Qatar Investment and Projects Development Holding Company v. Royale
Qatar Investment and Projects Development Holding Company, W.L.L. v. L'Etoile Royale, Inc.
- P. Castel
- 1:20-cv-09413
- U.S. District Court · Southern District of New York
- 2
Judge Castel ordered Qatar Investment v. L’Etoile Royale to clarify citizenship allegations supporting federal diversity jurisdiction.
Qatar Investment and Projects Development Holding Company, W.L.L., L’Etoile Royale, Inc., L’Etoile Royale, LLC, and Garbis Dogramaciyan; the order requires QIP to clarify citizenship allegations and requires the LLC and Garbis Dogramaciyan to respond to limited interrogatories.
What happened
In Qatar Investment and Projects Development Holding Company, W.L.L. v. L’Etoile Royale, Inc., the plaintiff relied on the parties’ citizenship to invoke federal diversity jurisdiction. The complaint did not adequately allege the citizenship of the members of defendant L’Etoile Royale, LLC, defendant Garbis Dogramaciyan, or QIP itself.
The court allowed QIP to send limited questions to the LLC and Garbis Dogramaciyan about their citizenship. The defendants must respond within 14 days, and QIP must amend its complaint within 45 days to provide the required citizenship allegations.
Judge Castel ordered this information-gathering and amendment process, warning that the action will be dismissed for lack of subject matter jurisdiction if QIP does not amend its complaint on time.
The detailed version
- Qatar Investment and Projects Development Holding Company v. Royale · No. 1:20-cv-09413
- P. Castel
- Nov. 16, 2020
Background
Qatar Investment and Projects Development Holding Company, W.L.L. (QIP) brought the action under the court’s diversity jurisdiction, which allows a federal court to hear certain disputes involving parties with different citizenships. The complaint described QIP as a family-run investment company based in Doha, Qatar.
For a limited liability company, the complaint must identify the citizenship of every member. If a member is a corporation, it must identify the corporation’s place of incorporation and principal place of business. The court also noted that diversity jurisdiction is unavailable when one side includes both citizens and foreign citizens while the other side includes only foreign citizens.
Jurisdictional deficiencies
The complaint did not allege the citizenship of the members of defendant L’Etoile Royale, LLC. It also did not allege the citizenship of defendant Garbis Dogramaciyan, whom the complaint identified as the chief executive officer of defendant L’Etoile Royale, Inc. Although the complaint suggested that QIP was a citizen of Qatar, it did not expressly allege QIP’s place of incorporation and principal place of business as required for a corporation or similar entity.
Order
Within 21 days of the order, QIP may serve L’Etoile Royale, LLC with a limited interrogatory—written discovery question—seeking the citizenship of all natural-person members and, for any corporate member, its place of incorporation and principal place of business. QIP may also serve Garbis Dogramaciyan with a limited interrogatory seeking his citizenship. The defendants must respond to their respective interrogatories within 14 days.
Within 45 days of the order, QIP must amend its complaint to allege its own citizenship, the citizenship of each member of L’Etoile Royale, LLC, and the citizenship of Garbis Dogramaciyan. The order states that the action will be dismissed for lack of subject matter jurisdiction if QIP does not do so. Judge P. Castel did not dismiss the action in this order; he ordered the specified discovery and amendment process.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.