← Atain Specialty Insurance Company v. Trinity SNK Corporation

Complaint Filed by Atain Specialty Insurance Company. (Attachments: # 1 Exhibit a - Underlying Complaint, # 2 Exhibit B - Underlying Amended Complaint, # 3 Exhibit C - Policy, # 4 Exhibit D - Loss Notice, # 5 Exhibit E - 10-15-5 Letter, # 6 Exhibit F - 1-9-26 Letter, # 7 Civil Cover Sheet) Please Visit Our Website at Http://www.gand.uscourts.gov/commonly-used-forms to Obtain Pretrial Instructions and Pretrial Associated Forms Which Includes the Consent to Proceed Before U.S. Magistrate Form

Document #1 Filed 03/27/2026 · 54 pages · District Court, N.D. Georgia · View original PDF

1This is a complaint for declaratory judgment brought pursuant to Federal Rule of Civil Procedure 57 and 28 U.S.C. § 2201 to declare the rights and other legal relations surrounding questions of actual controversy that presently exist between Atain and the Defendants.

2A controversy of a judicial nature presently exists among the parties which demands a declaration by this Court in order that Atain may have its rights and duties under the relevant contract of insurance determined and avoid the possible accrual of damages.

3Each named defendant herein has been joined in compliance with case law requiring the insurer seeking a declaratory judgment to bring into the action all individuals or entities that have a financial or other interest in the outcome of the coverage issues to be decided through declaratory judgment.

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4Plaintiff Atain Specialty Insurance Company (“Atain”) is a Michigan corporation with its principal place of business in Farmington Hills, Michigan. Atain is a citizen of the State of Michigan.

5Defendant Trinity SNK Corporation f/k/a Global Management and Investment Corporation (“Global”) is a domestic profit corporation organized and existing under the laws of the State of Georgia, with its principal place of business in the State of Georgia. Defendant Global changed its name with the Georgia Secretary of State, effective on September 17, 2024, after the Policy (defined below) was issued to Defendant Global by Atain. Defendant Global may be served with service of process through its registered agent, Joel M. Haber, located at 2030 Avalon Parkway, Suite 200, McDonough, Georgia 30253. Defendant Global is subject to the jurisdiction and venue of this Court.

6Defendant Radheshvar, LLC d/b/a Motel 6 (“Radheshvar” or “Motel 6”), is a hotel owner, hotel operator, franchisee, manager, and/or supervisor of a hotel located at 2820 Chamblee Tucker Road, Atlanta, Georgia 30341. Defendant Radheshvar is

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a domestic limited liability company organized and existing under the laws of the state of Georgia, with its principal place of business in the state of Georgia. Defendant Radheshvar is authorized to conduct business in the state of Georgia. Upon information and belief, Defendant Global is the owner, operator, franchisee, manager, and/or supervisor of Defendant Motel 6. Upon information and belief, Defendant Radheshvar/Motel 6 has the following members: Joel M. Haber and Rupa Patel. Members Haber and Patel are, upon information and belief, Georgia citizens who have the present intention to remain in the state of Georgia. Defendant Motel 6 may be served with process through Radheshvar’s registered agent, Kirtan Patel, located at One Lakeside Commons, 990 Hammond Drive, Suite 800, Atlanta, Georgia 30328. Defendant Motel 6 is subject to the jurisdiction and venue of this Court.

7Defendant Radheshvar, LLC d/b/a Super 8 (“Radheshvar” or “Super 8”)1, is a hotel owner, hotel operator, franchisee, manager, and/or supervisor of a hotel located at 2822 Chamblee Tucker Road, Atlanta, Georgia 30341. Defendant Radheshvar is a domestic limited liability company organized and existing under the laws of the 1 “Radheshvar” shall refer to the entity, collectively, in connection with both the Motel 6 and Super 8 properties, for ease of reference.

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state of Georgia, with its principal place of business in the state of Georgia. Defendant Radheshvar is authorized to conduct business in the state of Georgia. Upon information and belief, Defendant Global is the owner, operator, franchisee, manager, and/or supervisor of Defendant Super 8. Upon information and belief, Defendant Radheshvar/ Super 8 has the following members: Joel M. Haber and Rupa Patel. Members Haber and Patel are, upon information and belief, Georgia citizens who have the present intention to remain in the state of Georgia. Defendant Super 8 may be served with process through Radheshvar’s registered agent, Kirtan Patel, located at One Lakeside Commons, 990 Hammond Drive, Suite 800, Atlanta, Georgia 30328. Defendant Super 8 is subject to the jurisdiction and venue of this Court.

8Defendant CPLG Properties, LLC (“CPLG”) is a hotel owner, hotel operator, franchisee, manager, and/or supervisor of the La Quinta Inn & Suites by Wyndham Atlanta Midtown - Buckhead located at 2535 Chantilly Drive NE, Atlanta, Georgia 30324. Defendant CPLG is a foreign limited liability company organized and existing under the laws of the state of Delaware, with its principal place of business in the state of Texas. Defendant CPLG is authorized to conduct business in the state of Georgia. Upon information and belief, Defendant CPLG has the following

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Public U.S. federal court record (district court docket 73109864, document 1). Source via the RECAP Archive (Free Law Project). The same record is available from PACER. Informational only — not legal advice.