Ronald Patrick Cameron Trust Dated February 5 v. Warren Law Group
Ronald Patrick Cameron Trust Dated February 5, 1996 and RPC Ventures, LLC v. Warren Law Group, Scarinci & Hollenbeck, LLC, Scott J. Oh, and Christopher D. Warren
- Paul Engelmayer
- 1:25-cv-08583
- U.S. District Court · Southern District of New York
- 2
In Ronald Patrick Cameron Trust v. Warren Law Group, Judge Engelmayer ordered plaintiffs to amend their complaint to establish diversity jurisdiction.
The plaintiffs, Ronald Patrick Cameron Trust Dated February 5, 1996 and RPC Ventures, LLC, must amend their complaint to provide the information needed to establish diversity jurisdiction. The defendants are also affected because the case's continuation in federal court depends on that jurisdictional showing.
What happened
Ronald Patrick Cameron Trust Dated February 5, 1996 and RPC Ventures, LLC v. Warren Law Group, Scarinci & Hollenbeck, LLC, Scott J. Oh, and Christopher D. Warren began with plaintiffs asserting that the parties' diverse citizenship was the sole basis for federal jurisdiction.
The court found that the complaint did not identify the citizenship of the members of Scarinci & Hollenbeck, a limited liability company. That information was needed to determine whether the parties were completely diverse.
The court granted plaintiffs leave to amend their complaint by October 27, 2025, to provide the required citizenship information. Judge Engelmayer warned that if plaintiffs could not truthfully allege complete diversity, the complaint would be dismissed without prejudice for lack of subject-matter jurisdiction.
The detailed version
- Ronald Patrick Cameron Trust Dated February 5 v. Warren Law Group · No. 1:25-cv-08583
- Paul Engelmayer
- Oct. 20, 2025
Background
Plaintiffs filed the complaint on October 16, 2025, relying on diversity of citizenship as the sole basis for federal jurisdiction. The complaint alleged that Warren Law Group was a corporation that merged with and was succeeded by Scarinci & Hollenbeck, LLC. It described Scarinci & Hollenbeck as a New Jersey limited liability company with its principal place of business in New York, but did not allege the citizenship of the LLC's members.
Jurisdictional issue
For diversity jurisdiction, an LLC has the citizenship of each of its members. The court therefore required plaintiffs to identify the citizenship of each natural person who is a member of an LLC involved in the case. If a member is a corporation, plaintiffs must allege that corporation's place of incorporation and principal place of business. The opinion did not decide the underlying dispute between the parties.
Ruling
The court granted plaintiffs leave to amend the complaint under Federal Rule of Civil Procedure 15(a)(2) by October 27, 2025, to allege the citizenship of all LLC members. The court stated that if plaintiffs could not truthfully allege complete diversity based on the citizenship of the relevant people and entities, the complaint would be dismissed, without prejudice, for lack of subject-matter jurisdiction. This order was entered by Paul A. Engelmayer, United States District Judge.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.