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UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF TEXAS

DEL RIO DIVISION

OLGA MORENO

Plaintiff

§

§

§

v. §

§

CIVIL ACTION NO. 2:20-CV-00017

ALLSTATE TEXAS LLOYD’S AND 

VERNON MARSHALL

Defendants

§

§

§

DEFENDANTS’ NOTICE OF REMOVAL

Defendants, Allstate Texas Lloyd’s (“Allstate”) and Vernon Marshall, hereby remove this 

lawsuit pursuant to 28 U.S.C. §§ 1332 and 1441, on the grounds of diversity of citizenship and 

amount in controversy, and respectfully show the Court as follows:

I.

BACKGROUND 

1. On January 22, 2020, Plaintiff filed her Original Petition in the 293rd Judicial District 

Court of Maverick County, Texas, Cause No. 20-01-38398-MCV, styled Olga Moreno, Plaintiff 

vs. Allstate Texas Lloyd’s and Vernon Marshall. See Exhibit A (Plaintiff’s Original Petition). 

2. Plaintiff Olga Moreno’s (“Plaintiff”) lawsuit against Allstate arises from property damage 

to Plaintiff’s home allegedly caused by a wind and/or hailstorm occurring on June 19, 2019. Id at 

¶ 10. Therein, Plaintiff asserts causes of action against Allstate for breach of contract, breach of 

the common law duty of good faith and fair dealing, and violations of the Texas Insurance Code. 

See Id. generally.

3. Plaintiff served Allstate with Plaintiff’s Original Petition and process on February 4, 

2020 by certified mail upon on its registered agent. See Exhibit B (Certificate of Service). 

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4. Prior to filing and serving suit in this matter, Plaintiff served Allstate with the statutorily 

required pre-suit notice (the “Notice”). See Exhibit C (Plaintiff’s 542A.003 Notice). 

Importantly, Plaintiff’s Notice does not mention named defendant adjuster and agent for Allstate, 

Vernon Marshall (“Marshall”) at all. See Id.

5. Plaintiff failed to provide the statutorily required pre-suit notice to Marshall and as such, 

he was improperly joined to this lawsuit at the time of removal and remains improperly joined. 

See Exhibit D (Affidavit of Vernon Marshall).

6. Allstate elected to accept any and all liability for the actions of Vernon Marshall in 

relation to this lawsuit on February 18, 2020 pursuant to Texas Insurance Code § 542A.006. See

Exhibit E (Allstate’s Election of Adjuster Liability). Because Allstate has accepted liability for 

Marshall, Marshall may not be joined to the lawsuit in the future.

7. Importantly, and as is stated above and discussed below, Allstate has elected to accept 

any and all liability of Marshall in relation to this matter pursuant to Texas Insurance Code §

542A.006. Due to Allstate’s election to accept the liability of Marshall, and the fact that 

Marshall was never properly joined as, and can never be properly joined as, a party to this 

lawsuit, his consent to removal of this matter is not required.

8. The State Court’s Record Search including Case History for this matter is attached

hereto. See Exhibit F (State Court’s Record Search). 

II.

GROUNDS FOR REMOVAL

9. This Court has original jurisdiction of this suit under 28 U.S.C. § 1332(a) because this 

suit involves a controversy between citizens of different states and there was complete diversity 

between the parties at the time of the filing of the suit and at the time of the removal. Further, 

the amount in controversy, exclusive of interest and costs exceeds $75,000.00. 

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A. Parties are Diverse

i. Plaintiff’s Citizenship 

10. Plaintiff, Olga Moreno, is a natural person who resides in Maverick County, Texas. See

Exhibit A, ¶ 3. Plaintiff has not pled any other facts of her residency, intention to leave Texas, or 

domiciles in other States. Id. Accordingly, Defendant asserts that absent the same, Plaintiff’s 

citizenship at the time of filing of the suit and at the time of removal is properly established as 

the State of Texas. See Hollinger v. Home State Mut. Ins. Co., 654 F.3d 564, 571 (5th Cir. 2011). 

ii. Allstate’s Citizenship

11. Citizenship of an unincorporated association is determined by the citizenship of its 

members. See U.S.C. § 1332(a). For the purposes of determining citizenship of a Lloyds 

organization, the court looks to the citizenship of the Lloyd members. See Massey v. State Farm 

Lloyds Inc. Co., 993 F. Supp. 568, 570 (S.D. Tex., Galveston Div. 1998). 

12. Defendant, Allstate Texas Lloyd’s is an association of individual underwriters, authorized 

to conduct business in the State of Texas as a “Lloyd’s plan” insurer under the Texas Insurance 

Code. The underwriters are residents and citizens of the State of Illinois. Accordingly, Allstate 

Texas Lloyd’s is a citizen of the State of Illinois. 

iii. Vernon Marshall’s Citizenship

13. Marshall is a resident of Katy, Texas licensed by the Texas Department of Insurance to 

adjust insurance claims in the State of Texas. Suther is thus a citizen of the State of Texas. 

However, as discussed in detail below, Marshall is improperly joined to this lawsuit and thus his 

citizenship should be disregarded for the purposes of determining this Court’s subject matter 

jurisdiction. See Smallwood v. Illinois Cent. R.R. Co., 385 F.3d 568, 572 (5th Cir. 2003).

B. Marshall was Improperly Joined at time of the Filing of the Complaint

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(i) Legal Standard

14. The doctrine of improper joinder, or fraudulent joinder, ensures that the presence of an 

improperly joined, non-diverse defendant does not defeat federal removal jurisdiction premised 

on diversity. Borden v. Allstate Ins. Co., 589 F.3d 168, 171 (5th Cir. 2009). Citizenship of an 

improperly joined party is totally disregarded in determining the Court’s subject matter 

jurisdiction. Smallwood v. Illinois Cent. R.R. Co., 385 F.3d 568, 572 (5th Cir. 2003). 

15. The removing party bears the burden of establishing whether federal jurisdiction exists 

and removal is proper. Manguno v. Prudential Prop. & Cas. Ins. Co., 276 F.3d 720, 723 (5th Cir. 

2002). To meet this burden, the removing party must demonstrate that there is no reasonable 

basis for the district court to predict that the plaintiff might be able to recover against an in-state 

defendant.” McDonald v. Abbot Labs., 408 F.3d 177, 183 (5th Cir. 2005). 

16. To determine that an in-state defendant has been improperly joined, the court must find 

that (1) the plaintiff has fraudulently alleged that a defendant is non-diverse, or (2) the plaintiff 

has failed to state a claim against the non-diverse defendant. Smallwood, 385 F.3d at 573. In 

making this determination, a federal court must look to the original state court pleading but apply 

the federal pleading standard. Int’l Energy Ventures Mgmt., LLC v. United Energy Grp., Ltd., 

818 F.3d 193, 205 (5th Cir. 2016). “[R]emoval jurisdiction should be determined on the basis of 

the state court complaint at the time of removal” and a “plaintiff cannot defeat removal by 

amending it.” Cavallini v. State Farm Mut. Auto Ins. Co., 44 F.3d 256, 265 (5th Cir. 1995).

17. The court may resolve claims of improper joinder by conducting a Rule 12(b)(6)-type 

analysis. Smallwood, 385 F.3d at 573. The analysis requires the complaint to contain “enough 

facts to state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 

U.S. 544, 547, 127 S. Ct. 1955 (2007). “A claim has facial plausibility when the plaintiffs plead 

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factual content that allows the court to draw the reasonable inference that the defendant is liable 

for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 129 S. Ct. 1973 (2009). 

18. Pursuant to Twombly and Iqbal, the court conducts a two-prong analysis. First, the court 

separates legal conclusions from well-pled facts. Iqbal, 556 U.S. at 678-79. Second, the court 

reviews the well-pled facts, assumes they are true, and determines whether they “plausibly give 

rise to an entitlement of relief.” Id., at 679. A pleading “that offers labels and conclusions or a 

formulaic recitation of the elements of a cause of action will not do.” Iqbal, 556 U.S. at 678. 

“Nor does a complaint suffice if it tenders naked assertion[s] devoid of further factual 

enhancement.” Id. Plausibility requires more than a mere possibility. It calls for enough facts to 

raise a reasonable expectation that discovery will reveal evidence of actionable misconduct. 

Twombly, 550 U.S. at 565. 

19. In order to assert an actionable claim against an adjuster, Texas federal courts require the 

plaintiff “to allege specific actionable conduct by the adjuster and to distinguish claims against 

the adjuster from generic, conclusory, statute-tracking claims against the insurer.” Okenkpu v. 

Allstate Texas Lloyds, No. H-11-2376, 2010 WL 103678 at *7 (S.D. Tex. March 27, 2012) 

(citing string of Southern District cases).

(ii) Marshall was Not Properly Joined at the Time of Removal because Marshall never 

received the statutorily required Texas Insurance Code § 542A.003 Notice.

20. Plaintiff failed to provide Marshall with the statutory pre-suit notice required by Texas 

Insurance Code § 542A.003 and thus, at the time of removal, Marshall was not a proper party to 

the lawsuit.

21. Texas Insurance Code §542A “. . . applies to an action on a claim against an insurer or 

agent . . .” that “arises from damage to or loss of covered property caused wholly or partly, by 

forces of nature, including . . . hail, wind, . . . or a rainstorm.” Texas Insurance Code §§ 

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542A.002(b) and 542A.001(2)(C). An “agent” is defined as “. . . an employee, agent, 

representative, or adjuster who performs any act on behalf of an insurer.” Texas Insurance Code 

§ 542A.001(1).

22. Texas Insurance Code § 542A.003 explicitly requires that “not later than the 61st day 

before the date a claimant files an action to which this chapter applies in which the claimant 

seeks damages from any person1, the claimant must give written notice to the person in 

accordance with the this section as a prerequisite to filing the action.” In short, a Plaintiff is 

statutorily required to provide at least 61 days’ notice to any and all named defendants that are 

insurers, or agents thereof, prior to filing a suit to recover for property damages caused by a wind 

or hailstorm.

23. Plaintiff has filed this suit against Allstate and Marshall individually to recover for 

alleged “covered losses in the form of wind and/or hail damage and the damages resulting 

therefrom.” Exhibit A at ¶ 10. Plaintiff further alleges that “Vernon Marshall . . . on behalf of 

Allstate, was assigned as an individual adjuster on [Plaintiff’s] claim . . .” Id. at ¶ 13. Thus 

Plaintiff alleges, and Allstate admits, that Marshall was an agent and adjuster acting on Allstate’s 

behalf. Further, as is defined by Texas Insurance Code § 542.001A(5), Marshall is a “Person.”

24. In light of the foregoing, Plaintiff was required by statute to provide Marshall with at 

least 61 days’ notice prior to filing suit against him. Plaintiff never provided Marshall with such 

notice thus Marshall has been improperly included in this suit and is an improper party to it. See

Exhibit D. 

25. Additionally, Allstate has now accepted liability on behalf of Marshall, thus even if 

Plaintiff were now to provide the statutorily required notice to Marshall, he could not be as a 

 1 Texas Insurance Code § 542A.001(5) defines person as “a corporation, association, partnership, or other legal 

entity or individual.”

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party because, pursuant to § 542A.006(b), “if an insurer makes an election [to accept the liability 

of an agent or adjuster] before a claimant files an action to which this chapter applies, no cause 

of action exists against the agent related to the claimant’s claim . . .” Because Plaintiff filed suit 

without providing the statutorily required notice to Marshall, the lawsuit against Marshall was 

never ripe and now that Allstate has accepted liability on Marshall’s behalf, no cause of action 

can ever exist against Marshall. Hence, removal is proper because, “there is no reasonable basis 

for the district court to predict that the plaintiff might be able to recover against [the] in-state 

defendant.” Abbot Labs., 408 F.3d 177 at 183.

26. Because Plaintiff failed to provide Marshall with the statutorily required notice, and 

because Allstate has accepted liability on Marshall’s behalf, Marshall was improperly joined at 

the time of removal and now may never be properly joined to this matter.

(iii) Plaintiff Failed to State a Plausible Claim Against Marshall in the Petition

27. Even if Plaintiff had given Marshall proper notice prior to filing suit, Marshall was still 

improperly joined to this lawsuit at the time of removal because Plaintiff has not stated a 

plausible claim against Marshall in her Petition.

28. Plaintiff in this matter has claimed that Marshall is individually liable to Plaintiff under 

§§ 541 and 542 of the Texas Insurance Code because Marshall:

 Misrepresented, with actual awareness, the scope of covered damages as well as the cost 

to repair those damages;

 Performed an incomplete visual inspection of Plaintiff’s property;

 Undervalued the covered damages to Plaintiff’s property; and

 Failed to allow adequate funds to repair the covered damages to Plaintiff’s property.

Exhibit A at ¶¶ 43-45.

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29. Plaintiffs’ Original Petition does not offer any facts, other than mere conclusory 

allegations, to support Plaintiff’s claims against Marshall. Rather, Plaintiff’s Original Petition 

relies on the assertions that, 

 “Vernon Marshall (“MARSHALL”) on behalf of ALLSTATE, was assigned as an 

individual adjuster on the claim, conducted a substandard investigation and inspection of 

the property, and prepared a report that failed to include all of the damages that he noted 

during the inspection, and undervalued the damages he observed during his inspection”;

 “ALLSTATE and MARSHALL performed an outcome-oriented investigation of 

Plaintiff’s claim, which resulted in a biased, unfair and inequitable evaluation of 

Plaintiff’s losses on the property”; and that

 “ . . . VERNON MARSHALL committed various acts and omission violative of the 

Texas Insurance Code to include performing an incomplete visual inspection of the 

property, and failing to inspect all affected areas; said named adjuster undervalued 

damages and failed to allow for adequate funds to cover the costs of repairs, and set out 

to deny properly covered damages . . . The above-named adjuster in this suit conducted 

an outcome-oriented investigation designed to minimize the Plaintiff’s claim, and failed 

to promptly provide the Plaintiff with a reasonable explanation of the basis of the policy 

in relation to the facts or applicable law, for the claim decision.

Id. at ¶¶ 13, 16, and 45.

30. What is noticeably lacking from Plaintiff’s Original Petition is a single non-conclusory 

fact regarding the alleged acts and omissions of Marshall. Nowhere does Plaintiff state in her 

Original Petition:

 When Marshall made any alleged misrepresentations to the Plaintiff or what the 

substance of those alleged misrepresentations were in accordance with Federal Rule of 

Civil Procedure 9(b);

 What portions of Plaintiff’s property Marshall ostensibly failed to inspect;

 What alleged covered damages to Plaintiff’s property Marshall undervalued; or even

 The actual value of alleged covered damages Plaintiff believes she is entitled to recover 

in regards to her claim with Allstate.

31. Here, applying the Twombly and Iqbal analysis, Plaintiff’s Original Petition fails to state 

a plausible claim against Marshall under the federal pleading standard. Specifically, as shown 

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below, Plaintiff’s claims consist of conclusory and speculative allegations couched as “facts” and 

consist of allegations which sound in fraud that do not meet the pleading standard of Rule 9(b).

a. Speculative Allegations and Legal Conclusions Couched as Fact

32. As is demonstrated above, Plaintiff asserts general, speculative and conclusory 

allegations against Marshall and couches them as facts. For example, and as cited above, 

Plaintiff alleges that Marshall did not account for all of the damages to Plaintiff’s property. The 

additional allegations cited above are also just merely allegations couched as facts—mere

conclusory statements that give, at best, only the most general of information regarding the 

alleged damages to the property. These allegations are entirely without context and fail to even 

refer to any provisions of the insurance policy at issue which might give credence to Plaintiff’s

belief that covered losses were intentionally overlooked by Marshall.

33. However, true factual allegations “must be enough to raise a light to relief above the 

speculative level.” Papasan v. Allian, 478 U.S. 265, 286 (1986). Further, courts are not bound to 

accept as true a legal conclusion couched as a factual allegation. See Twombly, 550 U.S. at 155. 

34. Here, the allegations asserted above demonstrate at best a bona fide dispute regarding the 

disparity between Marshall’s evaluation of the coverage of the claim and the damages that 

Plaintiff believes should be covered. The allegations do not show how such a bona fide dispute 

raises to a level above and beyond a breach of contract cause of action—which would not be 

actionable against Marshall individually. 

35. The allegations in this matter have no more details than those considered in Gardezi v. 

Nationwide Property and Casualty Ins. Co., No. 4:15-CV-01663, *1 (S.D. Tex. Jan. 7, 2016). 

Therein, plaintiffs alleged as against the adjuster, that “[the adjuster] made numerous errors in 

estimating the value of the Plaintiffs’ claim, all of which were designed to intentionally minimize 

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and underpay the loss incurred by Plaintiffs ... As a result of [the adjuster’s] conduct, Plaintiffs’ 

claim was underpaid.” Id. at *2. The plaintiffs also referred to such allegations in asserting 

violations of the Texas Insurance Code. Id. The Gardezi court concluded that the plaintiffs 

failed to state a cause of action against the individual adjuster. Id. at *6. 

36. In another case, Hart v. Nationwide Property & Cas. Ins. Co., the plaintiff alleged that 

the insurer committed statutory violations by misrepresenting that damages were not covered, 

stating that the damages were less severe than they were, and in denying or underpaying the 

claim. 2011 WL 2210034, *4 (S.D. Tex. 2011) (Harmon, J.) (not designated for publication). In 

dismissing the plaintiff’s extra-contractual claims, the Court in Hart, noted that the “averments 

about [the insurer’s] ‘misrepresentations’ for purposes of her claims of fraud or claims of 

violations of the Texas Insurance Code are vague and conclusory....” Id., at *5. The Court 

further explained:

Not only are the complaints averments vague and general, but Plaintiff also fails 

to identify a single specific representation by Nationwide or its representatives, no 

less an actionable one, she does not specify the speaker or the person who 

performed allegedly deceptive conduct... explain how Plaintiff relied on such... 

Id. 

37. In light of the above, it is clear that Plaintiff’s allegations do not form the basis for an 

independent cause of action against the Dismissed Adjusters.

b. Plaintiff’s Fraud Claims Fail to Satisfy Rule 9(b) 

38. Allegations that sound in fraud are subject to the heightened pleading standard of Federal 

Rule of Civil Procedure 9(b). See Halprin v. FDIC, 2016 U.S. Dist. LEXIS 135402, *15 (W.D. 

Tex. 2016). The courts have held that provisions of Texas Insurance Code § 541.060(a) sound in 

fraud and should be subjected to the heightened pleading standard set forth by Federal Rule of 

Civil Procedure 9(b) where such allegations under the Texas Insurance Code involve 

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misrepresentations, are substantively claims of fraud, and the gravamen of the claim is fraud. 

Waste Mgmt. v. AIG Specialty Ins. Co., 2017 U.S. Dist. LEXIS 126880, fn.7 (S.D. Tex. 2017). 

39. All of the Plaintiff’s claims against the Marshall are based on violations of Texas 

Insurance Code § 541.060(a) or, arguably, § 541.061, and thus sound in fraud. See Exhibit A at 

¶¶ 13, 16, and 43-45. However, Plaintiff’s allegations described above fall far short of the 

heightened pleading requirements of Rule 9(b). See FED. R. CIV. P. 9(b) (“In alleging fraud or 

mistake, a party must state with particularity the circumstances constituting fraud or mistake.”); 

See Dorsey v. Portfolio Equities, Inc., 540 F.3 333, 339 (5th Cir. 2008) (to satisfy Rule 9(b), a 

plaintiff pleading fraud must “specify the statements contended to be fraudulent, identify the 

speaker, state when and where the statements were made, and explain why the statements were 

fraudulent.”). 

40. Here, Plaintiff fails to adequately support the alleged fraudulent acts of Marshall with 

enough facts to meet the pleading standards of Federal Rule of Civil Procedure 9(b). Rather, 

Plaintiff merely bases her claims sounding in fraud on vague statements; the entirely 

unsupported allegation that Marshall undervalued her claim; and entirely unsupported allegations 

that Marshall set out to undervalue, delay, and underpay Plaintiff’s claims. See Generally,

Exhibit A. Plaintiff’s allegations against Marshall – at most – demonstrate a disagreement about 

the scope of the claim and the findings of the investigation into said claim—they do not rise to 

the level of fraud. 

C. Amount in Controversy

41. The party seeking federal jurisdiction must prove by a preponderance of the evidence that 

the amount in controversy exceeds $75,000.00. Grant v. Chevron Phillips Chem. Co. L.P., 309 

F.3d 864, 868 (5th Cir. 2002). The removing party may satisfy its burden by either (1) 

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demonstrating that it is “facially apparent” from the petition that the claim likely exceeds 

$75,000.00, or (2) “by setting forth the facts in controversy – preferably in the removal petition, 

but sometimes by affidavit – that support a finding of the requisite amount.” Allen v. R & H Oil 

& Gas Co., 63 F.3d 1326, 1335 (5th Cir. 1995). 

42. If a defendant can produce evidence that establishes the actual amount in controversy 

exceeds the jurisdictional threshold, a plaintiff must be able to show that, to a legal certainty, he 

will not be able to recover more than the damages for which he has prayed in the state court 

complaint. See De Aguilar v. Boeing Co., 47 F.3d 1404, 1409 (5th Cir. 1995). 

a. It is facially apparent for the petition that the claim likely exceeds 

$75,000.00

43. Here, pursuant to Rule 47 of the Texas Rules of Civil Procedure, Plaintiff’s pleading 

makes the claim that “Plaintiff is seeking monetary relief over $100,000 but not more than 

$200,000.” Exhibit A ¶ 2. Plaintiff has affirmatively pled for recovery in an amount that 

exceeds $75,000.00 and thus it is facially apparent from the Original Petition that this matter 

exceeds the amount in controversy requirement set forth in 28 U.S.C. § 1332. 

III. 

REMOVAL IS PROCEDURALLY PROPER

44. This notice of removal is timely filed within thirty (30) after service of process upon 

Defendant. See 28 U.S.C. §1441(b)(1). 

45. Venue is proper in this Court under 28 U.S.C. §1441(a) since the District and Division of 

this Court includes Maverick County, Texas, the county where the State Court suit was filed. 

46. Pursuant to 28 U.S.C. §1446(a), all pleadings, process, orders, and all other filings in the 

state court action are attached herein. 

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47. Pursuant to 28 U.S.C. §1446(d), Defendant will promptly provide a true and correct copy 

of this Notice of Removal to Plaintiff and to the Clerk of Maverick County District Court. 

V.

CONCLUSION 

WHEREFORE, Defendant Allstate Texas Lloyd’s requests that the Court accept 

jurisdiction over this action for the reasons set forth above and grant Defendant any such other 

and further relief to which Allstate may show itself justly entitled. 

Respectfully submitted,

By: /s/ Michael M. Novak

Robert E. Valdez

State Bar No.20428100

S.D. Tex. Bar No. 9816

revaldez@valdeztrevino.com

Michael M. Novak

State Bar No. 24092905

S.D. Tex. Bar No. 3084746

VALDEZ & TREVIÑO 

ATTORNEYS AT LAW, P.C.

Callaghan Tower

8023 Vantage Dr., Suite 700

San Antonio, Texas 78230

Telephone: (210) 598-8686

Facsimile: (210) 598-8797

Attorney for Defendant Allstate Texas 

Lloyd’s and Vernon Marshall

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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing instrument was served on all 

parties through counsel of record on February 28, 2020 pursuant to the Rule 5 of the Federal 

Rules of Civil Procedure, via CM/ECF or other electronic means:

Jacqueline M. Sandoval

Perry J. Dominguez II

PERRY DOMINGUEZ LAW FIRM PLLC

1045 Cheever Blvd., Suite 103

San Antonio, Texas 78217

Tel: (210) 562-2879

Fax: (210) 570-2322

/s/ Michael M. Novak

Michael M. Novak

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