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UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

EDWARD L. VINSON, §

§

 Plaintiff, §

§

v. §

§

Civil Action No. 4:22-cv-928

AMERIHOME MORTGAGE 

COMPANY, LLC and CENLAR FSB,

§

§

§

 Defendants. §

DEFENDANTS’ NOTICE OF REMOVAL

Pursuant to 28 U.S.C. §§1332 and 1441, Defendants AmeriHome Mortgage Company, 

LLC (“AmeriHome”) and Cenlar FSB (“Cenlar”) (collectively “Defendants”) remove this action 

from the 352nd Judicial District Court of Tarrant County, Texas, to the United States District 

Court for the Northern District of Texas, Fort Worth Division, and in support thereof would 

show unto the Court the following:

I. STATE COURT ACTION

1. On September 29, 2022, Plaintiff Edward L. Vinson (“Plaintiff” or “Vinson”) 

filed his Original Petition, Application for Temporary Restraining Order, Temporary Injunction, 

Permanent Injunction, and Request for Disclosures (the “Complaint”), styled Edward L. Vinson v. 

AmeriHome Mortgage Company, LLC and Cenlar FSB, Cause No. 352-337284-22, in the 352nd

Judicial District Court of Tarrant County, Texas.

2. Pursuant to 28 U.S.C. §1446(d), this Notice of Removal will be filed with the 

352nd Judicial District Court of Tarrant County, Texas, and a copy of this Notice of Removal 

will also be served on all parties. Pursuant to Fed. R. Civ. P. 7.1 and L.R. 81.1, Defendants have

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filed contemporaneously with this Notice the civil cover sheet, supplemental cover sheet, state 

court docket, state court file, and a certificate of interested persons.

3. In the State Court Action, Plaintiff alleges causes of action centered around the

foreclosure of the real property commonly known as 4803 Comstock Way, Mansfield, Texas 

76063 (the “Property”). Plaintiff brought his lawsuit against Defendants for negligence, violation 

of the Texas Property Code, and breach of contract.

4. Pursuant to 28 U.S.C. §1446(a), copies of all process, pleadings, orders, and other 

papers filed in the 352nd Judicial District Court and obtained by Defendants are attached hereto.

5. In support of this removal and as required by Local Rule 81.1, please find 

attached as follows:

Exhibit A: Index of Matters;

Exhibit B: Civil Cover Sheet;

Exhibit C: Supplemental Civil Cover Sheet;

Exhibit D: State Court Civil Docket Sheet;

Exhibit E: State Court File;

Exhibit F: Certificate of Interested Parties.

II. TIMELINE FOR NOTICE OF REMOVAL

6. Defendants AmeriHome and Cenlar have not been served in this matter. Less than 

thirty (30) days have passed since Defendants received unofficial notice of this lawsuit, and thus, 

removal is timely. 28 U.S.C. §1446(b)(1).

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III. BASIS FOR REMOVAL: DIVERSITY JURISDICTION

8. The Court further has original jurisdiction over this action pursuant to 28 U.S.C. 

§§1332, 1441(a) and (b) because there is diversity among all parties and the amount in 

controversy is well in excess of $75,000.00 exclusive of interest, costs, and attorneys’ fees. 

a. Diversity of Citizenship

9. Based upon Plaintiff’s Complaint, Plaintiff Edward L. Vinson is a citizen of 

Tarrant County, Texas.

10. Defendant AmeriHome Mortgage Company, LLC is a Delaware limited liability 

company. The citizenship of a limited liability company depends on the citizenship of all its 

members. Tewari De-Ox Systems, Inc. v. Mountain States/Rosen, LLC, 757 F.3d 481, 483 (5th 

Cir. 2014); Harvey v. Grey Wolf Drilling Co., 542 F.3d 1077, 1080 (5th Cir. 2008). Amerihome 

is 100% owned by Western Alliance Mortgage Holding Company, LLC, a Delaware limited 

liability company. Western Alliance Mortgage Holding Company, LLC is a wholly owned 

subsidiary of Western Alliance Bancorporation. A corporation is a citizen of the state in which it 

is incorporated and of the state where it has its principal place of business. 28 U.S.C. § 

1332(c)(1). Western Alliance Bankcorporation is incorporated in Delaware with its principal 

business located in Phoenix, Arizona. Therefore, Defendant AmeriHome Mortgage Company, 

LLC is a citizen of Delaware and Arizona for diversity purposes.

11. Defendant Cenlar FSB is a bank chartered in New Jersey with its principal place 

of business in Ewing, New Jersey. Cenlar’s main office, as designated in its registration, is 

located in New Jersey. Therefore, Cenlar is a citizen of New Jersey for diversity purposes.

12. Plaintiff is a citizen of Tarrant County, Texas, Defendant AmeriHome Mortgage 

Company, LLC is a citizen of Delaware and Arizona, and Defendant Cenlar FSB is a citizen of 

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New Jersey, accordingly this lawsuit is between citizens of different states and complete 

diversity exists among the parties. See 28 U.S.C. §1332(a)(2).

b. Amount in Controversy Exceeds $75,000.

13. Plaintiff’s Complaint specifies that Plaintiff seeks monetary relief more than 

$250,000. This alone satisfies the $75,000 requirement for the amount in controversy. See

Plaintiff’s Complaint at ¶ 35.

IV. VENUE

14. Venue for this Removal is proper in the United States District Court for the 

Northern District of Texas, Fort Worth Division, because this district and division includes 

Tarrant County, Texas, which is the location of the pending state court action. 28 U.S.C. 

§1441(a).

V. CONCLUSION

WHEREFORE Defendants AmeriHome Mortgage Company, LLC and Cenlar F.S.B.

remove this action from the 352nd Judicial District Court of Tarrant County, Texas, to the 

United States District Court for the Northern District of Texas, Fort Worth Division, so that this 

Court may assume jurisdiction over the cause as provided by law.

Respectfully submitted,

By: /s/ Shelley L. Hopkins

Shelley L. Hopkins

State Bar No. 24036497

HOPKINS LAW, PLLC

3 Lakeway Centre Ct., Suite 110

Austin, Texas 78734

(512) 600-4320

BARRETT DAFFIN FRAPPIER

TURNER & ENGEL, LLP - Of Counsel

ShelleyH@bdfgroup.com

shelley@hopkinslawtexas.com

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Robert D. Forster, II

State Bar No. 24048470

BARRETT DAFFIN FRAPPIER

TURNER & ENGEL, LLP

4004 Belt Line Road, Ste. 100

Addison, Texas 75001

(972) 386-5040

RobertFO@bdfgroup.com

ATTORNEYS FOR DEFENDANTS

CERTIFICATE OF SERVICE

I hereby certify that on this 17th day of October 2022, I electronically filed the foregoing 

with the Clerk of the Court using the CM/ECF filing system, and will send a true and correct 

copy to the following:

VIA ECF:

Robert C. Newark, III

A Newark Firm

1341 W. Mockingbird Lane, Suite 600W

Dallas, Texas 75247

robert@newarkfirm.com

ATTORNEYS FOR PLAINTIFF

/s/ Shelley L. Hopkins

Shelley L. Hopkins

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