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6480323.1

 

Clarice A. Spicker, Bar #029964

JONES, SKELTON & HOCHULI, P.L.C. 

40 North Central Avenue, Suite 2700 

Phoenix, Arizona 85004 

Telephone: (602) 263-1700 

Fax: (602) 200-7810 

cspicker@jshfirm.com 

Attorneys for Defendants Kwak and PKD 

Trucking, Inc. 

UNITED STATES DISTRICT COURT 

DISTRICT OF ARIZONA 

GUILFORD INSURANCE COMPANY a/s/o 

INMAN TRUCKING, INC., 

Plaintiff,

v. 

SANG GUK KWAK and JANE DOE KWAK, 

husband and wife; ABC CORPORATION I-X; 

XYZ PARTNERSHIPS and/or SOLE 

PROPRIETORSHIPS I-X; JOHN DOES I-X 

and JANE DOES I-X; PKD TRUCKING, 

INC.; ABC CORPORATION I-X; XYZ 

PARTNERSHIPS and/or SOLE 

PROPRIETORSHIPS I-X; JOHN DOES and 

JANE DOES I-X, 

Defendants.

NO. 

NOTICE OF REMOVAL 

Defendants Sang Guk Kwak and PKD Trucking, Inc., by and through 

undersigned counsel, file this Notice of Removal of an Arizona State Court action against 

it to the United States District Court for the District of Arizona and states as follows: 

1. On or about December 6, 2017, an action was commenced against 

Defendants in the Superior Court of the State of Arizona, in and for the County of 

Mohave, under the caption Guildord Insurance Company a/s/a Inman Trucking Company, 

Inc. v. Sang Guk Kwak and Jane Doe Kwak, husband and wife; ABC CORPORATIONS IX; XYZ PARTNERSHIPS AND/OR SOLE PROPRIETORSHIPS I-X; JOHN DOES I-X and 

JANE DOES I-X; PKD TRUCKING, INC.; ABC CORPORATION I-X; XYZ 

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PARTNERSHIPS AND/OR SOLE PROPRIETORSHIPS I-X; JOHN DOES I-X and JANE 

DOES I-X, Case No. CV2017-00583. Plaintiffs’ counsel served Defendants Sang Guk 

Kwak and Jane Doe Kwak, whose true name is Haesun Kwak, on January 26, 2018, by 

personal service. It is believed that Defendant PKD Trucking on January 26, 2018, via 

personal service; however, no proof of service has been filed in the Coconino County 

Superior Court Clerk’s Office and, despite repeated requests, Plaintiff’s counsel has not 

yet provided information regarding the status of personal service on PKD Trucking, Inc. 

2. Copies of pleadings so far filed in the State Court action are attached 

hereto as Exhibit A. 

3. Defendant PKD Trucking, Inc., is a California corporation with its 

principal place of business in Diamond Bar, California. Defendant Kwak is a resident of 

the State of California. 

4. Plaintiff Guilford Insurance Company is a corporation with its 

principal place of business in Illinois. It is believed that Guilford Insurance Company was 

the insurer for Inman Trucking, Inc., a North Carolina corporation, at the time of the 

subject incident. 

5. Plaintiff claims personal injuries as a result of Defendants’ alleged 

liability. Defendants are of the belief that Plaintiffs’ injuries exceed the sum of $75,000. 

6. This Court has original jurisdiction over the civil action pursuant to 

28 U.S.C. § 1332 in that the matter in controversy exceeds the sum or value of $75,000 

exclusive of interest and costs, and the action is between citizens of different states. 

Therefore this action may be removed to this Court pursuant to the provisions of 28 

U.S.C. § 1441, et seq. 

7. Written notice of the filing of this Notice of Removal will be given to 

all adverse parties as required by law and a true and correct copy of this Notice will be 

filed with the Clerk of the Superior Court of the State of Arizona, in and for the County of 

Coconino. 

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6480323.1 3 

 

8. A Notice of Filing Notice of Removal with the Clerk of the 

Coconino County Superior Court and a copy of the same is attached as Exhibit B. 

DATED this 14th day of February, 2018.

JONES, SKELTON & HOCHULI, P.L.C.

By: /s/ Clarice A. Spicker 

Clarice A. Spicker 

40 North Central Avenue, Suite 2700 

Phoenix, Arizona 85004 

Attorneys for Defendants Kwak and PKD 

Trucking, Inc. 

 

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CERTIFICATE OF SERVICE 

I hereby certify that on this 14th day of February, 2018, I caused the 

foregoing document to be filed electronically with the Clerk of Court through the 

CM/ECF System for filing; and served on counsel of record via the Court’s CM/ECF 

system. 

Fred R. Saigh 

Saigh Law, P.L.L.C. 

11811 North Tatum, Suite 3031 

Phoenix, Arizona 85028 

fsaigh@cox.net 

/s/ Becky Finnell 

Case 3:18-cv-08028-GMS Document 1 Filed 02/14/18 Page 4 of 4