Response to Order to Show Cause by Atain Specialty Insurance Company.. (Tuz, Nicholas)

42673834.1:10739-0324

Plaintiff, vs.

f/k/a Global Management and Investment Corporation; RADHESHVAR LLC, d/b/a Motel 6 and d/b/a Super 8; CPLG

Defendants.

Plaintiff in the above-styled civil action and, through the undersigned counsel, hereby responds to this Honorable Court's Order to Show Cause as to why the instant civil matter should not be dismissed for lack of subject matter jurisdiction.

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As an initial matter, the undersigned acknowledges that the inclusion of “upon information and belief” in the jurisdictional paragraphs was improper. Notwithstanding same, the undersigned believed that their Complaint for Declaratory Judgment was accurate based on the information available and its investigation with respect to the citizenship of the members of the respective limited liability company defendants.

Recognizing that further investigation into the citizenship of the limited liability company defendants is warranted, the undersigned states they intend to dismiss the instant matter, without prejudice, to conduct same. After further investigation, the undersigned intends to re-file the Complaint. Accordingly, a Notice of Voluntary Dismissal, without prejudice, is forthcoming.

This 6th day of April, 2026.

1230 Peachtree Street NE; Suite 2350 Atlanta, Georgia 30309 Telephone: 470-552-1150 Fax: 470-552-1151 [email protected] [email protected] [email protected]

/s/ Nicholas B. Tuz Richard E. Zelonka Georgia Bar No. 142152 Nicholas B. Tuz Georgia Bar No. 274964 Attorneys for Atain Specialty Insurance Company