Juan Fermin v. Lonnie Gene III Hinson

I. BACKGROUND

27 On September 20, 2022, Plaintiff filed in the Los Angeles County Superior Court a 28 form complaint (“Complaint”) against Alliance Fabrication & Piping LLC (“Alliance”), a “business entity form unknown,” and Lonnie Gene III Hinson (“Hinson”) (collectively, “Defendants”). (ECF No. 1-1 at 2 (“Compl.”)). The Complaint alleges two causes of action labeled “Motor Vehicle” and “General Negligence,” respectively. (Id. at 4). As to the first cause of action, the Complaint alleges that, on September 25, 2022, on Interstate 605 near State Route 60 and in the City of Industry, California, Defendants committed negligent acts, and the acts were the legal and proximate cause of injuries and damages to Plaintiff. See (Id. at 5). As to Plaintiff’s second cause of action, the Complaint alleges on the same date and in the same location, “Defendants, and each of them, so carelessly and negligently owned, operated, maintained, drove, controlled, and entrusted their motor vehicle causing bodily injury and other damages to Plaintiff.” (Id. at 5–6). The Complaint does not state Defendants’ citizenship or an amount-in-controversy. See (id.).…