Dominguez

I. BACKGROUND

21 On or about August 14, 2019, Plaintiff MARGARITA DOMINGUEZ 22 (hereinafter “Plaintiff”) commenced the above-entitled civil action in the Superior 23 Court for the County of Solano by filing a Complaint therein entitled Margarita 24 Dominguez v. Dollar Tree Stores, Inc. dba Dollar Tree Jefan, LLC, and DOES 1 to 25 10, inclusive, Case No. FCS053401. Plaintiff’s Complaint for personal injury arises 26 from an alleged incident on July 20, 2018, at defendant Dollar Tree Stores, Inc.’s 27 (“Dollar Tree”) store in Fairfield, California. 28 On November 7, 2019, plaintiff, by and through her counsel of record, made a written settlement demand in the amount of $100,000 to defendant. Based on this “other paper,” Dollar Tree determined that the amount in controversy exceeded the $75,000.00 statutory minimum. Accordingly, Dollar Tree removed the matter to federal court pursuant to 28 U.S.C. §§1332, 1441, and 1367, on November 18, 2019. The parties have now agreed and stipulated to limit any and all recovery of damages by plaintiff MARGARITA DOMINGUEZ to $74,999. or less, as evidenced by the Stipulation to Cap Plaintiff’s…