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AMI STAMPING LLC v. ACE AMERICAN INSURANCE COMPANY et al notice of removal

AMI STAMPING LLC v. ACE AMERICAN INSURANCE COMPANY et al notice of removal

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Published by: ACELitigationWatch on Jan 20, 2014
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01/20/2014

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UNITEDSTATESDISTRICTCOURTEASTERNDISTRICTOFMICHIGANSOUTHERNDIVISIONAMISTAMPING,LLC,
Plaintiff,v.
ACEAMERICANINSURANCECOMPANY,andSTARRTECHNICALRISKSAGENCY,INC.,
Defendants.Case No.:State Case No. 13-016312-CK 
PETITIONFORREMOVAL
Pursuant to 28 U.S.C. §§ 1332, 1441(a), 1446(a), Fed. R. Civ. P. 81, andLocal Rule 81.1 Defendants, ACE American Insurance Company and StarTechnical Risks Agency, Inc. (collectively "Defendants") petition the Court for removal of the action described below from the Circuit Court for Wayne County,Michigan to this Court, and in support thereof, state as follows:1. On December 20, 2013, Plaintiff, AMI Stamping, LLC ("Plaintiff")filed an action against Defendants in the Circuit Court for Wayne County,Michigan, under Case Number 13-016312-CK.2. Defendant, ACE American Insurance Company, was served with acopy of the Complaint on December 26, 2013.3. Plaintiff's Complaint seeks monetary damages for breach of contractarising out of Plaintiff's claim for insurance proceeds following discovery of a theft
2:14-cv-10176-DML-PJK Doc # 1 Filed 01/15/14 Pg 1 of 5 Pg ID 1
 
of tools, equipment, and other personal property in which Plaintiff had an interestfrom a building located at 4300 Cabot Drive in Detroit, Michigan in January 2012("the Loss"). A copy of the Summons and Plaintiff's Complaint are attached asExhibit A.
BASISFORFEDERALJURISDICTION
4. This court has original jurisdiction of this action under 28 U.S.C. §1332 because there is complete diversity of citizenship between the parties and theamount in controversy, exclusive of interest and costs, exceeds $75,000.00.
 See
 28U.S.C. § 1441.5. Removal to the United States District Court for the Eastern District of Michigan, Southern Division, is proper because it is the district and divisionembracing the place where the removed action was pending. 28 U.S.C. § 1441(a).
DIVERSITYOF CITIZENSHIP
6. Plaintiff, AMI Stamping, LLC, is a Michigan limited liabilitycompany. Pl.'s Compl. ¶ 1.7. The members of AMI Stamping, LLC are the Scott R. HofmeisteIrrevocable Trust, the Megan G. Hofmeister Irrevocable Trust, and the Jamie S.Hofmeister Irrevocable Trust. All three trusts were established by George F.Hofmeister, a citizen of Kentucky.
2:14-cv-10176-DML-PJK Doc # 1 Filed 01/15/14 Pg 2 of 5 Pg ID 2
 
8. On information and belief, the Scott R. Hofmeister Irrevocable Trustis organized under the laws of the State of Indiana with Homer W. McClarty astrustee and Scott R. Hofmeister as the beneficiary. Homer W. McClarty is acitizen of Michigan. Scott R. Hofmeister is a citizen of Kentucky.9. On information and belief, the Megan G. Hofmeister IrrevocableTrust is organized under the laws of the State of Indiana with Homer W. McClartyas trustee and Megan G. Hofmeister as the beneficiary. Megan G. Hofmeister is acitizen of Kentucky.10. On information and belief, the Jamie S. Hofmeister Irrevocable Trustis organized under the laws of the State of Indiana with Homer W. McClarty astrustee and Jamie S. Hofmeister as the beneficiary. Jamie S. Hofmeister is acitizen of Kentucky.11. Defendant, ACE American Insurance Company, is a corporationorganized in Pennsylvania and with its principal place of business in Pennsylvania.12. Defendant, Starr Technical Risks Agency, Inc. is a corporationorganized in New York and with its principal place of business in New York.
AMOUNTINCONTROVERSY
13. The Complaint alleges that more than $25,000 is in controversy,exclusive of interest and costs but does not plead a specific amount in controversyin excess of the sum required under 28 U.S.C. § 1332(a).
2:14-cv-10176-DML-PJK Doc # 1 Filed 01/15/14 Pg 3 of 5 Pg ID 3

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