Read Foreclosure Mill Lawyer Michael Hord’s New Footnote Citation

White v. FCI USA, Inc., 319 F.3d 672, 675 (5th Cir. 2003);

“Additionally, in determining the amount in controversy, the court may consider attorney’s fees, penalties, statutory damages, mental anguish, harm to credit, and punitive damages.11”

Footnote 11

Manguno v. Prudential Prop. & Cas. Ins. Co., 276 F.3d 720, 723 (5th Cir. 2002)

(stating “If a state statute provides for attorney’s fees, such fees are included as part of the amount in controversy”);

St. Paul Reinsurance Co., Ltd. v. Greenberg, 134 F.3d 1250, 1253 (5th Cir. 1998);

see Ray v. State Farm Lloyds, No. CIV.A.3:98- CV-1288-G, 1999 WL 151667, at * 2-3 (N.D. Tex. Mar. 10, 1999)

(finding a sufficient amount in controversy in plaintiffs’ case against their insurance company for breach of contract, fraud, negligence, gross negligence, bad faith.

Chittick v. Farmers Ins. Exch., 844 F. Supp. 1153, 1155 (S.D. Tex. 1994)

(finding a sufficient amount in controversy after considering the nature of the claims, the types of damages sought and the presumed net worth of the defendant in a claim brought by the insureds against their insurance company for actual and punitive damages arising from a claim they made for roof damages).