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IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

CASE NO. 

JAWAD SEBRING, LLC

Plaintiff,

v.

WESTCHESTER SURPLUS LINES

INSURANCE COMPANY,

Defendant.

/

NOTICE OF REMOVAL

Defendant, Westchester Surplus LinesInsurance Company (“Westchester”), by and through 

undersigned counsel, hereby files this Notice of Removal, and states as follows:

1. On September 23, 2022, Plaintiff, Jawad Sebring, LLC, (“Jawad Sebring”) filed a 

lawsuit in the Circuit Court of the Tenth Judicial Circuit in and for Highlands County, Florida (Case 

No. GC-2022-00445) against Westchester in which Plaintiff seeks coverage under policy number 

FSF16162784 001 based on property damage allegedly sustained at the premises located at 2812 US 

27 N., Sebring, FL 33870 (“the Property”). The Summons and Complaint were served on the Chief 

Financial Officer of the State of Florida, which then forwarded these documents to Westchester on 

November 3, 2022. 

2. The Civil Cover Sheet for this Court is attached hereto as Exhibit A – Federal Civil 

Cover Sheet.

3. Copies of the State Court Proceedings are attached hereto as follows: Exhibit B –

State Court Civil Action Summons; Exhibit C – State Court Complaint; Exhibit D – State 

Court Notice Designating E-mail Address for Service of Court; Exhibit E – State Court 

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Plaintiff’s Notice of Service of First Interrogatories to Defendant; Exhibit F – State Court 

Plaintiff’s Notice of Taking Videotaped Deposition Duces Tecum; Exhibit G – State Court 

Plaintiff’s Notice of Taking Deposition Duces Tecum of Defendant’s Designated Corporate 

Representative; Exhibit H – State Court Plaintiff’s Request for Production to Defendant; 

Exhibit I – Defendant’s Motion for Extension of Time to Respond to Plaintiff’s Complaint.

These constitute all of the process, pleadings, and orders served upon Westchester or upon the 

Plaintiff to date. 

4. As grounds for removal, Westchester asserts that the above-styled case is one over 

which this Court has original jurisdiction pursuant to 28 U.S.C. §1332, and that this action is one 

which may be removed to this Court pursuant to 28 U.S.C. §1441 in that the matter in controversy 

exceeds the sum of $75,000, exclusive of interest and costs, and is between citizens of different 

states.

5. Plaintiff, Jawad Sebring, LLC is a Florida limited liability company whose members 

are all citizens of Florida. Plaintiff is therefore domiciled in and is a citizen of Florida for purposes 

of diversity jurisdiction. 

6. Upon information, investigation, and belief, and to the best of the undersigned’s 

knowledge, Plaintiff, Jawad Sebring, LLC is a single-member LLC. Ali H. Jawad is the only known 

member of Jawad Sebring and is a citizen of Florida. Ali H. Jawad is a citizen of Florida because he 

is domiciled in the State of Florida. See Travaglio v. Am. Express Co., 735 F. 3d 1266, 1268-1269 

(holding that citizenship means domicile for diversity purposes and domicile requires both residence 

in a state and an intention to remain there indefinitely). Ali H. Jawad is domiciled at 7630 Blue Quail 

Lane, Orlando, FL 32835, the same address as Jawad Sebring, LLC. Additionally, to that end, per 

the public records, Ali H. Jawad has claimed the homestead exemption at the property located at 

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7630 Blue Quail Lane, Orlando, FL 32835, for the year 2022, and therefore “in good faith ma[de] 

the property [his] permanent residence. See, Fla. Stat. § 196.031(1)(a); see also Articles of 

Incorporation of Jawad Sebring, LLC and Orange County Property Appraiser Records attached 

hereto as Composite Exhibit “J.” Accordingly, Plaintiff, Jawad Sebring, LLC, is a limited liability 

company whose members are all domiciled in and are all citizens of the State of Florida for purposes 

of diversity jurisdiction. 

7. Furthermore, Westchester Surplus Lines Insurance Company, is a Georgia 

corporation engaged in the insurance business with its principal place of business in Georgia. 

Accordingly, this action is between citizens of different states pursuant to 28 U.S.C. §1332(a).

8. Plaintiff bases its claim for insurance coverage in Plaintiff’s Complaint which states 

the amount of damages is over $100,000.00. (A copy of the State Court Complaint is attached hereto 

as Exhibit C.) Thus, an actual cause or controversy has arisen between Plaintiff and Westchester, 

and the amount of controversy exceeds $75,000, exclusive of interest and costs, thus satisfying the 

amount in controversy requirement pursuant to 28 U.S.C. § 1332(a).

9. Westchester is contemporaneously serving written notice of the filing of this Notice 

of Removal to the plaintiff and to the Clerk of the Circuit Court of the Tenth Judicial Circuit in and 

for Highlands County, Florida, pursuant to 28 U.S.C. §1446(d).

WHEREFORE, Westchester Surplus Lines Insurance Company files this Notice of 

Removal pursuant to 28 U.S.C. §1446.

Respectfully submitted,

LEWIS BRISBOIS BISGAARD & SMITH LLP

110 SE 6th Street, Suite 2600

Fort Lauderdale, FL 33301

Telephone: 954.728.1280

Facsimile: 954.728.1282

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By: /s/ Laura F. Farrant 

BRADLEY S. FISCHER, ESQ.

Florida Bar No. 716553 

bradley.fischer@lewisbrisbois.com 

LAURA F. FARRANT, ESQ.

Florida Bar No. 85872

laura.farrant@lewisbrisbois.com

VERONICA N. DANIEL, ESQ.

Florida Bar No. 127309

veronica.daniel@lewisbrisbois.com

Counsel for Defendant,

Westchester Surplus Lines Insurance Company

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on December 5, 2022, the foregoing document was electronically 

filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being 

served this day on all counsel of record or pro se parties identified on the attached service list in the 

manner specified, either via transmission of notices of electronic filing generated by CM/ECF or in 

some other authorized manner for those counsel or parties who are not authorized to receive 

electronically notices of filing.

/s/ Laura F. Farrant 

LAURA F. FARRANT, ESQ.

Florida Bar No. 85872

SERVICE LIST

Jesus David Moises, Esq.

Florida Bar No. 104457

Daniel R. Gross, Esq.

Florida Bar No. 91124

Moises Gross, PLLC.

999 Ponce de Leon Blvd., Suite 945

Coral Gables, FL 33134

E-mail: Service@moisesgross.com

rnieto@moisesgross.com

Tel: (305) 306-3055

Counsel for Plaintiff

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