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

PINKERTON v. LEONARDO 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: 
5:12-cv-00140 Search Pacer
ACE Group party(s): 
Opposing Party: 
Joseph Mark Pinkerton
Court Type: 
Federal
US District Court: 
Middle District of Georgia
Date Filed: 
Apr 20 2012

"1. On March 23, 2012, Plaintiff Joseph Mark Pinkerton filed a complaint styled Joseph Mark Pinkerton v. Joseph Lee Leonardo, Werner Enterprises, Inc . , Ace American Insurance Company and John Does 1-10, In the State Court of Bibb County, Georgia, Civil Action File No. 79666. A copy of the Summons and Complaint are attached hereto as Exhibit 1 .

2. Defendants Joseph Lee Leonardo, Werner Enterprises, Inc. and Ace American Insurance Company attach a copy of the Answer to the Complaint and Demand for a Jury of Twelve they filed in the State Court of Bibb County, Georgia as Exhibit 2 and Exhibit 3.

3 . The Plaintiff is a citizen and resident of the State of Georgia. Complaint ~ 1.

4 . Defendant Joseph Lee Leonardo is a citizen and resident of Las Vegas with his permanent address at 2993 Berman Street, Las Vegas, Nevada 89169.

5. Defendant Werner Enterprises, Inc. is a Nebraska corporation with its principal place of business at 14507 Frontier Road, Omaha, Nebraska 68138.

6. Defendant Ace American Insurance Company is a Pennsylvania corporation with its principal place of business at 436 Walnut Street, Philadelphia, Pennsylvania 19106.

7. The Plaintiff alleges in the Compliant he is entitled to recover for past and future medical expenses, lost wages, past and future pain and suffering plus punitive damages in excess of $100,000. Complaint ~~ 54, 83.

8. The foregoing action is subj ect to removal to this Court pursuant 28 U.S.C. §1332(a) because there is a complete diversity of citizenship between Plaintiff and Defendants and the amount in controversy exceeds the sum of $75,000, exclusive of interest and costs.

9. Defendants are entitled to remove this case from the State Court of Bibb County, Georgia to the United States District Court for the Northern District of Georgia, Atlanta Division pursuant to 28 U.S.C. §§ 1441(a), 1446(a) and (b).

10. Defendants give notice of the removal of this action to this Court within thirty days after service of the first Defendant of a copy of the Summons and Complaint filed in the State Court of Bibb County, Georgia pursuant to 28 U.S.C. § 1446 and Rule 11 of the Federal Rules of Civil Procedure."

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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