French Laundry Partners, LP dba The French Laundry et al v. Hartford Fire Insurance Company et al

Filing 1

NOTICE OF REMOVAL from Napa County Superior Court California. Their case number is 20CV000397. (Filing fee $400 receipt number 0971-14669467). Filed byHartford Fire Insurance Company, Trumbull Insurance Company. (Attachments: #1 Declaration of Johanna Oh, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Exhibit F, #8 Exhibit G, #9 Exhibit H, #10 Exhibit I, #11 Exhibit J, #12 Exhibit K, #13 Exhibit L, #14 Exhibit M, #15 Exhibit N, #16 Civil Cover Sheet, #17 Certificate/Proof of Service)(Oh, Johanna) (Filed on 7/8/2020)

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Johanna Oh (SBN 316681)
STEPTOE & JOHNSON LLP
One Market Plaza
Spear Tower, Suite 3900
San Francisco, California 94105
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
Of counsel:
Sarah D. Gordon (pro hac vice forthcoming)
James E. Rocap III (pro hac vice forthcoming)
Johanna Dennehy (pro hac vice forthcoming)
STEPTOE & JOHNSON LLP
1330 Connecticut Avenue NW
Washington, District of Columbia 20036
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants Hartford Fire Insurance
Company and Trumbull Insurance Company

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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FRENCH LAUNDRY PARTNERS, LP dba
The French Laundry; KRM, INC. dba Thomas
Keller Restaurant Group; YOUNTVILLE
FOOD EMPORIUM, LLC dba Bouchon
Bistro,
Plaintiffs,
vs.
HARTFORD FIRE INSURANCE
COMPANY; TRUMBULL INSURANCE
COMPANY; KAREN RELUCIO; DOES 1 to
25,

Case No.:
DECLARATION OF JOHANNA OH IN
SUPPORT OF NOTICE OF REMOVAL
BY DEFENDANTS HARTFORD FIRE
INSURANCE COMPANY AND
TRUMBULL INSURANCE COMPANY
Complaint Filed: June 1, 2020
Complaint Filed: June 8, 2020
Removal Date: July 8, 2020

Defendants.

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DECLARATION OF JOHANNA OH

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I, Johanna Oh, declare:

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1.

I am an attorney licensed in the State of California and an associate attorney of

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the law firm Steptoe & Johnson LLP, which is appearing in this action as counsel for Defendants

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Hartford Fire Insurance Company and Trumbull Insurance Company. I am submitting this

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Declaration in support of a Notice of Removal of this action to the U.S. District Court for the

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Northern District of California. Unless otherwise stated, I have personal knowledge of all of the

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facts stated below, and if called upon to do so, I could and would testify competently to the

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matters set forth herein.

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2.

Attached hereto as Exhibits A-I are true and correct copies of the documents filed

in Napa Superior Court, Case No. 20CV000397.

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2.

Attached hereto as Exhibit J is a true and correct copy of a Statement of

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Information (Domestic Stock and Agricultural Cooperative Corporations) that KRM, Inc. filed

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with the California Secretary of State on January 22, 2020.

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4.

Attached hereto as Exhibit K is a true and correct copy of a Statement of

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Information (Limited Liability Company) that Yountville Food Emporium LLC filed with the

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California Secretary of State on October 21, 2019.

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5.

Attached hereto as Exhibit L is a true and correct copy of a Certificate of Limited

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Partnership that French Laundry Partners, L.P. filed with the California Secretary of State on

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March 2, 1994.

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6.

Attached hereto as Exhibit M is a true and correct copy of a Statement of

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Information (Domestic Stock and Agricultural Cooperative Corporations) that French Laundry

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Restaurant Corporation filed with the California Secretary of State on October 28, 2015.

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DECLARATION OF JOHANNA OH

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7.

Attached hereto as Exhibit N is a true and correct copy of an Amendment to

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Certificate of Limited Partnership that French Laundry Partners, LP filed with the California

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Secretary of State on October 9, 2018.

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I declare under penalty of perjury under the laws of the United States of America and the

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State of California that the foregoing is true and correct. Executed this 8th day of July, 2020, at

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San Francisco, California.

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s/ Johanna Oh___________________
Johanna Oh

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DECLARATION OF JOHANNA OH