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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

SAN ANTONIO DIVISION

GRANDMA’S HOUSE CHILD CARE, LLC §

AMANDA TATUM, DOUGLAS COATS and §

STELLA SUE COATS §

§

Plaintiffs §

§ Civil Action no: 5:20-cv-240

vs. §

§

WESTERN WORLD INSURANCE GROUP, INC. §

§

Defendant. §

DEFENDANT’S NOTICE OF REMOVAL

TO THE HONORABLE UNITED STATES DISTRICT COURT:

Defendant Western World Insurance Company, incorrectly named herein as “Western 

World Insurance Group, Inc.,” files this Notice of Removal.

1. Plaintiff Grandma’s House Child Care, LLC is now and at the time suit was filed 

was a citizen of the State of Texas. (Appendix page 015, ¶3.)

2. Plaintiff Amanda Tatum is now and at the time suit was filed was a citizen of the 

State of Texas. (Appendix page 015, ¶4.)

3. Plaintiff Douglas Coats is now and at the time suit was filed was a citizen of the 

State of Texas. (Appendix page 016, ¶5.)

4. Plaintiff Stella Sue Coats is now and at the time suit was filed was a citizen of the 

State of Texas. (Appendix page 016, ¶6.)

5. Intervener Elizabeth Wong, as parent and next friend of M.J. a minor child, is now 

and at the time suit was filed was a citizen of the State of Texas. (Appendix page 006, ¶3.)

6. Defendant Western World Insurance Company is now a corporation incorporated 

in the State of New Hampshire and with its principal place of business in New Jersey, and at the 

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time suit was filed was a corporation incorporated in the State of New Hampshire and with its 

principal place of business in New Jersey. (Appendix page 024.) 

7. Because Plaintiff is now and was a citizen of Texas when suit was filed, and because 

Defendant Western World is now and was at the time suit was filed a citizen of New Hampshire 

and New Jersey, complete diversity of citizenship exists among the parties.

8. Defendant Western World files this Notice of Removal within 30 days of the date 

that the Defendant was notified of service of the suit. (See Appendix page 011.)

9. The amount in controversy exceeds $75,000.00, exclusive of interests and costs. 

(See Appendix page 015, ¶2.)

10. Because complete diversity of citizenship exists among the parties, and because the 

amount in controversy exceeds $75,000.00 exclusive of interests and costs, this action is 

removable under 28 U.S.C. §§ 1332 and 1441.

11. Venue is proper in the present Court pursuant to 28 U.S.C. 1441(a), because the 

U.S. District Court for the Western District of Texas, San Antonio Division, embraces the 

81st/218th District Court, Wilson County Texas, where the State Court Action was originally filed 

and where the alleged loss occurred.

12. True and correct copies of the state court filings to date are attached to this Notice. 

(See Appendix pages 001 - 023.)

CONCLUSION

By this Notice of Removal, Defendant does not waive any objections it may have as to 

service, jurisdiction or venue or any other defenses or objections it may have to this action, except 

as expressly herein admitted, and Western World expressly reserves all defenses, motions and 

pleas.

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Respectfully submitted,

By: s/Robert G. Hogue

Robert G. Hogue

State Bar No. 09811050

ROBERT G. HOGUE, P.C.

Highland Park Place

4514 Cole Avenue, Suite 600

Dallas, Texas 75205-4193

Phone: (214) 559-7107

Fax: (214) 559-7101

email: robhogue@msn.com

COUNSEL FOR DEFENDANT

WESTERN WORLD INSURANCE COMPANY

CERTIFICATE OF SERVICE

I hereby certify that on February 27, 2020, the foregoing document was served on counsel 

of record for the parties as follows:

Mr. Nohl Bryant Via e-service

Bryant Law, PC

111 Olmos Dr.

San Antonio, Texas 78212

nohl.bryant@bryantlawpc.com

COUNSEL FOR PLAINTIFFS

Jerry A. Gibson Via e-service

Stanley Bernstein

George LeGrand

LeGrand & Bernstein

2511 North St. Mary’s Street

San Antonio, Texas 78212

COUNSEL FOR INTERVENERS

By: s/Robert G. Hogue

Robert G. Hogue

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