper in this district pursuant to the provisions of 28 USC Section 1391(f) (1) (3),and pursuant to 28 USC Section 1391(d) and 28 USC Section 1391(a).3.The Defendant LifeChoice International A.D. is a private Bulgaria commercial companyincorporated in the City of Sofia, Bulgaria on July 17th 1993 and having commercialinterests and activities in the United States.4.The Plaintiff Michael Kapoustin, having been a resident of the United States and citizen of Canada has a derivative proprietary interest in commercial activities of the Defendant in theUnited States and elsewhere. The Plaintiff Kapoustin having suffered damages as a directresult of the Defendant’s failure to meet its obligation to the Plaintiff.5.Plaintiff’s rights are evidenced in all instances by a bank document issued by theInternational Bank for Investments and Development of Sofia, Bulgaria or Balkan Bank,Plovdiv, Bulgaria or by contract executed by a legal representative of the Defendant
19305852.docPage 1 of 2
MICHAEL KAPOUSTIN,
Plaintiff,v.
LIFECHOICE INTERNATIONAL A.D.
Defendant
of 00

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