UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

KENNY SHANNON,

USDC Case No. 2:14-cv-14153

Plaintiff, Hon.

vs.

WCCC Case No. 14-013137-NI

Hon. Susan D. Borman 

STATE FARM INSURANCE COMPANY, 

Defendant.

TODD R. PERKINS (P55623)

THE PERKINS LAW GROUP, PLLC

Attorneys for Plaintiff

615 S Griswold, Suite 400

Detroit, Michigan 48226

(313) 964-1702

tperkins@perkinslawgroup.net 

SHELLY LEE GRIFFIN (P49488)

CARY R. BERLIN (P64122)

PATRICK, JOHNSON & MOTT, P.C.

Attorneys for Defendant

27777 Franklin Road, Suite 1400

Southfield, Michigan 48034

(248) 356-8590

sgriffin@pjmpc.com

STATE FARM’S NOTICE OF REMOVAL

The Defendant, State Farm Insurance Company(“State Farm”), through its attorneys, Patrick,

Johnson & Mott, P.C., removes the above action from the Wayne CountyCircuit Court to this Court,

pursuant to 28 U.S.C. § 1446, based upon the following grounds:

1. The above action was filed in the Circuit Court for the County of Wayne, State of

Michigan [Docket No. 14-013137-NI] and is now pending in that court. Process, including a

summons and complaint, which was served upon State Farm on October 16, 2014, and copies of all

process and pleadings served upon State Farm are attached as Exhibit “A .” 

2. State Farm is now, and was at the time of the commencement of this action, a

corporation organized and existing under the laws of the State of Illinois, having its principal place

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of business located in the City of Bloomington, State of Illinois. State Farm is, therefore, a resident

of the State of Illinois and is not a citizen or corporation of the State of Michigan.

3. At all times material hereto, the individual improperly identified as the “Plaintiff,”

Kenny Shannon was a citizen of the State of the Michigan as evidenced by Paragraph 4 of his

Complaint (Exhibit “A”).

4. State Farm issued an insurance policy numbered 82-B4-T865-7 to Global Shannon

Enterprises, LLC.

5. It is the citizenship of the members of a limited liability company, which determines

the citizenship of the limited liability company for purposes of federal court diversity jurisdiction.

CMPS Inst., LLC v. MMG II, LLC, 521 F.Supp.2d 616, 617-18 (E.D. Mich, 2007).

6. Based upon information and belief, Kenny Shannon, is the sole member of Global

Shannon Enterprise, LLC.

7. Based upon information and belief, Global Shannon Enterprise, LLC is a real estate

business, incorporated in the State of Michigan.

8. All communications between State Farm and Shannon Global Enterprises have been

through Kenny Shannon, who resides in Wayne County, Michigan.

9. A controversy exists between State Farm and Global Shannon Enterprises, LLC, and

the amount of controversy in this action is no less than the sum of $113,000.00, exclusive of interest

and costs, as evidenced by the Plaintiff’s Sworn Statement in Proof of Loss (attached as Exhibit B).

10. This Court has original jurisdiction over this action pursuant to 28 U.S.C. § 1332, due

to the amount in controversy and the diversity of citizenship of the parties.

11. State Farm is, therefore, entitled to remove the above action from the Wayne County

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Circuit Court to this Court pursuant to 28 U.S.C. § 1446(a).

Respectfully submitted, 

PATRICK, JOHNSON & MOTT, P.C. 

/s/ Shelly Lee Griffin

Attorneys for Defendant

27777 Franklin Road, Suite 1400

Southfield, Michigan 48034

(248) 356-8590

sgriffin@pjmpc.com

P49488

Date: October 28, 2014

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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

KENNY SHANNON,

USDC Case No. 2:14-cv-14153

Plaintiff, Hon..

vs.

WCCC Case No. 14-013137-NI

Hon. Susan D. Borman

 

STATE FARM INSURANCE COMPANY, 

Defendant.

TODD R. PERKINS (P55623)

THE PERKINS LAW GROUP, PLLC

Attorneys for Plaintiff

615 S Griswold, Suite 400

Detroit, Michigan 48226

(313) 964-1702

tperkins@perkinslawgroup.net 

SHELLY LEE GRIFFIN (P49488)

CARY R. BERLIN (P64122)

PATRICK, JOHNSON & MOTT, P.C.

Attorneys for Defendant

27777 Franklin Road, Suite 1400

Southfield, Michigan 48034

(248) 356-8590

sgriffin@pjmpc.com

PROOF OF SERVICE

The undersigned certifies that on October 28, 2014, my legal assistant Laura Martinico

served copies of State Farm’s Notice of Removal and Proof of Service upon:

Todd R. Perkins, Esq

The Perkins Law Group, PLLC

Attorneys for Plaintiff

615 S Griswold, Suite 400

Detroit, Michigan 48226

(first class mail)

Clerk of the Court

Wayne County Circuit Court

Two Woodward Avenue

Detroit, Michigan 48226

(via e-filing)

I declare under penalty of perjury that the above statement is true to the best of my knowledge,

information and belief.

/s/Shelly Lee Griffin

Attorneys for Defendant

27777 Franklin Road, Suite 1400

Southfield, Michigan 48034

(248) 356-8590

sgriffin@pjmpc.com 

P49488

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