Оригинальный текст

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

 

GLOBAL ART, S.A.,

Plaintiff,

UPI LIMITED, INC.

Defendant.

 

FIRST AMENDED COMPLAINT

Plaintiff GLOBAL ART, S.A., by its attorneys, as and for its complaint, alleges as follows:

 

THE PARTIES

• Plaintiff GLOBAL ART, S.A. is a foreign corporation, duly organized and existing by virtue of the laws of Switzerland, with a place of business in Geneva Switzerland.

• Upon information and belief, Defendant UPI LIMITED, INC. is a foreign corporation, duly organized and existing by virtue of the laws of the State of Delaware, with a place of business in the County of Clinton, State of New York.

 

 

 

JURISDICTION AND VENUE

• This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1332(a). The amount in controversy exceeds $75,000, exclusive of interest and costs, and there is diversity between the parties.

• Venue in the Eastern District of New York is based upon 28 U.S.C. § 1391(b).

• As a result of Defendants' actions, Plaintiff is entitled to a judgment directing Defendants to deliver the Goods to Plaintiff, requiring Defendants to pay all storage and related fees which accrued while the Goods were in storage, and granting Plaintiff a money judgment in an amount to be determined at trial, plus interest and expenses.

 

JURY TRIAL DEMANDED

• Plaintiff demands that this matter be tried before a jury.

 

 

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray that this Court:

A. Enter a judgment in favor of Plaintiff and against  Defendants in the sum of One Hundred Eighty-Nine Thousand Four Hundred ($189,400.84) Dollars and Eighty-Four Cents, plus interest, attorney's fees and expenses;

B. Enter a judgment directing Defendants to deliver the Goods to Plaintiff and to pay all storage and related fees which accrued while the Goods were in storage;

C. Enter a judgment in favor of Plaintiff and against Defendants in an amount to be determined at trial, plus interest and expenses; and

D. Award Plaintiff such other and further relief as this Court may deem just and proper.