Liberty Harbor Coffee Inc. v. Moss
- Rochon
- 1:25-cv-01335
- U.S. District Court · Southern District of New York
- 1
In Liberty Harbor Coffee v. Moss, Judge Rochon ordered defendants to clarify a plaintiff member’s domicile in an amended removal notice.
The defendants, Maggie Moss and Moss Business Consulting LLC, must amend the removal notice to clarify Arun Nanda’s state of domicile; the order also concerns plaintiff NYNJ Coffee2 LLC’s membership information.
What happened
Liberty Harbor Coffee Inc. and NYNJ Coffee2 LLC sued Maggie Moss and Moss Business Consulting LLC. The defendants filed a second amended notice of removal stating that Arun Nanda and American Management Strategies, Inc. were the sole members of NYNJ Coffee2 LLC.
The notice identified Nanda’s state of residence but did not identify his state of citizenship or domicile. The court explained that residence and domicile are not the same and ordered the defendants to clarify Nanda’s state of domicile.
Judge Jennifer L. Rochon ordered the defendants to file an amended notice of removal by May 16, 2025. The order addressed the removal paperwork and did not decide the underlying dispute.
The detailed version
- Liberty Harbor Coffee Inc. v. Moss · No. 1:25-cv-01335
- Rochon
- May 13, 2025
Background
On February 27, 2025, the defendants filed a Second Amended Notice of Removal. The notice clarified that Arun Nanda and American Management Strategies, Inc. were the sole members of plaintiff NYNJ Coffee2 LLC, also known as Jersey Social.
Issue
The notice stated Nanda’s residence but did not state his citizenship or domicile. The court noted that domicile—the person’s legal home for purposes such as citizenship—is not synonymous with residence.
Ruling
The court ordered the defendants to file an Amended Notice of Removal no later than May 16, 2025, clarifying Nanda’s state of domicile. The order did not resolve the parties’ underlying claims or defenses.
Effect
The order required clarification of the notice used to remove the case to federal court. It does not state any final ruling on the merits of the dispute.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.