1I submit this declaration in support of the Notice of Removal filed by Allagash Timberlands LP in the above-captioned action.
2I serve as the Vice President of Woodlands for J. D. Irving, Limited, which, as noted below, is one of the partners the owns Defendant Allagash Timberlands LP. In my role as Vice President of Woodlands, I manage and oversee the day-to-day operations of Allagash Timberlands LP. Accordingly, I make this declaration based upon my own personal knowledge, including my review of relevant business records of Allagash Timberlands LP made at or near the time of the events recorded therein, by a person with knowledge of those events or from information transmitted by such a person, kept in the course of Allagash Timberlands LP’s regularly conducted business, and which were the regular practice of Allagash Timberlands LP to make. I specifically have personal knowledge of the places of incorporation and principal places of business of Allagash Timberlands LP’s partners, as well as the fair market value of the approximately 80 acres of real property at issue in this case.
3Allagash Timberlands LP is a limited partnership.
4Allagash Timberlands LP is owned by four partners: J. D. Irving, Limited, Consolidated Rambler Mines Limited, Eagle Lake Timberlands Inc., and Allagash Holdings Limited.
5J. D. Irving, Limited is a corporation formed under the laws of New Brunswick, Canada, with a principal place of business in New Brunswick, Canada. That is the location from which its executives direct, control, and coordinate the corporation’s activities.
6Consolidated Rambler Mines Limited is a corporation formed under the laws of Ontario, Canada, with a principal place of business in Ontario, Canada. That is the location from which its executives direct, control, and coordinate the corporation’s activities.
7Eagle Lake Timberlands Inc. is a corporation formed under the laws of New Brunswick, Canada, with a principal place of business in New Brunswick, Canada. That is the location from which its executives direct, control, and coordinate the corporation’s activities.
8Allagash Holdings Limited is a corporation formed under the laws of New Brunswick, Canada, with a principal place of business in New Brunswick, Canada. That is the location from which its executives direct, control, and coordinate the corporation’s activities.
9Allagash Timberlands LP is a statewide leader in forestry and land management, and, accordingly, appropriately valuing land holdings is central to our business. Allagash Timberlands values the disputed property, described in Paragraphs 6 and 7 of the Plaintiffs’ Complaint as approximately 80 acres, at an amount greater than $75,000.
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct. Dated: March 27, 2026
/s/ Jason Limongelli__________________ Jason Limongelli UNITED STATES DISTRICT COURT DISTRICT OF MAINE
I hereby certify that on March 27, 2026, I electronically filed the foregoing document, via email to the U.S. District Court in Portland, Maine, and served the same, via email and U.S. Mail, postage prepaid, upon counsel for Plaintiff addressed as follows:
John E. Baldacci, Jr., Esq. Steve Smith Trial Lawyers 191 Water Street Augusta, ME 04330 [email protected] /s/ Nolan L. Reichl Nolan L. Reichl PIERCE ATWOOD LLP Merrill’s Wharf 254 Commercial Street Portland, ME 04101 Tel: 207.791.1100 [email protected] Attorney for Defendant Allagash Timberlands LP
