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CAUSE NO. 21-DCV-283916
PRAJEE INVESMENTS,
IN THE DISTRICT COURT OF
Plaintiff
v
FORT BEND COUNTY, TEXAS
PRINCETON EXCESS AND
SURPLUSS LINE INSURANCE
COMPANY,
Defendant 400th JUDICIAL DISTRICT
NOTICE OF REMOVAL
TO THE COURT:
Please take notice that, The Princeton Excess and Surplu
s Lines Insurance Company,
named Defendant in the above-entitled action has,
on July 2, 2021, filed a Petition for Removal,
a copy of which is attached hereto (Civil Action No.
4:21-cv-02157) , in the Office of the Clerk
of the United States District Court for the Southern Distri
ct of Texas, Houston Division.
Respectfully submitted,
CALLIER LAW GROUP PLLC
4s/ Joseph Alan Callier
Joseph Alan Callier
TBN — 03663500
Megan Elizabeth Callier
TBN - 24097448
4900 Woodway, Suite 700
Houston, Texas 77056
Telephone: (713) 439-0248
Facsimile: (713) 439-1908
Email: callier@callierlawgrouppllc.con
meallier@callierlawgrouppllc.com
Attorneys for Defendant
THE PRINCETON EXCESS AND
SURPLUS LINES INSURANCE
COMPANY
G:\Docs\143 MRE CB\MRE Files\143-99Prajee Invest\Pleadings
\Federal Pleadings\r notice of Removal.doc
Page |
CERTIFICATE OF SERVICE
Thereby certify that a true and correct copy of the
foregoing instrument has been served
upon all counsel of record by certified mail/return
receipt requested on the 6th day of July, 2021.
4s/Joseph Alan Callie
Joseph Alan Callier
G\Docs\143 MRE CB\MRE Files\143-99Prajce Invest\Pleadings
\Federal Pleadings\notice of Removal.doc
Page 2
Case 4:21-cv-02157 Document 1 Filed on 07/02/21 in TXSD Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
PRAJEE INVESMENTS, §
Plaintiff §
§
v.
§ CIVIL ACTION NO. HiAl -0y- 02157
THE PRINCETON EXCESS AND § JUDGE
SURPLUS LINES INSURANCE §
COMPANY, § JURY DEMANDED
Defendant §
CAUSE NO. 21-DCV-283916
PRAJEE INVESMENTS, IN THE DISTRICT COURT OF
Plaintiff
v. FORT BEND COUNTY, TEXAS
PRINCETON EXCESS AND
SURPLUSS LINE INSURANCE
COMPANY,
Defendant 400th JUDICIAL DISTRICT
DEFENDANT PRINCETON EXCESS AND SURPLUS LINES INSURANCE
COMPANY’S PETITION FOR REMOVAL
TO THE UNITED STATES DISTRICT COURT:
This is a Petition for Removal of this action from the 400th Judicial District Court of the
State of Texas, Fort Bend County, Texas to the United States District Court for the Southern
District of Texas, Houston Division, pursuant to 28 U.S.C. §1332.
STATE PROCEEDINGS:
1 The petitioner, The Princeton Excess Surplus Lines Insurance Company (Princeton) is a
Defendant in a civil action brought against it in the 400th Judicial District Court of the State of
Case 4:21-cv-02157 Document 1 Filed on 07/02/21 in TXSD Page 2 of 3
Texas, Fort Bend County, Texas (a copy of the Original Petition
is attached hereto Exhibit A)
asserting a claim against Princeton, with a “home office or principal place of
business... Princeton, NJ...and seeks damages of $75,000.00”. Therefore,
diversity in citizenship
and $75,000.00 in controversy exists providing original jurisdiction in
federal court.
REMOVAL TIMELINE AND JURISDICTION:
2, This action was commenced by the filing of an Original Petition on
or about May 28,
2021, and service upon Princeton occurred on or about June 3, 2021. The Original Petition
claims “breach of the insurance contract... unfair and deceptive act or
practice in the busin ess of
insurance... breach of the common law duty of good faith and fair dealing... Defendant
knowingly...engaged in actions and/or omissions Jor the purpose of misleading Plaintiff...
Defendant was a member of a combination... whose object was to accompl
ish.. illegal acts upon
Plaintiff’ (9 28-57).
3 The controversy herein between the Plaintiff and Princeton is a controv
ersy involving
parties from the State of Texas and the State of New Jersey.
4 This is a civil action brought in a State Court of which the United States
District Courts
have original jurisdiction because of diversity and $75,000.00 in controv
ersy, pursuant to 28
U.S.C. §1332.
NOTICE
5 Plaintiff has been notified of intent by Princeton to remove this cause
through their
attorney of record who received a copy of this removal petition along with the 400th Judicial
District Court of the State of Texas, Fort Bend County, Texas by its receipt
of a notice of filing.
6. This removal petition was filed with this Court within thirty (30) days
after receipt by
Princeton of the Original Petition, which was received on June
3, 2021.
Case 4:21-cv-02157 Document 1 Filed on 07/02/21 in TXSD Page 3 of 3
WHEREFORE, Petitioner for Removal The Princeton Excess Surplus Lines Insurance
Company prays that this cause proceed in this Court as an action properl
y removed thereto.
Respectfully submitted,
CALLIER LAW GROUP PLLC
/s/ Joseph Alan Callier
Joseph Alan Callier
TBN — 03663500
Megan Elizabeth Callier
TBN - 24097448
4900 Woodway, Suite 700
Houston, Texas 77056
Telephone: (713) 439-0248
Facsimile: (713) 439-1908
Email: callier@callierlawgrouppllc.com
meallier@callierlawgrouppllc.com
Attorneys for Defendant
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing instrument
has been served
upon all counsel of record through the court’s electronic-filing system
or, in person, by mail, by
commercial delivery service, by facsimile or by email on the 2nd day
of July, 2021
/s/ Joseph Alan Callier
Joseph Alan Callier
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CAUSE NO. 21-DCV-283916 PRAJEE INVESMENTS, IN THE DISTRICT COURT OF Plaintiff v FORT BEND COUNTY, TEXAS PRINCETON EXCESS AND SURPLUSS LINE INSURANCE COMPANY, Defendant 400th JUDICIAL DISTRICT NOTICE OF REMOVAL TO THE COURT: Please take notice that, The Princeton Excess and Surplu s Lines Insurance Company, named Defendant in the above-entitled action has, on July 2, 2021, filed a Petition for Removal, a copy of which is attached hereto (Civil Action No. 4:21-cv-02157) , in the Office of the Clerk of the United States District Court for the Southern Distri ct of Texas, Houston Division. Respectfully submitted, CALLIER LAW GROUP PLLC 4s/ Joseph Alan Callier Joseph Alan Callier TBN — 03663500 Megan Elizabeth Callier TBN - 24097448 4900 Woodway, Suite 700 Houston, Texas 77056 Telephone: (713) 439-0248 Facsimile: (713) 439-1908 Email: callier@callierlawgrouppllc.con meallier@callierlawgrouppllc.com Attorneys for Defendant THE PRINCETON EXCESS AND SURPLUS LINES INSURANCE COMPANY G:\Docs\143 MRE CB\MRE Files\143-99Prajee Invest\Pleadings \Federal Pleadings\r notice of Removal.doc Page | CERTIFICATE OF SERVICE Thereby certify that a true and correct copy of the foregoing instrument has been served upon all counsel of record by certified mail/return receipt requested on the 6th day of July, 2021. 4s/Joseph Alan Callie Joseph Alan Callier G\Docs\143 MRE CB\MRE Files\143-99Prajce Invest\Pleadings \Federal Pleadings\notice of Removal.doc Page 2 Case 4:21-cv-02157 Document 1 Filed on 07/02/21 in TXSD Page 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION PRAJEE INVESMENTS, § Plaintiff § § v. § CIVIL ACTION NO. HiAl -0y- 02157 THE PRINCETON EXCESS AND § JUDGE SURPLUS LINES INSURANCE § COMPANY, § JURY DEMANDED Defendant § CAUSE NO. 21-DCV-283916 PRAJEE INVESMENTS, IN THE DISTRICT COURT OF Plaintiff v. FORT BEND COUNTY, TEXAS PRINCETON EXCESS AND SURPLUSS LINE INSURANCE COMPANY, Defendant 400th JUDICIAL DISTRICT DEFENDANT PRINCETON EXCESS AND SURPLUS LINES INSURANCE COMPANY’S PETITION FOR REMOVAL TO THE UNITED STATES DISTRICT COURT: This is a Petition for Removal of this action from the 400th Judicial District Court of the State of Texas, Fort Bend County, Texas to the United States District Court for the Southern District of Texas, Houston Division, pursuant to 28 U.S.C. §1332. STATE PROCEEDINGS: 1 The petitioner, The Princeton Excess Surplus Lines Insurance Company (Princeton) is a Defendant in a civil action brought against it in the 400th Judicial District Court of the State of Case 4:21-cv-02157 Document 1 Filed on 07/02/21 in TXSD Page 2 of 3 Texas, Fort Bend County, Texas (a copy of the Original Petition is attached hereto Exhibit A) asserting a claim against Princeton, with a “home office or principal place of business... Princeton, NJ...and seeks damages of $75,000.00”. Therefore, diversity in citizenship and $75,000.00 in controversy exists providing original jurisdiction in federal court. REMOVAL TIMELINE AND JURISDICTION: 2, This action was commenced by the filing of an Original Petition on or about May 28, 2021, and service upon Princeton occurred on or about June 3, 2021. The Original Petition claims “breach of the insurance contract... unfair and deceptive act or practice in the busin ess of insurance... breach of the common law duty of good faith and fair dealing... Defendant knowingly...engaged in actions and/or omissions Jor the purpose of misleading Plaintiff... Defendant was a member of a combination... whose object was to accompl ish.. illegal acts upon Plaintiff’ (9 28-57). 3 The controversy herein between the Plaintiff and Princeton is a controv ersy involving parties from the State of Texas and the State of New Jersey. 4 This is a civil action brought in a State Court of which the United States District Courts have original jurisdiction because of diversity and $75,000.00 in controv ersy, pursuant to 28 U.S.C. §1332. NOTICE 5 Plaintiff has been notified of intent by Princeton to remove this cause through their attorney of record who received a copy of this removal petition along with the 400th Judicial District Court of the State of Texas, Fort Bend County, Texas by its receipt of a notice of filing. 6. This removal petition was filed with this Court within thirty (30) days after receipt by Princeton of the Original Petition, which was received on June 3, 2021. Case 4:21-cv-02157 Document 1 Filed on 07/02/21 in TXSD Page 3 of 3 WHEREFORE, Petitioner for Removal The Princeton Excess Surplus Lines Insurance Company prays that this cause proceed in this Court as an action properl y removed thereto. Respectfully submitted, CALLIER LAW GROUP PLLC /s/ Joseph Alan Callier Joseph Alan Callier TBN — 03663500 Megan Elizabeth Callier TBN - 24097448 4900 Woodway, Suite 700 Houston, Texas 77056 Telephone: (713) 439-0248 Facsimile: (713) 439-1908 Email: callier@callierlawgrouppllc.com meallier@callierlawgrouppllc.com Attorneys for Defendant CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument has been served upon all counsel of record through the court’s electronic-filing system or, in person, by mail, by commercial delivery service, by facsimile or by email on the 2nd day of July, 2021 /s/ Joseph Alan Callier Joseph Alan Callier