Graham Thompson and Robert Norton successfully defended a plaintiff’s attempt to remand a personal injury lawsuit from federal court, on behalf of a national retailer. Plaintiff originally filed the lawsuit in state court in a plaintiff-friendly venue. The complaint did not include a specific ad damnum, which is required under Tennessee law. Through the defendant’s motion practice, Plaintiff was forced to file an amended complaint including a seven-figure ad damnum. Thompson and Norton then removed the case to the United States District Court based on diversity jurisdiction. Plaintiff filed a Motion to Remand, arguing that the removal was untimely, as the defendant was aware of the amount in controversy because of a pre-suit demand letter. The federal judge denied Plaintiff’s Motion to Remand, calling the motion practice of the defendant’s counsel “commendable”, and stating that the plaintiff should not benefit from her lack of clarity in not stating a specific ad damnum.