Kayla Jones v. KLLM Transport Services, LLC

I. BACKGROUND

On April 30, 2019, Plaintiff Kayla Jones (“Plaintiff”) filed her complaint against Defendants KLLM Transport Services, LLC (“KLLM”), Gregory Bell (“Bell”) (collectively, “Defendants”), and Does 1–50 and in the Superior Court for the County of San Bernardino. (“Complaint,” Dkt. No. 1-1.) The Complaint alleges personal injury claims arising out of a vehicle collision. (Id.) Plaintiff served KLLM on July 19, 2019. (Dkt. No. 14 at 13.) Plaintiff has not yet served Gregory Bell. (Id. at 10.)

Defendants removed the action to this Court on August 23, 2019. (“Notice of Removal,” Dkt. No. 1.) Defendants assert diversity jurisdiction. (Id.) Plaintiff filed the Motion on September 17, 2019. (Motion.) In support of the Motion, Plaintiff filed the Declaration of Anna You with Exhibits A–C. (“You Declaration,” Dkt. No. 14 at 9–26.) Defendants opposed the Motion on September 26, 2019. (“Opposition,” Dkt. No. 16.) In support of the Opposition, Defendants filed the Declaration of Matthew J. Kracht with Exhibits A–C. (“Kracht Declaration,” Dkt. No. 16-1.) Plaintiff filed her reply on October 4, 2019 with a second Declaration of Anna You. (“Reply,” Dkt. No. 17;…