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

LOONTJENS ET AL 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: 
2:13-cv-01217 Search Pacer
ACE Group party(s): 
Opposing Party: 
John J Loontjens
Court Type: 
Federal
US District Court: 
Eastern District of Wisconsin
Date Filed: 
Oct 30 2013

PLEASE TAKE NOTICE that, pursuant to 28 U.S.C. §§ 1441 and 1446, defendants
ACE American Insurance Company, GHP Group, Inc. and W.W. Grainger, Inc. (collectively,
"Defendants"), by their attorneys, Whyte Hirschboeck Dudek S.C., hereby remove this action
from the Circuit Court of Milwaukee County, Wisconsin, to the United States District Court for
the Eastern District of Wisconsin. The grounds for removal are as follows:
1. This action was initiated by the plaintiff, John J. Loontjens, in the Circuit Court of
Milwaukee County, Wisconsin, and is currently pending in said Court as Civil Action No.
13-CV-007826.
2. This action was filed by the plaintiff on August 28, 2013.

3. Defendant ACE American Insurance Company was served via its Registered
Agent on October 8, 2013 at 8:33 a.m.
4. Defendant GHP Group, Inc. was served via on October 11, 2013 at 1:15 p.m. A
copy of the Summons and Complaint is attached to this Notice as Exhibit A, and the plaintiff's
initial discovery requests (which contain the date and time of service and the signature of the
process server on the last page) are attached as Exhibit B.
5. Defendant W.W. Grainger, Inc. was served via its Registered Agent on October 8,
2013 at 8:33 a.m. A copy of the Proof of Service on W.W. Grainger, Inc. is attached as Exhibit C.
6. In addition to the documents attached as Exhibits A through C, Defendants have
also been served with the Notice of Appearance, Answer, Cross-Claim and Counterclaim of
Sentry Insurance, a Mutual Company, which are collectively attached as Exhibit D.
7. This notice is timely filed pursuant to 28 U.S.C. § 1446(b), in that thirty (30) days
have not expired since October 2, 2013 the earliest date upon which any of the Defendants were
served with the Summons and Complaint through their Registered Agent.
8. Plaintiff John J. Loontjens is an individual who resides in Caledonia, Wisconsin.
9. Involuntary plaintiff Sentry Insurance, a Mutual Company, is a Wisconsin
insurance company domiciled in Stevens Point, WI.
10. Defendant ACE American Insurance Company is a Pennsylvania insurance
company with its principal place of business in Philadelphia, PA.
11. Defendant GHP Group, Inc. is an Illinois corporation with its principal place of
business in Morton Grove, IL.
12. Defendant W.W. Grainger, Inc. is an Illinois corporation with its principal place
of business in Lake Forest, IL.

13. In light of the plaintiff's alleged personal injuries and his request for an award of
punitive damages, the matter in controversy in this action exceeds the sum of $75,000, exclusive
of interest and costs.
14. This court has original jurisdiction of this action pursuant to 28 U.S.C. § 1332
because the matter in controversy exceeds the sum of $75,000, exclusive of interest and costs,
and is between parties who are deemed citizens of different states.
15. The United States District Court for the Eastern District of Wisconsin is the
proper district court to which this civil action should be removed, because it was originally filed
in the Milwaukee County, a county within the jurisdiction of this Court.
16. All defendants consent to this removal.
WHEREFORE, Defendants respectfully request that this case be removed from the
Milwaukee County Circuit Court, where it is currently pending, to the United States District
Court for the Eastern District of Wisconsin.
Dated this 30th day of October, 2013.

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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