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Full Answer

A. Introduction

On October 4, 2021, Plaintiffs Pervaiz Rahman and Raufia Rahman (“Plaintiffs”) filed Plaintiffs’ Suit to Redeem (“Petition”) in the 191st Judicial District Court of Dallas County, Texas, styled Pervaiz Rahman and Raufia Rahman v. Citigroup Mortgage Loan Trust Inc. Asset- Backed Pass-Through Certificates, Series 2007-AMC4, U.S.

B. Basis for Removal

Removal in this case is proper because this Court has diversity jurisdiction under 28 U.S.C. § 1332 (a). Where there is complete diversity among parties and the amount in controversy exceeds $75,000, an action may be removed to federal court.

I. Diversity of Citizenship

Based upon information and belief, pursuant to public records searches and Plaintiffs’ Petition, Plaintiffs are citizens of Texas because she is domiciled here.3

II. Amount in Controversy

The Petition seeks injunctive relief to stop foreclosure pursuant to TEX. R. CIV. P. 736.11.4

C. Conclusion

Defendant removes this action from the 191st Judicial District Court of Dallas County, Texas, to the United States District Court for the Northern District of Texas, Dallas Division, so that this Court may assume jurisdiction over the cause as provided by law. Respectfully submitted,