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

GRAVES v. ACE AMERICAN INSURANCE COMPANY 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: 
5:13-cv-03122 Search Pacer
ACE Group party(s): 
Opposing Party: 
Klarissa Graves
Court Type: 
Federal
US District Court: 
Western District of Louisiana
Date Filed: 
Nov 22 2013

Plaintiff alleges personal injury, including scarring and disfigurement, loss of enjoyment
of life, past and future medical expenses, past and future lost wages, past and future physical
pain and suffering, and past and future mental anguish distress and suffering. Plaintiff claims
she has been hospitalized multiple days with multiple fractures and a torn spleen. She claims she
may require future surgery. Plaintiff is claiming her damages are excess of $75,000, exclusive of
interests and costs.

Plaintiff is alleged to be a resident and domiciliary of Bossier Parish, Louisiana.
4.
Defendant, Sky Attractions, LLC, is a Michigan corporation, whose corporate
headquarters and principal place of business is in the State of Michigan. McDonagh
Amusements is a d/b/a name for Sky Attractions, LLC. Its members are all citizens of Michigan.
5.
Also named as defendant herein is ACE American Insurance Company. ACE American
Insurance Company is a Pennsylvania corporation. Its citizenship is deemed the same as its
insured, Sky Attractions, LLC, pursuant to 28 U.S.C. § 1441(c).
6.
Johan Small, Johann Petrus Smit, and Kieran Matthew Fouries are all also named as
defendants. On information and belief, Small, Smit and Fouries are all citizens of the Republic
of South Africa, and were sued in their respective capacities as employees of Sky Attractions.
Small, Smit and Fouries have not been served.
7.
KMG B.V., Inc. is also named as defendant herein. On information and belief, KMG
B.V., Inc. is an alien corporation with its domicile in the Netherlands. On information and belief
it is unserved.

8.
Haas & Wilkerson, Inc. was also named, but has been dismissed. In any event, on
information and belief, Haas & Wilkerson, Inc. is a Kansas corporation with it principal place of
business in the State of Kansas.
9.
There is complete diversity between plaintiff Klarissa Graves and all named defendants.
10.
Defendant Sky Attractions, LLC, shows it is entitled to remove this suit from the First
Judicial District Court for Caddo Parish, Louisiana to the United States District Court for the
Western District of Louisiana pursuant to the provisions of 28 U.S.C. § 1332 and § 1441.
11.
The only other served defendant, ACE American Insurance Company, consents to
removal.
12.
Upon filing this notice of removal, counsel for appearer will give written notice to
plaintiffs counsel and provide a copy of the notice of removal to the Clerk of Court for the First
Judicial District Court of Caddo Parish, Louisiana.
WHEREFORE, defendant Sky Attractions, LLC prays that this Notice of Removal be
filed, and that the suit entitled Klarissa Graves v. ACE American Insurance Company, Haas &
Wilkerson Insurance Company, Inc., SIcy Attractions, LLC, McDonagh Amusements, Inc. and
K&4G B. V., Inc., number 571,254-A, First Judicial District Court of Caddo Parish, Louisiana, be
removed to the United States District Court for the Western District of Louisiana and that the

First Judicial District Court for Caddo Parish, Louisiana proceed no further herein unless the
case is subsequently remanded.

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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