In Re Curtis Bruce WILLIS, Petitioner

Zachary Perry, a Missouri resident, filed this personal injury action in Missouri state court on October 7, 1999, against Virginia resident Curtis Bruce Willis. The complaint sought an unspecified amount of damages for pain and suffering, permanent disability, and wage loss. Following an initial round of discovery wherein Willis’ filed an Offer of Judgment in the amount of $75,001, Willis removed the action to federal court under 28 U.S.C. § 1441(b), asserting the court had diversity jurisdiction under 28 U.S.C. § 1332(a). Perry then moved to remand the case to state court, arguing the notice…