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THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF SOUTH CAROLINA
GREENVILLE DIVISION
Kamal Webb, Plaintiff,
vs.
Gallagher Bassett Services, Inc. andACE American Insurance
Company,
Defendants.
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Civil Action No.:
NOTICE OF REMOVAL BY ACE
AMERICAN INSURANCE COMPANY
Defendant, ACE American Insurance Company (ACE American), by and
through
counsel, files this Notice of Removal to the United States
District Court for the District of South
Carolina, Greenville Division, pursuant to, inter alia, 28
U.S.C. 1332, 1441, and 1446.
ACE American would respectfully show this Honorable Court:
1. This action was filed in the Greenville County Court of
Common Pleas, case
2014-CP-23-00301, on January 17, 2014. A copy of the summons and
complaint is attached as
Exhibit A.
2. ACE American was served with summons and complaint through
the South
Carolina Department of Insurance on January 24, 2014. A copy of
the notice of service of
process on ACE American is attached hereto as Exhibit B.
3. Plaintiff is a citizen of Greenville County, South
Carolina.
4. Defendant ACE American is a Pennsylvania corporation with its
principal place
of business in the State of Pennsylvania.
5. Defendant Gallagher Bassett Services, Inc. is a corporation
incorporated in the
State of Delaware with its principle place of business in the
State of Illinois.
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6. Gallagher Bassett Services, Inc. consents to the removal of
this case to federal
court.
7. This case is removable to federal court pursuant to 28 U.S.C.
1441 as this court
has original jurisdiction over this action under 28 U.S.C. 1332
in that there is complete
diversity of citizenship between the parties.
8. The amount in controversy exceeds $75,000.00, exclusive of
costs.
9. Ace American has at this time filed a copy of this Notice of
Removal in this
action with the Clerk of Court for Greenville County, South
Carolina, and served counsel for
Plaintiff.
WHEREFORE, Ace American prays that this Court accept this Notice
of Removal and
that this Court take jurisdiction of the this cause and all
further proceedings in said cause in the
Court of Common Pleas, County of Greenville, State of South
Carolina be stayed.
Respectfully submitted,COLLINS & LACY, P.C.
By: /s/ Peter H. DworjanynPETER H. DWORJANYNFederal I.D. No.
[email protected] Lady Street, Sixth Floor
(29201)Post Office Box 12487Columbia, South Carolina 29211(803)
256-2660 (voice)(803) 771-4484 (facsimile)
ATTORNEYS FOR ACE AMERICANINSURANCE COMPANY
Columbia, South CarolinaFebruary 24, 2014
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mailto:[email protected]:[email protected]
