Maria Velaso Rodas v. Costco Wholesale Corporation

I.

BACKGROUND

Plaintiff Maria Velaso Rodas visited a store owned and operated by Defendant Costco Wholesale Corporation (“Costco”) in Inglewood, California, on November 18, 2018. Not. of Removal, Ex. 1 (Compl.) at ¶¶ 14-15 [Doc. # 1-2]. She alleges that as she was exiting the store, she slipped and fell on a sausage “and/or similar object,” causing severe injuries. Id. at ¶ 8.

On August 12, 2020, Plaintiff filed suit in Los Angeles County Superior Court against Costco, “Lisa Doe,” and Does 1 through 25, inclusive. The Complaint alleges that, while Costco is a corporate citizen of Washington, Plaintiff and Lisa Doe are residents of Los Angeles County. Id. at ¶¶ 1-3.

Costco removed the action to this Court on September 7, 2021. [Doc. # 1]. The Notice of Removal asserts that the Court has diversity jurisdiction over the action because Plaintiff and Costco are diverse and Plaintiff’s statement of damages received on August 6, 2021 indicates that she seeks $2 million in total damages. Not. of Removal at ¶¶ 1-2, 8-9.

Plaintiff now moves to remand the action to Los Angeles County Superior Court. Mot. to Remand (“MTR”) [Doc. # 9.] The motion is fully briefed. [Doc. ##…