{00286102.1} 1

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

SAN ANTONIO DIVISION

RARE & FINE WATCHES AG §

Plaintiff, §

§

V. § CIVIL ACTION NO. 5:20-CV-00249

§

ROBERT MARON, INDIVIDUALLY, §

and ROBERT MARON, INC., §

Defendant. §

NOTICE OF REMOVAL

Pursuant to 28 U.S.C. §§1332, 1441, and 1446, Defendants ROBERT MARON, 

INDIVIDUALLY and ROBERT MARON, INC, remove this action from the 73rd

Judicial District Court of Bexar County, Texas to the United States District Court

for the Western District of Texas, San Antonio Division.

I. NATURE OF THE ACTION

1. On January 27, 2020, Plaintiffs RARE & FINE WATCHES AG filed a 

lawsuit against Defendants in the 73RD Judicial District Court, Bexar County, Texas

(the “State Court Action”). Plaintiff’s claims are for breach of contract, promissory 

estoppel, conversion and fraud. 

II. BASIS FOR REMOVAL

2. The State Court Action is removable because there is complete diversity 

of citizenship between the parties and the alleged amount in controversy exceeds 

$75,000, exclusive of interest and costs. See 28 U.S.C. § 1332(a).

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3. Plaintiff is a Swiss corporation domiciled and doing business at 

Grundstrasse 12, CH-6343 Rotkreuz, Switzerland.

4. Defendant ROBERT MARON, INDIVIDUALLY is an individual who 

resides in and is a citizen of the State of California.

5. Defendant ROBERT MARON, INC. is a citizen of the State of California 

because it is a corporation organized and existing under the laws of California and 

its principal place of business is located in California at 2060 Avenida de Los Arboles, 

Suite D309, Thousand Oaks, California 91362. 

6. Consequently, there is complete diversity of citizenship among the

parties.

7. Plaintiff is seeking recovery of a watch that it claims has valued of at 

least $1,000,000. Based upon Plaintiff’s allegations, the amount in controversy 

exceeds the sum of $75,000, exclusive of interest and costs.

8. Defendants are filing this Notice timely within 30-day time period 

required by 28 U.S.C. § 1446(b)(1).

9. A copy of all process, pleadings, and orders served upon Defendants is 

filed with this Notice.

10. For these reasons, Defendants hereby remove this action from the 73rd

Judicial District Court of Bexar County, Texas to the United States District Court for 

the Western District of Texas, San Antonio Division. 

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HORNBERGER FULLER

 & GARZA INCORPORATED

The Quarry Heights Building

7373 Broadway, Suite 300

San Antonio, Texas 78209

Tel: (210) 271-1700, Fax: (210) 271-1740

By: /s/ David Jed Williams

David Jed Williams

State Bar No. 21518060

jwilliams@hfgtx.com

Stephanie L. Curette

State Bar No. 24076780

scurette@hfgtx.com

ATTORNEYS FOR DEFENDANTS

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on March 1, 2020, I electronically filed the foregoing 

document 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 by 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 Electronic Filing.

David Lopez

dlopez@ccn-law.com

Manuel Martinez Anzaldua

mmartinez@ccn-law.com

CACHEAUX, CAVAZOS & NEWTON, L.L.P.

Convent Plaza

333 Convent Street

San Antonio, Texas 78205

/s/ David Jed Williams

David Jed Williams

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