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The Collaborative Clearinghouse for Lawsuits and Other Claims Against ACE Group Insurance Companies

BODDEN, MARY ET AL v. TARGET CORPORATION et al

ATTENTION: It is possible that this information may no longer be current and therefore may be inaccurate. The index contains both open and closed cases and is not a complete list of cases in which an ACE Insurance Group company is involved. This information is provided to give interested persons an idea of the issues disputed in the indexed cases. For a full understanding of a case, one should read the rest of the court file, including the response. For the most up-to-date and complete information on a case, visit www.pacer.gov or contact the clerk of the relevant court.

Case Number: 
3:14-cv-00159 Search Pacer
ACE Group party(s): 
Opposing Party: 
Mary Bodden
Court Type: 
Federal
US District Court: 
Western District of Wisconsin
Date Filed: 
Feb 27 2014

PLEASE TAKE NOTICE that Target Corporation and Ace American Insurance
Company, by their attorneys, CRIVELLO CARLSON, S.C, pursuant to 28 U.S.C. §§ 1441(b)
and 1446, file this Notice of Removal with the Court. The grounds for removal of this action are
as follows:
1. A civil action designated as Case No. 14-CV-44 has been commenced and is now
pending in the Circuit Court for Wood County, Wisconsin, between the above-named parties.
2. On January 27, 2014, the plaintiffs filed the Summons and Complaint in the
Circuit Court for Wood County, Wisconsin. A true and correct copy of the Summons and
Complaint is attached as Exhibit A.
3. On February 24, 2014, Target Corporation and Ace American Insurance
Company filed their Answer and Affirmative Defenses in the Circuit Court for Wood County,
Wisconsin, and served all parties who have appeared in Case No. 14CV44. A true and correct
copy of Target Corporation and Ace American Insurance Company's Answer is attached as
Exhibit B. On February 27, 2014, the Defendants filed an Amended Answer and Affirmative
Defenses. See Exhibit C.
4. The above-described action is a civil action for damages alleged to have arisen
from actions arising in Wood County, Wisconsin.
5. The United States District Court for the Western District of Wisconsin has
jurisdiction over this action for the following reasons:
a. The Plaintiffs are residents of the State of Wisconsin. Complaint at ]} 1.
Defendant Target Corporation is a foreign corporation incorporated in Minnesota with its
principal place of business located in Minneapolis, Minnesota. See Exhibit D. Defendant Ace
American Insurance Company is a foreign corporation incorporated in Pennsylvania with a
principal place of business located in Philadelphia, Pennsylvania See Exhibit E.
b. Removal of this action to the United States District Court is proper under
28 U.S.C. Sec. 1441(a) and (b) because there is complete diversity of citizenship between the
plaintiff and the defendants and the amount in controversy exceeds $75,000. The United States
District Court would, therefore, have had original jurisdiction of this matter under 28 U.S.C. Sec.
1332 had the action been brought in federal court originally.
c. The case is properly venued in that the Plaintiffs are within the jurisdiction
of the Western District of Wisconsin, and that some of the alleged events or omissions that form
the basis for the Plaintiffs' claims occurred within the Western District of Wisconsin.
d. This Notice of Removal is timely under Section 1446(b) of Title 28 of the
United States Code because the time permitted by statute for filing has not expired.
e. Defendants Target Corporation and Ace American Insurance Company
consent to removal.
8. Concurrent with the filing of the original Notice of Removal, Defendants, by their
attorneys, notified all active parties and the Clerk of the Circuit Court for Wood County that this
case is the subject of a petition for removal in the United States District Court for the Western
District of Wisconsin, as required by 28 U.S.C. § 1446(d).

The provided text is an excerpt from a document filed in this case. For a full understanding of the case, one should read the complete court file, including the response.

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