UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN MILWAUKEE DIVISION

JOHN J. LOONTJENS, Plaintiff, and SENTRY INSURANCE, A MUTUAL COMPANY, Case No. 2013-CV-1217 Involuntary Plaintiff, v. ACE AMERICAN INSURANCE COMPANY; GHP GROUP, INC; ABC INSURANCE COMPANY; and W.W. GRAINGER, INC. Defendants. NOTICE OF REMOVAL

PLEASE TAKE NOTICE that, pursuant to 28 U.S.C. 1441 and 1446, defendants ACE American Insurance Company, GHP Group, Inc. and W.W. Grainger, Inc. (collectively, Defendants), by their attorneys, Whyte Hirschboeck Dudek S.C., hereby remove this action from the Circuit Court of Milwaukee County, Wisconsin, to the United States District Court for the Eastern District of Wisconsin. The grounds for removal are as follows: 1. This action was initiated by the plaintiff, John J. Loontjens, in the Circuit Court of

Milwaukee County, Wisconsin, and is currently pending in said Court as Civil Action No. 13-CV-007826. 2. This action was filed by the plaintiff on August 28, 2013.

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Defendant ACE American Insurance Company was served via its Registered

Agent on October 8, 2013 at 8:33 a.m. 4. Defendant GHP Group, Inc. was served via on October 11, 2013 at 1:15 p.m. A

copy of the Summons and Complaint is attached to this Notice as Exhibit A, and the plaintiffs initial discovery requests (which contain the date and time of service and the signature of the process server on the last page) are attached as Exhibit B. 5. Defendant W.W. Grainger, Inc. was served via its Registered Agent on October 8,

2013 at 8:33 a.m. A copy of the Proof of Service on W.W. Grainger, Inc. is attached as Exhibit C. 6. In addition to the documents attached as Exhibits A through C, Defendants have

also been served with the Notice of Appearance, Answer, Cross-Claim and Counterclaim of Sentry Insurance, a Mutual Company, which are collectively attached as Exhibit D. 7. This notice is timely filed pursuant to 28 U.S.C. 1446(b), in that thirty (30) days

have not expired since October 2, 2013 the earliest date upon which any of the Defendants were served with the Summons and Complaint through their Registered Agent. 8. 9. Plaintiff John J. Loontjens is an individual who resides in Caledonia, Wisconsin. Involuntary plaintiff Sentry Insurance, a Mutual Company, is a Wisconsin

insurance company domiciled in Stevens Point, WI. 10. Defendant ACE American Insurance Company is a Pennsylvania insurance

company with its principal place of business in Philadelphia, PA. 11. Defendant GHP Group, Inc. is an Illinois corporation with its principal place of

business in Morton Grove, IL. 12. Defendant W.W. Grainger, Inc. is an Illinois corporation with its principal place

of business in Lake Forest, IL.

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In light of the plaintiffs alleged personal injuries and his request for an award of

punitive damages, the matter in controversy in this action exceeds the sum of $75,000, exclusive of interest and costs. 14. This court has original jurisdiction of this action pursuant to 28 U.S.C. 1332

because the matter in controversy exceeds the sum of $75,000, exclusive of interest and costs, and is between parties who are deemed citizens of different states. 15. The United States District Court for the Eastern District of Wisconsin is the

proper district court to which this civil action should be removed, because it was originally filed in the Milwaukee County, a county within the jurisdiction of this Court. 16. All defendants consent to this removal.

WHEREFORE, Defendants respectfully request that this case be removed from the Milwaukee County Circuit Court, where it is currently pending, to the United States District Court for the Eastern District of Wisconsin. Dated this 30th day of October, 2013. Respectfully submitted,

/s/ John W. Halpin Daniel J. La Fave Wis. Bar No. 1020190 John W. Halpin Wis. Bar No. 1064336 WHYTE HIRSCHBOECK DUDEK S.C. 555 East Wells Street, Suite 1900 Milwaukee, WI 53202 Telephone: (414) 273-2100 Facsimile: (414) 223-5000 Email: dlafave@whdlaw.com jhalpin@whdlaw.com

ATTORNEYS for DEFENDANTS ACE American Insurance Company, GHP Group, Inc. and W.W. Grainger, Inc.

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