`
`Robert M. Carlson
`CORETTE BLACK CARLSON & MICKELSON
`129 West Park Street
`P.O. Box 509
`Butte, MT 59703
`PH
`: 406-782-5800
`FAX : 406-723-8919
`bcarslon@cpklawmt.com
`
`Attorneys for Defendants
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MONTANA
`GREAT FALLS DIVISION
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`* *
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`
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` No. CV-21-51-GF-BMM-JTJ
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`* *
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`* *
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` NOTICE OF REMOVAL
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`* * * * *
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`*
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`GOODIAN & SON, INC. a Montana
`Corporation, and JAG FARMS, INC., a
`Montana Corporation,
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` Plaintiffs,
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` v.
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`CORTEVA, INC., CORTEVA
`AGRISCIENCE, DOW
`AGROSCIENCES, The DOW
`CHEMICAL COMPANY,
`DOWDUPONT, INC., and DOE
`DEFENDANTS 1-20,
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` Defendants.
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`COMES NOW defendant Corteva Agriscience and for its notice of removal
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`alleges as follows:
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`1. This action was commenced in the Montana Twelfth Judicial District Court,
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`Hill County, on or about March 1st, 2021, and defendant Corteva
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`Case 4:21-cv-00051-BMM-JTJ Document 1 Filed 05/13/21 Page 2 of 4
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`Agriscience was served on or about April 13th, 2021. Based on the facts
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`alleged in plaintiff’s complaint, the amount in controversy in this matter
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`exceeds $75,000. A copy of all processes and pleadings from the Montana
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`Twelfth Judicial District Court, Hill County, served upon or provided to
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`Corteva Agriscience are attached.
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`2. Based on the allegation in the complaint, plaintiffs Goodian & Son, Inc. and
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`JAG Farms, Inc. are Montana Corporations with their principal place of
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`business in Hill County, Montana.
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`3. Defendant Corteva, Inc. was incorporated in the state of Delaware and has
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`its principal place of business in the state of Delaware.
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`4. Corteva Agriscience was incorporated in the state of Delaware and has its
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`principal place of business in the state of Indiana.
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`5. DowAgrosciences was incorporated in the state of Delaware and had its
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`principal place of business in the state of Indiana.
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`6. The Dow Chemical Company was incorporated in the state of Delaware and
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`has its principal place of business in the state of Michigan.
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`7. DowDupont, Inc. was incorporated in the state of Delaware and has its
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`principal place of business in the state of Delaware.
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`8. This action is now pending in the Montana Twelfth Judicial District Court,
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`Hill County, for the recovery of an amount in excess of $75,000.
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`NOTICE OF REMOVAL
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`Case 4:21-cv-00051-BMM-JTJ Document 1 Filed 05/13/21 Page 3 of 4
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`9. This action is one in which this court has jurisdiction pursuant to the
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`provisions of 28 U.S.C. § 1332, and it is removable from the state court to
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`this court on demand and pursuant to the provisions of 28 U.S.C. § 1446 and
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`it is an action where the matter in controversy exceeds the sum of $75,000,
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`exclusive of interest and costs: the plaintiffs are incorporated in the state of
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`Montana with their principal place of business in the state of Montana; and,
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`defendants are incorporated under the laws of a state other than Montana and
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`have their principal places of business in states other than Montana, in the
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`states of Delaware, Indiana, and Michigan respectively.
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`10. Defendants, Corteva, Inc., DowAgrosciences, The Dow Chemical
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`Company, and DowDupont, Inc., who are represented in this action by the
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`undersigned counsel, have consented to removal of this case to this federal
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`court pursuant to 28 USCA § 1446.
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`Wherefore, the above-named defendants file this notice of removal and
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`request removal of this action to the United States District Court of the
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`District of Montana, Great Falls Division.
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`NOTICE OF REMOVAL
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`DATED this 13th day of May 2021.
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`s/ Robert M. Carlson
`Corette Black Carlson & Mickelson
`Attorneys for Defendants
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`3
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`Case 4:21-cv-00051-BMM-JTJ Document 1 Filed 05/13/21 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`
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`I hereby certify that on this 13th day of May 2021, a copy of the forgoing
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`document was served on the following persons by the following means:
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` CM/ECF Clerk, US District Court
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` Mail/Email
`Reid Perkins
`WORDEN THANE P.C.
`321 W. Broadway St., Ste. 300
`Missoula, MT 59802
`RPerkins@wordenthane.com
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`DATED this 13th day of May 2021.
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`s/ Robert M. Carlson
`Corette Black Carlson & Mickelson
`Attorneys for Defendants
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`NOTICE OF REMOVAL
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`4
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