Lessee, LLC, Hilton Management, LLC and Hilton New Orleans, LLC (at times hereincollectively “Defendants”), named defendants in that certain proceeding entitled, “
Rita Vesich v. ACE American Insurance Company, et al.
," bearing Number 2012-02880 and pending in Division"A" of the Civil District Court for the Parish of Orleans, State of Louisiana, hereby remove that proceeding to the United States District Court, Eastern District of Louisiana.Copies of this Notice of Removal are being served upon Darla D’Amico as counsel of record for plaintiff, Rita Vesich (“plaintiff”), and will promptly be filed with the Clerk of theaforesaid State Court, all in conformity with 28 U.S.C. §1446(d). Defendants appear for the purpose of removal only and for no other purpose and, reserving all rights and defenses, state asfollows:1.On March 22, 2012, plaintiff filed a Petition for Damages (the “Petition”) captioned “
RitaVesich v. ACE American Insurance Company, et al.
,” bearing Number 2012-02880 and pendingin Division "A" of the Civil District Court for the Parish of Orleans, State of Louisiana, whichCourt is within the jurisdictional boundaries of the Eastern District of Louisiana.2.Defendants, ACE American Insurance Company, Hilton Riverside, LLC, HiltonWorldwide, Inc. and Hilton Management, LLC were served with plaintiff’s Petition on April 3,2012, through their agent(s) for service of process, Corporation Service Company, 320Somerulos St., Baton Rouge, La. and for ACE, the Louisiana Secretary of State. InternationalRivercenter Lessee, LLC was served on April 9, 2012 through its agent for service of process,Robert C. Carpenter and there is no record of returned service on Hilton New Orleans, L.L.C.Page 2 of 7
Case 2:12-cv-01129-ILRL-DEK Document 1 Filed 05/02/12 Page 2 of 7