O4024995.v1

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA

FREEDOMROADS, LLC, )

a limited liability company, )

)

Plaintiff, ) Case No. 9:22-cv-81305-DMM 

)

v. )

)

MIDWEST ADVENTURE )

BUILDS LLC, a limited liability )

company, and WALTER HOLEM, )

an individual, )

)

Defendants. )

_______________________________/

NOTICE OF SUPPLEMENTARY JURISDICTIONAL FACTS

Plaintiff, FreedomRoads, LLC, by and through its undersigned counsel, pursuant 

to this Court’s January 17, 2023 Paperless Order (“Order”), hereby gives notice of 

supplementary jurisdictional facts that demonstrates federal subject matter jurisdiction

based on diversity, and in support states as follows:

1. On August 23, 2022, Plaintiff filed its Complaint against Defendants 

Midwest Adventure Builds LLC (“Midwest”) and Walter Holem (“Holem”) for breach 

of contract and unjust enrichment, among other claims. [DE 1].

2. Plaintiff alleges in the Complaint that it is a limited liability company 

organized under the laws of the State of Minnesota, with its principal place of business 

located at 250 Parkway Drive, Suite 270, Lincolnshire, Illinois 60069. [DE 1, Compl. ¶ 

Case 9:22-cv-81305-DMM Document 14 Entered on FLSD Docket 01/19/2023 Page 1 of 4
2

O4024995.v1

1]. Plaintiff does hereby further expressly allege that it is a citizen of the State of 

Minnesota.

3. Plaintiff further alleges in the Complaint that Midwest is a limited liability 

company organized under the laws of the State of Florida, with its principal place of 

business located at 313 Datura Street, Suite 200, West Palm Beach, Florida 33401 and 

that Holem, who is Midwest’s manager and registered agent, may be served at the same 

address. [DE 1, Compl. ¶¶ 2-3].

4. Pursuant to this Court’s Order and controlling law, Plaintiff must plead 

the citizenships of all the members of FreedomRoads, LLC and Midwest Adventure 

Builds LLC. [DE 13]; See Rolling Greens MHP, L.P. v. Comcast SCH Holdings L.L.C., 374 

F.3d 1020, 1022 (11th Cir. 2004) (stating “[t]o sufficiently allege the citizenships of these 

unincorporated business entities, a party must list the citizenships of all the members of 

the limited liability company[.]”).

5. According to the Order, Plaintiff must also plead the citizenship of 

Defendant Holem. [DE 13].

6. Plaintiff’s sole member is FreedomRoads Intermediate Holdco, LLC, 

which is organized under the laws of the State of Minnesota and is otherwise a citizen of 

the State of Minnesota, with its principal place of business located at 250 Parkway 

Drive, Suite 270, Lincolnshire, Illinois 60069.

Case 9:22-cv-81305-DMM Document 14 Entered on FLSD Docket 01/19/2023 Page 2 of 4
3

O4024995.v1

7. Holem is the sole member of Midwest and is a citizen of the State of 

Florida and resides at 885 Malcom Chandler Lane, Apartment 404, West Palm Beach, 

Florida 33401, where he was personally served with process in this action.

WHEREFORE, this action should proceed in the United States District Court for 

the Southern District of Florida as an action properly before it based on diversity of 

citizenship. 

Respectfully submitted,

DEAN, MEAD, EGERTON, 

BLOODWORTH, CAPOUANO & 

BOZARTH, P.A.

Attorneys for Plaintiff

By: /s/ A. Felipe Guerrero

SEND MAIL TO: A. Felipe Guerrero, for the firm

Dean, Mead, Egerton, Bloodworth, Florida Bar No. 022589

Capouano & Bozarth, P.A. Telephone 407-841-1200

Attn: A. Felipe Guerrero Facsimile 407-423-1831

Post Office Box 2346 fguerrero@deanmead.com

Orlando, FL 32802-2346 smarshall@deanmead.com

Case 9:22-cv-81305-DMM Document 14 Entered on FLSD Docket 01/19/2023 Page 3 of 4
4

O4024995.v1

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on January 19, 2023, I electronically filed the 

foregoing with the Clerk of the Court by using the CM/ECF system, which will send 

notice of electronic filing to all CM/ECF participants.

s/ A. Felipe Guerrero

A. FELIPE GUERRERO

Case 9:22-cv-81305-DMM Document 14 Entered on FLSD Docket 01/19/2023 Page 4 of 4