2      In support of a finding that there is minimal diversity of citizenship, Defendant asserts  that the operative pleading in this action is Plaintiff’s Amended Petition for Damages. (R. Doc. 1  at 2). Paragraph 104 of the Amended Petition defines the purported class as follows:  The class ofall residents of Louisianawho were insured by GoAuto for the total loss of their vehicle, who suffered damage to their vehicle during the GoAuto policy period, and who were paid by GoAuto for their total loss based upon a valuation that was reduced by a “condition adjustment” deducted from the stated values of the comparison vehicles used to calculate GoAuto’s payment for the total loss vehicle.   (R. Doc. 1-28 at 20) (emphasis added). Defendant asserts that while it is a citizen of Louisiana,  some “Louisiana resident policyholders are not Louisiana citizens” because, in the process of  asserting claims, those policyholders “have provided GoAuto last known addresses outside the  State of Louisiana.” (R. Doc 1 at 5-6). Defendant submits declarations by Jason Burge and Kerry  Berry in support of the proposition that certain purported class members under the Amended  Petition are not citizens of Louisiana, and, therefore, there is minimal diversity under CAFA.  (SeeR. Docs. 1-2 to 1-13; R. Doc. 1-31) (sealed)).    The foregoing assertion of minimal diversity under CAFA is premised on Plaintiff’s  Amended Petition being the operative pleading at the time of removal. Defendant asserts the  following in Footnote 1 of its Notice of Removal: “Plaintiff subsequently filed a Motion for  Leave to File Second Supplemental and Amending Petition on September 7, 2021, but the order  granting the motion for leavewas not executed as of the date this Notice of Removal was  filed, hence the Amended Petition remains the operative petition.” (R. Doc. 1 at 2 n.1) (emphasis  added). Defendant submits a copy of Plaintiff’s Motion for Leave to File Second Supplemental  and Amending Petition, which includes an unsigned proposed order. (R. Docs. 1-23 at 18-19  (pages 1-2); R. Doc. 1-24 (pages 3-13), 1-25 (pages 15-24), 1-26 at 1-6 (pages 25-30).  Case 3:21-cv-00557-BAJ-RLB Document 15 10/13/21 Page 2 of 5