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`(“Defendant” or “PCNY”)
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`(“C
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`”)
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`“Plaintiff ”)
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`Roleo Beverage Corp. (“Roleo”) and
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`(the “State Court Action”).
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`; and (ii) Plaintiffs’ Order to Show Cause
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`with Exhibits A and B; Plaintiffs’ Memorandum of Law in support of application for preliminary
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`Case 1:22-cv-06921 Document 1 Filed 08/15/22 Page 2 of 6
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`the representations by Plaintiffs’ counsel regarding the anticipated filing of the Order to Show
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`Action from the Court’s docket on
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`Case 1:22-cv-06921 Document 1 Filed 08/15/22 Page 3 of 6
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`For purposes of removal, “a corporation shal
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`has its principal place of business . . . .” 28 U.S.C. § 1332(c)(1). Defendant is therefore a citizen
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`Injunction and Temporary Restraining Order (“Pl’s
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`Pl’s Mem. of Law
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`) “In actions seeking declaratory or
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`Brief”) at 1
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`’
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`ation.”
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`Hunt v. Washington State Apple Adver. Comm’n
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`(1977)). “[T]he amount in controversy is calculated from the plaintiff’s standpoint; the
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`the suit’s intended benefit or the value of the right being protected or the injury being averted
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`constitutes the amount in controversy when damages are not requested.”
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`Case 1:22-cv-06921 Document 1 Filed 08/15/22 Page 4 of 6
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`Plaintiffs claim injunctive relief is necessary to prevent “[t]he loss of an entire
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`profession or livelihood,” including “Plaintiffs’ invaluable customer relationships, reputation,
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`and goodwill,” which were “cultivated over decades of time and effort.” (Pl’s Brief at
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`that Defendant’s “[t]ermination of the Agreement would cause Plaintiffs to
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`forfeit the Distributorship, as if it were being sold with no consideration.” (
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`Plaintiffs intend to assert claims for “breach of contract, and declaratory relief as
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`replevin; anticipatory repudiation; … and/or prima facie tort.” Plaintiffs’ Summons with
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`Case 1:22-cv-06921 Document 1 Filed 08/15/22 Page 5 of 6
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`’
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`(“NYSCEF”) system, and a true and correct copy of this Notice of Removal is being filed this
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`Clerk’s Office, Supreme Court of the State of New York.
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`Case 1:22-cv-06921 Document 1 Filed 08/15/22 Page 6 of 6
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`I hereby certify that, on this date, I caused a copy of Defendant’s Notice of Removal
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`I hereby further certify that, on this date, I caused Defendant’s Notice of Filing of
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