IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

CRESTBROOK INSURANCE COMPANY

a/s/o MATT AND CHRISTINE RAMSEY,

Plaintiffs, Civil Action No.:

Judge:

v. Magistrate Judge:

GREPOW, INC., NOTICE OF REMOVAL

JURY TRIAL DEMANDED

Defendant.

NOTICE OF REMOVAL

NOW COMES the above-named Defendant, Grepow, Inc., by its attorneys, McCoy Leavitt 

Laskey LLC, pursuant to 28 U.S.C. §§ 1332, 1441 and 1446, and hereby gives notice of removal

of the above-captioned action from the Circuit Court of Cook County, State of Illinois, County 

Department, Law Division, to the United States District Court for the Northern District of Illinois 

– Eastern Division. In support of removal, Defendant alleges and shows to the Court as follows:

I. INTRODUCTION

1. On July 27, 2020, Plaintiffs filed an action in the Circuit Court of Cook County, 

State of Illinois, County Department, Law Division, styled Crestbrook Insurance Company a/s/o 

Matt and Christine Ramsey v. Grepow, Inc. and the case was assigned No. 2020L007900. A copy 

of the Complaint at Law is attached hereto as Exhibit 1.

2. This is a civil insurance subrogation action in which the Plaintiffs are claiming 

damages resulting from a fire loss that occurred on or about November 13, 2018 at a residence 

owned by Matt and Christine Ramsey located at 3946 Franklin Avenue, Western Springs, Cook 

County, Illinois. Plaintiffs allege that a battery manufactured, assembled, designed, or sold by 

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2

Defendant Grepow, Inc. malfunctioned to cause the subject fire. The Complaint at Law asserts 

claims for negligence and strict product liability against Defendant Grepow, Inc. (Ex. 1.) 

II. TIMELINESS OF REMOVAL

3. Plaintiff’s counsel Kyle Burkhardt provided a courtesy copy of the Complaint at 

Law to Counsel for Defendant Grepow, Inc. on July 29, 2020 via email, before Grepow, Inc. was 

served with the Summons and Complaint at Law. A copy of the email attaching the courtesy copy 

of the Complaint at Law is attached hereto as Exhibit 2. This Notice of Removal is timely filed 

because it is filed within thirty (30) days of July 29, 2020, the date on which Defendant Grepow, 

Inc. first received a courtesy copy of the Complaint at Law via email from Plaintiff’s counsel. (Ex. 

2.)

III. BASIS FOR REMOVAL – DIVERSITY JURISDICTION

4. The United States District Court has original jurisdiction over this litigation filed 

in state court based on diversity of citizenship of the parties. This case may be removed from the 

Circuit Court of Cook County, State of Illinois, County Department, Law Division, to the United 

States District Court for the Northern District of Illinois – Eastern Division, pursuant to 28 U.S.C. 

§ 1332 because it is a civil action between citizens of different states and the amount in controversy 

exceeds $75,000.00, exclusive of interest and costs.

5. Defendant Grepow, Inc. is incorporated in the State of California, has its principal 

place of business in and is deemed to be a citizen of California pursuant to 28 U.S.C. 1332(c)(1). 

6. Plaintiff Crestbrook Insurance Company is incorporated in Ohio, has its principal 

place of business in Ohio, and is deemed to be a citizen of Ohio pursuant to 28 U.S.C. 1332(c)(1). 

Crestbrook issued a policy of homeowner’s insurer to Matt and Christine Ramsey effective at the 

time of the subject fire loss and made payments to and on behalf of the Ramseys under said policy. 

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3

7. Matt and Christine Ramsey, Crestbrook’s insureds, are citizens and residents of 

Illinois. (Ex. 1, ¶ 1.)

8. Plaintiffs are claiming damages in the amount of $821,067.86 for property damage 

to the residence. (Ex. 1.) The amount in controversy thus exceeds the sum or value of $75,000.00, 

exclusive of interest and costs.

9. This Court has diversity jurisdiction over this action pursuant to 28 U.S.C. §§ 1332 

and 1441(a) because it is a civil action between citizens of different states and the amount in 

controversy exceeds $75,000 exclusive of costs and interest.

IV. VENUE

10. The subject fire loss forming the basis for this action occurred in Western Springs, 

Cook County, Illinois, making venue proper in the Northern District of Illinois – Eastern Division. 

(Ex. 1.)

V. FULL COMPLIANCE

10. Pursuant to 28 U.S.C. § 1446(d), Defendant Grepow, Inc. is filing this Notice of 

Removal with the clerk for the state court in which the State Court Action was originally filed. 

Copies of the Notice to the Circuit Court of Cook County, State of Illinois, County Department, 

Law Division, together with this Notice of Removal with exhibits, are being served upon the 

Plaintiffs through their attorneys of record pursuant to 28 U.S.C. § 1446(d). Counsel who has 

appeared on behalf of the Plaintiffs in the state court action is:

Kyle R. Burkhardt, Esq.

Law Office of Frank S. Capuani

135 S. LaSalle Street, Suite 2950

Chicago, IL 60603

Telephone: (312) 263-0093

Email: Burkhk3@nationwide.com

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WHEREFORE, Defendant Grepow, Inc. hereby removes the above-captioned action now 

pending against it in the Circuit Court of Cook County, State of Illinois, County Department, Law 

Division to the United States District Court for the Northern District of Illinois – Eastern Division

to assume full jurisdiction over this action as provided by law.

Respectfully submitted,

McCOY LEAVITT LASKEY LLC

Attorneys for Defendant Grepow, Inc.

Dated: August 13, 2020 By: /s/ Eugene M. LaFlamme

Eugene M. LaFlamme

ILND-GT-11876; ARDC No. 6304557

225 W. Washington Street

Suite 2200

Chicago, IL 60606

Telephone: 262-522-7000

Facsimile: 262-522-7020

elaflamme@MLLlaw.com

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5

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a copy of this document was served on the 13th day 

of August, 2020, upon all parties in the above cause by serving the attorneys of record at their 

respective addresses disclosed on the pleadings. Service was made by:

U.S. Mail Hand-Delivery Email Facsimile Other – EDMS

Attorney for Claimants, Crestbrook Insurance Co. 

a/s/o Matt & Christine Ramsey

Kyle R. Burkhardt, Esq.

Law Office of Frank S. Capuani

135 LaSalle Street, Ste. 2950

Chicago, IL 60603

Burkh3@nationwide.com

Mary B. Schramm

Schramm1@nationwide.com

/s/ Michelle M. Neil

Michelle M. Neil, Legal Assistant

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Atty ARDC No. 6242612/Firm No. 62495 18-019291/CLM00044678/KRB/emb

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS 

COUNTY DEPARTMENT, LAW DIVISION

CRESTBROOK INSURANCE COMPANY ) 

a/s/o MATT and CHRISTINE RAMSEY, ) 

) 

Plaintiff, ) 

) 

v. ) No. 

) 

GREPOW, INC., ) Amount Claimed:$821,067.86 

) 

Defendant. ) 

) 

) 

COMPLAINT AT LAW 

NOW COMES the Plaintiff, CRESTBROOK INSURANCE COMPANY a/s/o

MATT and CHRISTINE RAMSEY Ramsey s , by its attorneys, the Law 

Office of Frank S. Capuani, and for its Complaint against Defendant, GREPOW, 

INC., states the following: 

JURISDICTION AND VENUE 

1. Matt and Christine Ramsey, are Cook County

residents and currently reside at 3946 Franklin Avenue, Western Springs, IL 

60558. 

2. Plaintiff, Crestbrook Insurance Company Crestbrook , is a

corporation authorized to issue insurance policies in the State of Illinois. 

3. Defendant, GREPOW, Inc., was and is a Corporation with its

principal place at 6681 Sierra Lane, Suite F, Dublin, CA and was licensed to do 

business in Cook County, Illinois. 

FILED

7/27/2020 2:35 PM

DOROTHY BROWN

CIRCUIT CLERK

COOK COUNTY, IL

2020L007900

9898855 FILED DATE: 7/27/2020 2:35 PM 2020L007900 2020L007900

EXHIBIT 1

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2 

4. The incident that is the subject of this lawsuit occurred at 3946

Franklin Avenue, Western Springs, Illinois, Cook County, State of Illinois. 

GENERAL ALLEGATIONS 

5. On or about November 13, 2018, Crestbrook had in full force and 

effect a policy of insurance numbered HO00036829 with its named insureds 

Matt and Christine Ramsey which insured the property located at 3946

Franklin Avenue, Western Springs, Illinois, Cook County, State of Illinois. The 

insurance policy insured the Ramsey s property against physical loss or 

damage. 

6. This action stems from fire damage that occurred at the residence 

that was owned by Matt and Christine Ramsey on November 13, 2018, located 

at 3946 Franklin Avenue, Western Springs, Illinois, Cook County, State of 

Illinois. 

7. , and at all times relevant hereto, 

Defendant, , was and is in the business of selling, marketing and 

manufacturing lithium batteries and putting them in the stream of commerce 

in the State of Illinois. 

8. On or about November 13, 2018, the Ramsey s owned and resided 

at the property located at 3946 Franklin Avenue, Western Springs, Illinois. 

9. On information and belief on June 15, 2018, a Tattu 4S LiPo 

Battery 75C, manufactured and sold by GREPOW, was purchased. FILED DATE: 7/27/2020 2:35 PM 2020L007900

EXHIBIT 1

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3 

10. On or about November 13, 2018, fire infiltrated the residence of 

Matt and Christine Ramsey s due to a defect and malfunction of the Tattu 4S 

LiPo Battery 75C at the Ramsey s residence. 

11. As a direct and proximate result of the defect and/or malfunction 

of the Tattu 4S LiPo Battery 75C in the residence, the premises owned and 

occupied by the Ramsey s suffered significant fire damage. 

12. Pursuant to the terms of its insurance policy with Crestbrook, the 

Ramsey s made a claim seeking indemnification and reimbursement of 

damages resulting from the November 13, 2018 fire damage. 

 13. Pursuant to the policy of insurance between Crestbrook and the 

Ramsey s, CRESTBROOK INSURANCE COMPANY has paid to and on behalf of 

its insureds monies for the repair and restoration for all of the property 

damaged by the defect and malfunction of the Tattu 4S LiPo Battery 75C. 

COUNT I NEGLIGENCE 

GREPOW, INC. 

14-28. CRESTBROOK repeats and realleges paragraphs 1 through 13 of 

the General Allegations set forth above as paragraphs 14 through 28 of this 

Count I, as though fully set forth herein. 

29. At all relevant times, the Defendant owed a duty to exercise 

reasonable care and caution in the sale, assembly and/or design of the 4S 

LiPO Battery 75C placed in the residence at 3946 Franklin Avenue, Western 

Springs, Illinois, so as not to cause damage to the property as a result of a

defect and/or malfunction. FILED DATE: 7/27/2020 2:35 PM 2020L007900

EXHIBIT 1

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4 

30. Notwithstanding the aforementioned duty and breach thereof, the 

Defendant committed one or more of the following negligent acts or omissions:

a) improperly manufactured the aforesaid lithium 

battery in such a manner as to prevent defects 

causing malfunctions from catching on fire; 

b) failed to warn the Plaintiff and/or its insureds that 

the lithium battery was defective; and 

 c) was otherwise careless and negligent. 

32. As a direct and proximate result of the foregoing negligent and 

careless acts and/or omissions by the Defendant, GREPOW, the Ramsey s were

caused to suffer significant fire damage to their property referenced above. 

33. As a direct and proximate result of one or more of the negligent 

and careless acts and/or omissions by the Defendant, GREPOW, Crestbrook 

was obligated to pay for the damages suffered by its insureds because of the 

Tattu 4S LiPo Battery 75C malfunction. 

WHEREFORE, Plaintiff, CRESTBROOK INSURANCE COMPANY a/s/o

MATT and CHRISTINE RAMSEY S, prays for judgment, in the amount of 

$821,067.86 plus costs, against Defendant, GREPOW, INC., and any other 

such relief as this Court deems just and proper. 

COUNT II STRICT LIABILITY 

GREPOW, INC. 

34. CRESTBROOK repeats and realleges paragraphs 1 through 13 of 

the General Allegations set forth above as paragraphs 14 through 28 of this 

Count I, as though fully set forth herein. FILED DATE: 7/27/2020 2:35 PM 2020L007900

EXHIBIT 1

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5 

35. Defendant, Grepow, manufactured and sold the 4S LiPO Battery 

75C which was involved in the instant accident. 

36. It was the duty of the defendant in manufacturing and selling the 

battery to make it reasonably safe for its intended and foreseeable uses and to 

ascertain that the battery was free from defects which would render it safe. 

37. Notwithstanding the aforementioned duty and breach thereof, the 

defendant manufactured and sold the subject battery in a defective, unsafe and 

unreasonably dangerous condition in one or more of the following respects: 

a) was not reasonably safe for its intended or foreseeable 

uses; 

b) failed to warn the Plaintiff and/or its insureds that 

the lithium battery was defective; and 

c) was otherwise unreasonably dangerous for its 

intended and foreseeable uses. 

38. As a direct and proximate result of one or more of the foregoing 

defects by the Defendant, GREPOW, the Ramsey s were caused to suffer 

significant fire damage to their property referenced above. 

39. As a direct and proximate result of one or more of the foregoing 

defects by the Defendant, GREPOW, Crestbrook was obligated to pay for the 

damages suffered by its insureds because of the Tattu 4S LiPo Battery 75C

malfunction. 

WHEREFORE, Plaintiff, CRESTBROOK INSURANCE COMPANY a/s/o

MATT and CHRISTINE RAMSEY S, prays for judgment, in the amount of 

$821,067.86 plus costs, against Defendant, GREPOW, INC., and any other 

such relief as this Court deems just and proper. FILED DATE: 7/27/2020 2:35 PM 2020L007900

EXHIBIT 1

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6 

Respectfully submitted:

CRESTBROOK INSURANCE COMPANY 

a/s/o MATT and CHRISTINE RAMSEY,

Plaintiff 

 

 By: 

 KYLE R. BURKHARDT, ESQ. 

 

Law Office of Frank S. Capuani - ARDC No.: 6242612 

Attorneys for Plaintiff 

135 S. LaSalle Street, Suite 2950 

Chicago, IL 60603 

Main: (312) 263-0093 

Email: Burkhk3@nationwide.com FILED DATE: 7/27/2020 2:35 PM 2020L007900

EXHIBIT 1

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From: Burkhardt, Kyle R

To: Michael Aiken

Cc: Eugene LaFlamme; Angela Hinrichs

Subject: RE: Ramsey battery fire

Date: Wednesday, July 29, 2020 11:09:24 AM

Attachments: Ramsey Pltf Complaint (2).pdf

Counsel,

We have filed suit and put it out for service. As a courtesy, I am attaching a copy of the filed

Complaint.

Kyle R. Burkhardt, Esq.

Senior Trial Attorney

Law Office of Frank S. Capuani

135 South LaSalle Street, Suite 2950

Chicago, Illinois 60603

(312) 263-0093 (office)

(312) 917-5254 (direct)

(312) 285-1491 (cell)

Burkhk3@nationwide.com

Employees of Nationwide® Mutual Insurance Company 

Not a legal partnership

Many associates in our office will be working remotely. To help us with this process, please

refrain from sending paper mail, and instead direct all documents only to my secretary, Mary

Schramm at schramm1@nationwide.com

You may continue to send me regular emails during this time.

EXHIBIT 2

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Atty ARDC No. 6242612/Firm No. 62495 18-019291/CLM00044678/KRB/emb

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS 

COUNTY DEPARTMENT, LAW DIVISION

CRESTBROOK INSURANCE COMPANY ) 

a/s/o MATT and CHRISTINE RAMSEY, ) 

 ) 

 Plaintiff, ) 

 ) 

v. ) No. 

 ) 

GREPOW, INC., ) Amount Claimed:$821,067.86 

 ) 

 Defendant. ) 

 ) 

 ) 

COMPLAINT AT LAW 

 NOW COMES the Plaintiff, CRESTBROOK INSURANCE COMPANY a/s/o

MATT and CHRISTINE RAMSEY Ramsey s , by its attorneys, the Law 

Office of Frank S. Capuani, and for its Complaint against Defendant, GREPOW, 

INC., states the following: 

JURISDICTION AND VENUE 

1. Matt and Christine Ramsey, are Cook County

residents and currently reside at 3946 Franklin Avenue, Western Springs, IL 

60558. 

2. Plaintiff, Crestbrook Insurance Company Crestbrook , is a 

corporation authorized to issue insurance policies in the State of Illinois. 

3. Defendant, GREPOW, Inc., was and is a Corporation with its 

principal place at 6681 Sierra Lane, Suite F, Dublin, CA and was licensed to do 

business in Cook County, Illinois. 

FILED

7/27/2020 2:35 PM

DOROTHY BROWN

CIRCUIT CLERK

COOK COUNTY, IL

2020L007900

9898855 FILED DATE: 7/27/2020 2:35 PM 2020L007900 2020L007900

EXHIBIT 2

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2 

4. The incident that is the subject of this lawsuit occurred at 3946

Franklin Avenue, Western Springs, Illinois, Cook County, State of Illinois. 

GENERAL ALLEGATIONS 

5. On or about November 13, 2018, Crestbrook had in full force and 

effect a policy of insurance numbered HO00036829 with its named insureds 

Matt and Christine Ramsey which insured the property located at 3946

Franklin Avenue, Western Springs, Illinois, Cook County, State of Illinois. The 

insurance policy insured the Ramsey s property against physical loss or 

damage. 

6. This action stems from fire damage that occurred at the residence 

that was owned by Matt and Christine Ramsey on November 13, 2018, located 

at 3946 Franklin Avenue, Western Springs, Illinois, Cook County, State of 

Illinois. 

7. , and at all times relevant hereto, 

Defendant, , was and is in the business of selling, marketing and 

manufacturing lithium batteries and putting them in the stream of commerce 

in the State of Illinois. 

8. On or about November 13, 2018, the Ramsey s owned and resided 

at the property located at 3946 Franklin Avenue, Western Springs, Illinois. 

9. On information and belief on June 15, 2018, a Tattu 4S LiPo 

Battery 75C, manufactured and sold by GREPOW, was purchased. FILED DATE: 7/27/2020 2:35 PM 2020L007900

EXHIBIT 2

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3 

10. On or about November 13, 2018, fire infiltrated the residence of 

Matt and Christine Ramsey s due to a defect and malfunction of the Tattu 4S 

LiPo Battery 75C at the Ramsey s residence. 

11. As a direct and proximate result of the defect and/or malfunction 

of the Tattu 4S LiPo Battery 75C in the residence, the premises owned and 

occupied by the Ramsey s suffered significant fire damage. 

12. Pursuant to the terms of its insurance policy with Crestbrook, the 

Ramsey s made a claim seeking indemnification and reimbursement of 

damages resulting from the November 13, 2018 fire damage. 

 13. Pursuant to the policy of insurance between Crestbrook and the 

Ramsey s, CRESTBROOK INSURANCE COMPANY has paid to and on behalf of 

its insureds monies for the repair and restoration for all of the property 

damaged by the defect and malfunction of the Tattu 4S LiPo Battery 75C. 

COUNT I NEGLIGENCE 

GREPOW, INC. 

14-28. CRESTBROOK repeats and realleges paragraphs 1 through 13 of 

the General Allegations set forth above as paragraphs 14 through 28 of this 

Count I, as though fully set forth herein. 

29. At all relevant times, the Defendant owed a duty to exercise 

reasonable care and caution in the sale, assembly and/or design of the 4S 

LiPO Battery 75C placed in the residence at 3946 Franklin Avenue, Western 

Springs, Illinois, so as not to cause damage to the property as a result of a

defect and/or malfunction. FILED DATE: 7/27/2020 2:35 PM 2020L007900

EXHIBIT 2

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4 

30. Notwithstanding the aforementioned duty and breach thereof, the 

Defendant committed one or more of the following negligent acts or omissions:

a) improperly manufactured the aforesaid lithium 

battery in such a manner as to prevent defects 

causing malfunctions from catching on fire; 

b) failed to warn the Plaintiff and/or its insureds that 

the lithium battery was defective; and 

 c) was otherwise careless and negligent. 

32. As a direct and proximate result of the foregoing negligent and 

careless acts and/or omissions by the Defendant, GREPOW, the Ramsey s were

caused to suffer significant fire damage to their property referenced above. 

33. As a direct and proximate result of one or more of the negligent 

and careless acts and/or omissions by the Defendant, GREPOW, Crestbrook 

was obligated to pay for the damages suffered by its insureds because of the 

Tattu 4S LiPo Battery 75C malfunction. 

WHEREFORE, Plaintiff, CRESTBROOK INSURANCE COMPANY a/s/o

MATT and CHRISTINE RAMSEY S, prays for judgment, in the amount of 

$821,067.86 plus costs, against Defendant, GREPOW, INC., and any other 

such relief as this Court deems just and proper. 

COUNT II STRICT LIABILITY 

GREPOW, INC. 

34. CRESTBROOK repeats and realleges paragraphs 1 through 13 of 

the General Allegations set forth above as paragraphs 14 through 28 of this 

Count I, as though fully set forth herein. FILED DATE: 7/27/2020 2:35 PM 2020L007900

EXHIBIT 2

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5 

35. Defendant, Grepow, manufactured and sold the 4S LiPO Battery 

75C which was involved in the instant accident. 

36. It was the duty of the defendant in manufacturing and selling the 

battery to make it reasonably safe for its intended and foreseeable uses and to 

ascertain that the battery was free from defects which would render it safe. 

37. Notwithstanding the aforementioned duty and breach thereof, the 

defendant manufactured and sold the subject battery in a defective, unsafe and 

unreasonably dangerous condition in one or more of the following respects: 

a) was not reasonably safe for its intended or foreseeable 

uses; 

b) failed to warn the Plaintiff and/or its insureds that 

the lithium battery was defective; and 

c) was otherwise unreasonably dangerous for its 

intended and foreseeable uses. 

38. As a direct and proximate result of one or more of the foregoing 

defects by the Defendant, GREPOW, the Ramsey s were caused to suffer 

significant fire damage to their property referenced above. 

39. As a direct and proximate result of one or more of the foregoing 

defects by the Defendant, GREPOW, Crestbrook was obligated to pay for the 

damages suffered by its insureds because of the Tattu 4S LiPo Battery 75C

malfunction. 

WHEREFORE, Plaintiff, CRESTBROOK INSURANCE COMPANY a/s/o

MATT and CHRISTINE RAMSEY S, prays for judgment, in the amount of 

$821,067.86 plus costs, against Defendant, GREPOW, INC., and any other 

such relief as this Court deems just and proper. FILED DATE: 7/27/2020 2:35 PM 2020L007900

EXHIBIT 2

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6 

Respectfully submitted:

CRESTBROOK INSURANCE COMPANY 

a/s/o MATT and CHRISTINE RAMSEY,

Plaintiff 

 

 By: 

 KYLE R. BURKHARDT, ESQ. 

 

Law Office of Frank S. Capuani - ARDC No.: 6242612 

Attorneys for Plaintiff 

135 S. LaSalle Street, Suite 2950 

Chicago, IL 60603 

Main: (312) 263-0093 

Email: Burkhk3@nationwide.com FILED DATE: 7/27/2020 2:35 PM 2020L007900

EXHIBIT 2

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