Case 3:13-cv-00818-ST

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Patrick D. Gilroy, OSB No. 832106 E-Mail: pgilroy@gilroylawfirm.com Wade R. Keenon, OSB No. 852522 E-Mail: wkeenon@gilroylawfirm.com THE GILROY LAW FIRM, PC 7307 SW Beveland Street, Suite 200 Tigard, OR 97223 Tel. (503) 619-2333 Fax (503) 619-2339 Attorneys for Def. Red Rock Risk Retention Group, Inc.

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON PORTLAND DIVISION

LES D. BRANNON, Plaintiff, v. AON RISK SERVICES SOUTHWEST, INC., a foreign corporation; AON RISK INSURANCE SERVICES WEST, INC., a foreign corporation; RED ROCK RISK RETENTION GROUP, INC., a foreign corporation; and ACE AMERICAN INSURANCE COMPANY, a foreign corporation., Defendants. TO THE CLERK OF THE ABOVE-ENTITLED COURT: Case No. NOTICE OF REMOVAL OF ACTION UNDER 28 U.S.C. 1441(B) (DIVERSITY)

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PLEASE TAKE NOTICE that defendant RED ROCK RISK RETENTION GROUP, INC. hereby removes to this Court the state court action described below. 1. On March 23, 2013, an action was commenced in the Circuit Court for the State of the Oregon in and for the County of Multnomah, entitled Les D. Brannon, plaintiff v. Aon Risk Services Southwest, Inc. et. al, defendants, as Case Number 1303-04339. A copy of the initial Complaint is attached hereto as Exhibit A. On April 11, 2013, plaintiff filed an Amended Complaint in said action, a copy of which is attached hereto as Exhibit B. 2. Defendant Red Rock Risk Retention Group, Inc. was first served with summons and a copy of the Amended Complaint on April 15, 2013. A copy of the summons is attached as Exhibit C. This Notice of Removal is timely as it is filed within 30 days of the date on which Red Rock was served with summons and complaint. 3. This is a civil action of which this Court has original jurisdiction under 28 U.S.C. 1332, and is one which may be removed to this Court by defendant pursuant to the provisions of 28 U.S.C. 1441(b) in that it is a civil action between citizens of different states and the matter in controversy exceeds the sum of $75,000, exclusive of costs and interest. 4. At the time the state court action was filed and on the date of this notice of removal, plaintiff was and still is a citizen of the State of Oregon. Defendant Red Rock Risk Retention Group, Inc. was, at the time of the filing of this action, and still is, a corporation incorporated under the laws of the State of Arizona, having its principal place of business in that state. Defendant Aon Risk Services Southwest, Inc. was, at the time of the filing of this action, and still is, a corporation incorporated under the laws of the State of Texas, having its principal place of business in the State of Illinois. Defendant Aon Risk Services West, Inc. was, at the time of the filing of this action, and still is, a corporation incorporated under the laws of the State of California, having its principal place of business in the State of Illinois. Defendant Ace

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American Insurance Company was, at the time of the filing of this action, and still is, a corporation incorporated under the laws of the State of Pennsylvania, having its principal place of business in that state. 5. Robert Barton, counsel for defendants Aon Risk Insurance Services West, Inc. and Aon Risk Services Southwest, Inc., has confirmed those defendants consent to the removal of this action to federal court. 6. Defendant Ace American Insurance Company has not appeared in the state court action. Defendant Red Rock has made a good faith effort to determine whether Ace American is represented by counsel, but has been unable to do so. Defendant Red Rock believes Ace American will consent to this removal once it and its counsel are notified. DATED this 14th day of May, 2013. THE GILROY LAW FIRM, P.C.

By:

/s/ Wade R. Keenon Patrick G. Gilroy, OSB No. 832106 Wade R. Keenon, OSB No. 852522 Attorneys for def. Red Rock Risk Retention Group, Inc.

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