Document text
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND
(NORTHERN DIVISION)
THE CORDISH COMPANIES, INC. * 601 East Pratt Street, 6
th Floor
Baltimore, Maryland 21202 * P l a i n t i f f , * v. * Case No.:
AFFILIATED FM INSURANCE COMPANY, * 270 Central Avenue, P.O. Box 7500 Johnston, Rhode Island 02919-4949 * Defendant. * * * * * * * * * * * * * * *
DEFENDANT AFFILIATED FM INSURANCE COMPANY’S
NOTICE OF REMOVAL
The Defendant, Affiliated FM Insurance Co mpany (“AFM”), by and through undersigned
counsel, and pursuant to 28 U.S.C. §§ 1332 and 1446, hereby files this Notice of Removal from
the Circuit Court for Baltimore City, Maryland, to the United States District Court for the
District of Maryland, Northe rn Division, and in support thereof state as follows:
1. Plaintiff, The Cordish Companies, Inc. (“Cordish”), initiated the present action
against AFM in the Circuit Court for Baltimo re City, Maryland, Ci vil Action No. 24-c-20-
002952, on or about July 9, 2020, seeking a declar atory judgment and alleging breach of
contract.
2. AFM came into receipt of the Complaint on or about July 22, 2020.
3. Pursuant to 28 U.S.C. §1446(b)(1), this no tice is being filed w ithin 30 days of
AFM’s receipt of the Plai ntiff’s initial pleadings.
4. Plaintiff is domiciled in the State of Maryland. Case 1:20-cv-02419-ELH Document 1 Filed 08/21/20 Page 1 of 3
2
5. AFM is an insurance company organized under the laws of the State of Rhode
Island and maintains its principal place of business in Rhode Island.
6. This Court has original jurisdiction pur suant to 28 U.S.C. § 1332. There is true
diversity of citizenship, and th e amount in controve rsy exceeds $75,000, excl usive of costs and
interest.
7. A copy of the Complaint filed in the Circ uit Court and the subsequently issued
Summons are attached hereto as Exhibit A .
8. AFM will file and serve its responsive pl eading to the Complaint as required by
the Federal Rules.
9. A true and correct copy of the Notice of Filing of Removal, which has been filed
contemporaneously in the Maryland Circui t Court action, is attached hereto as Exhibit B .
Respectfully Submitted,
/s/ Bryant S. Green, Esq. (#19752)
Craig D. Roswell, Esq. (# 09529)
Bryant S. Green, Esq. (# 19752) N
ILES, BARTON & WILMER , LLP
111 S. Calvert Street, Suite 1400 Baltimore, Maryland 21202 (410) 783-6300 (410) 783-6363 facsimile [email protected] [email protected] Counsel for Defendant, Affiliated FM Insurance Company
Case 1:20-cv-02419-ELH Document 1 Filed 08/21/20 Page 2 of 3
3
CERTIFICATE OF SERVICE
I CERTIFY that on this 21st day of August, 2020, a copy of this Notice of Removal was
served via e-mail, first cl ass mail, and CM/ECF on:
Daniel J. Healy, Esq.
Marshall Gilinsky, Esq. Pamela D. Hans, Esq. Maria Brinkmann, Esq. [email protected] [email protected] [email protected] [email protected] 1717 Pennsylvania Avenue NW, Suite 200 Washington, DC 20006 Counsel for Plaintiff,
The Cordish Companies, Inc. / s / B r y a n t S . G r e e n
B r y a n t S . G r e e n
Case 1:20-cv-02419-ELH Document 1 Filed 08/21/20 Page 3 of 3