PracticeProtection Casualty Company v. Center for Gastrointestinal Health, S.C. et al

Page 1 of 28
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS
PRACTICEPROTECTION
CASUALTY 	COMPANY, 	formerly
known 	as 	DOCTORS 	DIRECT
INSURANCE, INC.,
Plaintiff,
v. 	Case No. 25-CV-00784-SPM
CENTER FOR
GASTROINTESTINAL HEALTH
S.C., et al.,
Defendants.
MEMORANDUM AND ORDER
McGLYNN, District Judge:
This matter comes before the Court on two Motions to Dismiss: first, a Motion
to Dismiss for Lack of Subject Matter Jurisdiction pursuant to Federal Rule of Civil
Procedure 12(b)(1) filed by Defendant Veronica Douglas (Doc. 28) and joined by
Defendants Vickie Franco, Efrain Franco, Melissa Porter, Robert Porter, and Center
for Gastrointestinal Health, S.C. (Doc. 34, p. 1; Docs. 35, 36); and, second, a Motion
to Dismiss on the basis of the Brillhart abstention doctrine filed by Defendant Center
for Gastrointestinal Health, S.C. (Doc. 34). Having fully considered the issues
presented, the Motion to Dismiss for Lack of Subject Matter Jurisdiction (Doc. 28) is
DENIED, and the Motion to Dismiss based on the Brillhart abstention doctrine (Doc.
34) is DENIED.
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 1 of 28 Page ID
#<pageID>

Page 2 of 28
FACTUAL A ND P ROCEDURAL B ACKGROUND
This lawsuit involves a dispute over insurance coverage for a medical practice
clinic in Illinois and underlying medical malpractice litigation. We begin with the
medical malpractice claims for relevant background. On or about November 8, 2021,
Efrain 	and 	Vickie 	Franco 	(“the 	Francos,” 	who 	were 	spouses 	and 	are 	current
Defendants in this action) brought suit against Defendants Kurt Sprunger, M.D.;
Center for Gastrointestinal Health, S.C. (hereinafter “CGH,” also a Defendant named
in this action); Granite City Illinois Hospital Company, LLC, d/b/a Gateway Regional
Medical Center; and Davol, Inc. in the Circuit Court for St. Clair County, Illinois.
(Doc. 1, Ex. B); Franco et al. v. Kurt Sprunger, M.D., et al., Case No. 21L0672 (Ill. Cir.
Ct. 2021). The Francos sought damages for injuries incurred on or about December
30, 2019, that they alleged were the result of Defendants’ negligence in providing
medical care to Vickie Efrain. (Doc. 1, Ex. B). On or about August 17, 2021, Veronica
Douglas (also a current Defendant in this action) brought action against Sprunger,
CGH, and Gateway Regional Medical Center in the Circuit Court for St. Clair County.
(Doc. 1, Ex. B); Douglas v. Kurt Sprunger, M.D., et al., Case No. 21L0449 (Ill. Cir. Ct.
2021). Douglas sought damages for injuries she alleged she sustained while in the
care of Defendants on or about March 2020. (Doc. 1, Ex. B). On or about March 29,
2022, Melissa and Robert Porter (“the Porters,” who were spouses and are current
Defendants in this action) brought suit against Sprunger, CGH, and Gateway
Regional Medical Center in the Circuit Court for St. Clair County. (Doc. 1, Ex. B);
Porter et al. v. Kurt Sprunger, M.D., et al., Case No. 22LA0263 (Ill. Cir. Ct. 2022). The
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 2 of 28 Page ID
#<pageID>

Page 3 of 28
Porters sought damages for alleged injuries incurred by Melissa Porter on or about
June 22, 2020. (Doc. 1, Ex. B). The Francos, the Porters, and Douglas all allege they
were injured at Gateway Regional Medical Center, a medical practice in Granite City,
Illinois, while in the care of Sprunger, CGH, and Gateway Regional Medical Center.
(See id.).
Prior to the alleged injuries, Plaintiff PracticeProtection Casualty Company,
formerly known as Doctor’s Direct Insurance, Inc. (hereinafter “PracticeProtection”),
issued a medical professional liability insurance policy to CGH, which operated a
medical practice in Fairview Heights, Illinois. (Doc. 1, Ex. A). The Francos, the
Porters, and Douglas alleged that their treating physician, Sprunger, was an
employee and agent of both Gateway Regional Medical Center and CGH. (See Doc. 1,
Ex. B). The insurance policy at issue in this suit, Policy No. E14-50415 (hereinafter
the 	“Policy”), 	as 	Plaintiff 	PracticeProtection 	alleges, 	provided 	coverage 	from
September 5, 2020, to September 5, 2021, which was renewed with effective dates of
September 5, 2021, to September 5, 2022. (See Doc. 1, p. 3).
On February 11, 2025, two months before the instant suit was filed, CGH filed
suit in the Circuit Court of St. Louis County, Missouri. (Doc 34, Ex. 1); Center for
Gastrointestinal Health v. The Hilb Group Central, LLC, et al., Case No. 25SL-
CC01577 (Mo. Cir. Ct. 2025). CGH’s Missouri Petition names as defendants The Hilb
Group Central, LLC (an insurance broker) and Doctor’s Direct Insurance, Inc. (the
former name of current Plaintiff in this case, PracticeProtection), and brought three
counts: breach of fiduciary duty against the broker (Count I); breach of contract
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 3 of 28 Page ID
#<pageID>

Page 4 of 28
against PracticeProtection (Count II); and vexatious refusal to pay under the Policy
in violation of M O. REV. STAT . §§ 375.296, 375.240 against PracticeProtection (Count
III). (Doc. 34, Ex. 1).
Count II of CGH’s Missouri Petition, the breach of contract claim, alleged that
PracticeProtection initially provided a defense for the underlying malpractice suits
brought by the Francos, the Porters, and Douglas, but later denied coverage, thereby
breaching the insurance contract. (Doc. 34, Ex. 1). The Missouri Petition seeks a
declaration that PracticeProtection is obligated to defend and indemnify CGH in the
underlying Illinois malpractice suits. (Doc. 34, Ex. 1). CGH’s Missouri suit does not
name the Francos, the Porters, or Douglas as parties to that suit. (Doc. 34, Ex. 1).
PracticeProtection filed a motion to dismiss the Missouri action on forum non
conveniens 	grounds, 	arguing 	in 	part 	that 	the 	underlying 	tort 	claimants 	were
necessary parties who cannot be joined in Missouri. (Doc. 39, Ex. 2). The Missouri
court denied that motion on July 10, 2025. (Doc. 39, Ex. 3).
On April 30, 2025, PracticeProtection filed the instant declaratory judgment
action in this Court, alleging diversity jurisdiction exists to establish federal subject
matter jurisdiction. (Doc. 1). The Complaint names as defendants CGH and the five
individual plaintiffs from the underlying Illinois state court malpractice suits: the
Francos, the Porters, and Douglas. PracticeProtection seeks a declaration that the
Policy does not provide liability insurance coverage for CGH with respect to the three
underlying lawsuits pending in St. Clair County. (Doc. 1, pp. 6−8).
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 4 of 28 Page ID
#<pageID>

Page 5 of 28
On June 17, 2025, Defendant Douglas filed a Motion to Dismiss for Lack of
Subject Matter Jurisdiction pursuant to Federal Rule of Civil Procedure12(b)(1).
(Doc. 28). Defendants Efrain and Vickie Franco and Melissa and Robert Porter filed
Motions to Join Douglas’ Motion, which this Court granted on July 11, 2025. (See
Docs. 35, 36, 37). Douglas argues in her Motion that Plaintiff PracticeProtection’s
principal place of business is in Illinois, and as such, complete diversity does not exist.
(See Doc. 28). On June 25, 2025, CGH filed a separate Motion to Dismiss, joining
Douglas’ jurisdictional challenge and independently seeking dismissal under the
Brillhart abstention doctrine. (Doc. 34). CGH contends that this Court should decline
to exercise jurisdiction over the action because CGH’s earlier-filed Missouri lawsuit
presents the same coverage issues between substantially the same parties. (See id.).
PracticeProtection opposes both motions. (See Docs. 38, 39).
LEGAL S TANDARD
I. 	Federal Subject Matter Jurisdiction
Federal courts are courts of limited jurisdiction, empowered only to decide
“Cases” and “Controversies” under Article III of the Constitution. U.S. CONST . art.
III, § 2; Fox v. Dakkota Integrated Sys., LLC, 980 F.3d 1146, 1151 (7th Cir. 2020).
This limitation “confines federal courts to hearing only those disputes that are
sufficiently concrete and presented in a form historically recognized as appropriate
for judicial resolution.” Fox, 980 F.3d at 1151. “Subject-matter jurisdiction is the first
question in every case.” State of Illinois v. City of Chicago, 137 F.3d 474, 478 (7th Cir.
1998). A Rule 12(b)(1) motion challenges the court’s power to hear the case. F ED. R.
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 5 of 28 Page ID
#<pageID>

Page 6 of 28
CIV. P. 12(b)(1); Hallinan v. Fraternal Order of Police of Chi. Lodge No. 7, 570 F.3d
811, 820 (7th Cir. 2009).
Diversity jurisdiction exists under 28 U.S.C. § 1332(a) when the citizenship of
every plaintiff is diverse from every defendant and the amount in controversy exceeds
$75,000, exclusive of interest and costs. For purposes of diversity jurisdiction, a
corporation is deemed a citizen of every state where it has been incorporated and of
the state where it maintains its principal place of business. See id. § 1332(c)(1). A
corporation’s principal place of business “refers to the place where the corporation’s
high level officers direct, control, and coordinate the corporation’s activities.” Hertz
Corp. v. Friend, 559 U.S. 77, 80 (2010). This location is commonly referred to as the
corporation’s “nerve center.” Id. “In practice, the principal place of business should
normally be the place where the corporation maintains its headquarters—provided
that the headquarters is the actual center of direction, control, and coordination.” Id.
at 93. The test focuses on the location of corporate management and decision-making,
not on where the bulk of a company’s business activities occur or where the public
perceives the company to be located. Id. at 92−93, 96.
Critically, “[f]actors dealing with day-to-day operating responsibilities” are to
be disregarded in the nerve center analysis. Chamberlain Mfg. Corp. v. Maremont
Corp., 828 F. Supp. 589, 592 (N.D. Ill. 1993). As the Supreme Court emphasized, by
way of example, even “if the bulk of a company’s business activities visible to the
public take place in New Jersey, while its top officers direct those activities just across
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 6 of 28 Page ID
#<pageID>

Page 7 of 28
the river in New York, the ‘principal place of business’ is New York.” Hertz, 559 U.S.
at 96.
It is also firmly established that “the jurisdiction of the court depends upon the
state of things at the time of the action brought,” which is also referred to as the time-
of-filing rule. See Grupo Dataflux v. Atlas Glob. Grp., L.P., 541 U.S. 567, 570−71
(2004) (quoting Mollan v. Torrance, 22 U.S. (9 Wheat.) 537, 539 (1824)). The
citizenship of the parties at the time the complaint is filed controls the diversity
analysis, regardless of subsequent events or prior circumstances. Perez v. Staples
Cont. & Com. LLC, 31 F.4th 560, 567 (2022).
II. 	Abstention Doctrine
The Declaratory Judgment Act provides that federal courts “may declare the
rights and other legal relations of any interested party seeking such declaration,
whether or not further relief is or could be sought.” 28 U.S.C. § 2201(a). The Act
requires that an actual controversy exists between the parties, but if all jurisdictional
prerequisites are satisfied, it gives district courts broad discretion in deciding
whether to exercise its authority. Nationwide Ins. v. Zavalis, 52 F.3d 689, 692 (7th
Cir. 1995); see also Envision Healthcare, Inc. v. PreferredOne Ins. Co., 604 F.3d 983,
986 (7th Cir. 2010) (stating that district courts “possess significant discretion to
dismiss or stay claims seeking declaratory relief, even though they have subject
matter jurisdiction over such claims”). The permissive language of the statute confers
discretion on courts rather than creating an absolute right for litigants. See Wilton v.
Seven Falls Co., 515 U.S. 277, 287 (1995). This discretion led to the creation of the
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 7 of 28 Page ID
#<pageID>

Page 8 of 28
Wilton-Brillhart doctrine. See Arnold v. KJD Real Est., LLC, 752 F.3d 700, 707 (7th
Cir. 2014) (“Wilton-Brillhart abstention is possible because of the federal court’s
unique and substantial discretion in deciding whether to declare the rights of
litigants.”) (citation modified).
Wilton-Brillhart abstention applies “when a federal court is called upon to
proceed in a declaratory judgment suit where another suit is pending in state court
presenting the same issues, not governed by federal law, between the same parties.”
Id. (citing Brillhart v. Excess Ins. Co. of Am., 316 U.S. 491, 495 (1942)) (citation
modified). Under the doctrine, a district court is permitted to—but not required to—
abstain 	in 	cases 	where 	“solely 	declaratory 	relief 	is 	sought 	and 	parallel 	state
proceedings are ongoing.” Envision Healthcare, Inc., 604 F.3d at 986. The doctrine is
rooted in many considerations, including federalism, comity, efficiency, and fairness.
See id.; Nationwide Ins., 52 F.3d at 692.
The classic example of when courts abstain under the Wilton-Brillhart doctrine
is where there is a federal case seeking only declaratory relief and a state case
involving “the same parties” and litigating “the same issues.” Envision Healthcare,
Inc., 604 F.3d at 986. However, “the mere pendency of another suit is not enough in
itself to refuse a declaration.” Sears, Roebuck & Co. v. Zurich Ins. Co., 422 F.2d 587,
590 (7th Cir. 1970). Determining whether to abstain under the Wilton-Brillhart
doctrine is “an inherently discretionary call for the district court, ‘because facts
bearing on the usefulness of the declaratory judgment remedy, and the fitness of the
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 8 of 28 Page ID
#<pageID>

Page 9 of 28
case for resolution, are peculiarly within [its] grasp.’” Arnold, 752 F.3d at 707 (quoting
Wilton, 515 U.S. at 288).
When determining whether to abstain from exercising jurisdiction over a
declaratory judgment action, district courts must consider several factors derived
from Brillhart:
“(a) the scope of the pending state court proceeding and the nature
of defenses open there,
(b) whether the claims of all parties in interest can satisfactorily
be adjudicated in that proceeding,
(c) whether necessary parties have been joined,
(d) 	whether 	such 	parties 	are 	amenable 	to 	process 	in 	that
proceeding, and
(e) whether going forward with the declaratory action will serve a
useful 	purpose 	in 	clarifying 	the 	legal 	obligations 	and
relationships 	among 	the 	parties 	or 	will 	merely 	amount 	to
duplicative and piecemeal litigation.”
316 U.S. at 495; Nationwide Ins., 52 F.3d at 692. Other relevant considerations
are “whether the declaratory remedy is being used merely for the purpose of
‘procedural fencing’ or ‘to provide an arena for a race for res judicata’” and “whether
the use of a declaratory action would increase friction between our federal and state
courts and improperly encroach on state jurisdiction.” NUCOR Corp. v. Aceros Y
Maquilas de Occidente, S.A. de C.V., 28 F.3d 572, 579 (7th Cir. 1994) (quoting
Nationwide Mut. Fire Ins. Co. v. Willenbrink, 924 F.2d 104, 105 (6th Cir. 1991)).
Importantly, “the mere pendency of another suit is not enough in itself to refuse a
declaration.” Sears, Roebuck & Co., 422 F.2d at 590.
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 9 of 28 Page ID
#<pageID>

Page 10 of 28
A NALYSIS
I. 	Motion to Dismiss for Lack of Jurisdiction Pursuant to Rule 12(b)(1)
Defendants Douglas, the Francos, the Porters, and CGH challenge this Court’s
subject matter jurisdiction on the ground that complete diversity does not exist. (See
Docs. 28, 34) The parties agree, as does this Court, that all Defendants are citizens of
Illinois and that the amount in controversy exceeds $75,000, exclusive of interest and
costs.1 (Doc. 28, p. 6). The sole dispute regarding citizenship of the parties concerns
whether PracticeProtection is sufficiently diverse from all Defendants, such that this
matter may be heard by this Court. We first begin with the time-of-filing rule. “The
time-of-filing rule measures all challenges to subject-matter jurisdiction premised
upon diversity of citizenship against the state of facts that existed at the time of filing
regardless of when raised.” Rodas v. Seidlin, 656 F.3d 610, 623 (7th Cir. 2011) (citing
Grupo Dataflux, 541 U.S. at 570−71) (citation modified). Accordingly, this Court is
concerned with the citizenship of the parties as of the date that PracticeProtection
filed the instant lawsuit in this Court: April 30, 2025. (Doc. 1).
In her Motion, Defendant Douglas (joined by the remaining Defendants the
Francos, the Porters, and CGH) argues that PracticeProtection is not diverse from all
Defendants because it, too, is a citizen of the State of Illinois. (Doc. 28, p. 2). Douglas
argues that in a 2021 filing with the State of Florida, Plaintiff indicated it was
1 Douglas alleges in her underlying St. Clair County Complaint that she is a resident of Illinois. (See
Doc. 28, Ex., 1). In her Motion to Dismiss, which the Francos and the Porters joined by Motion, Douglas
further states that “[t]here is no dispute that all named Defendants are citizens of Illinois.” (See id.,
p. 6). Further, Douglas’ Motion states there is no dispute that the amount in controversy in the action
exceeds $75,000. (See id.).
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 10 of 28 Page ID
#<pageID>

Page 11 of 28
incorporated under the laws of the State of Illinois, with its principal office in Oak
Park, Illinois; further, Plaintiff asserted the same information in three subsequent
filings in the State of Florida in 2022, 2023, and 2024. (Doc. 28, pp. 4, 6; id., Exs.
9−12). Nonetheless, Defendants argue that Plaintiff’s website, as of June 2025 (the
date on which Douglas filed her Motion), Plaintiff’s website states its main office is
in Oak Park, Illinois.2 (Doc. 28, p. 7). Douglas asserts, without any accompanying
evidence, that several of the states in which Plaintiff has a license to issue insurance
lists Plaintiff as an Illinois corporation with a business or home office address of an
Oak Park, Illinois, address. (Doc. 29, p. 7). Defendants also point to filings with the
National Association of Insurance Commissions, a “database used to track licensed
insurance providers for several of the States where Doctors Direct is licensed,” which
purportedly state that Plaintiff maintains a business and a statutory home office
address at a location in Oak Park, Illinois. (Doc. 28, p. 4; id., Exs. 15−16). Defendants
acknowledge that Plaintiff’s “most recent filings with the State of Florida state that
its principal place of business” is in Jacksonville, Florida, but argues that “it is
insufficient for a corporate entity to change its principal place of business just by
filing new paperwork—the nerve center of the corporation must actually move.” (Doc.
28, p. 7).
In its Response, PracticeProtection asserts that on December 6, 2024, the
company filed its articles of incorporation under Florida law and, as a result, became
a citizen of Florida. (Doc. 38, p. 4). In addition, PracticeProtection asserts that as of
2 In support of this, Douglas attaches a purported screenshot of Doctors Direct Insurance website
indicating an Oak Park, Illinois, address on the site’s “Contact Us” page. (Doc. 28, Ex. 14).
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 11 of 28 Page ID
#<pageID>

Page 12 of 28
April 30, 2025, its corporate headquarters were located in Jacksonville, Florida. (Id.).
As such, Plaintiff PracticeProtection asserts it is only a citizen of the State of Florida
as of the date of filing this suit.
The evidence presented by the parties establishes the following. Plaintiff
PracticeProtection was initially incorporated as Doctors Direct Insurance, Inc., in the
State of Illinois on or about July or August 2006. (See Doc. 28, Ex. 9; Doc. 38, Ex. 3;
see also Doc. 38, Ex. 1, ¶ 4). In August 2024, Doctors Direct applied to re-domesticate
and become an insurance company incorporated under the laws of the State of Florida
under the new name PracticeProtection Casualty Company. (Doc. 38, Ex. 1, ¶5; id.,
Ex. 2). On December 6, 2024, both the Florida Department of State and the Florida
Office of Insurance Regulation approved the re-domestication. (Doc 38, Ex. 1, ¶ 6; id.,
Ex. 3). On December 18, 2024, the Illinois Department of Insurance issued an
Amended Certificate of Authority, effective December 6, 2024, recognizing the re-
domestication to Florida and the name change. (Doc 38, Ex. 1, ¶ 8; id., Exs. 6−7).
Defendants do not dispute that Plaintiff re-domesticated under the laws of the State
of Florida on December 6, 2024. (See Doc. 28, p. 4). Accordingly, this Court finds that
as of April 30, 2025, PracticeProtection was incorporated under the laws of the State
of Florida. Therefore, for purposes of diversity jurisdiction, PracticeProtection is a
citizen of Florida.
The inquiry does not stop there; this Court must also examine the location of
PracticeProtection’s headquarters; or where its principal place of business was
located as of April 30, 2025. Under Supreme Court precedent established in Hertz,
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 12 of 28 Page ID
#<pageID>

Page 13 of 28
the principal place of business is the corporation’s “nerve center”—the place where
its high-level officers direct, control, and coordinate corporate activities. See 559 U.S.
at 92−93. Defendants argue that the continued use of both addresses by Plaintiff
“raises an inference that the [Oak Park, Illinois,] address continues to function as the
‘nerve center’ of the corporation,” while “the fact that the company previously used
the 	[Jacksonville, 	Florida,] 	address 	as 	the 	business 	address 	of 	a 	single
director/registered agent raises the inference that it continues to function as, at most,
a meeting place of certain specific directors, and not the ‘nerve’ center of the
corporation.” (Doc. 28, p. 7).
In Response, Plaintiff argues that as of April 30, 2025, its principal place of
business was located in the State of Florida. (Doc 38, p. 7). Plaintiff puts forth
evidence that, as of it filing with the Secretary of State for the State of Florida on
February 10, 2025, its principal place of business was in Jacksonville, Florida, where
it remained as of the date of filing suit on April 30, 2025. (Id., p. 8; see id., Ex. 2).
Moreover, Plaintiff argues, its headquarters in Jacksonville, Florida, is the location
at which its corporate officers run the company and make decisions to direct, control,
and coordinate PracticeProtection’s business activities. (Id.; see id., Ex. 1, ¶¶ 11−13).
PracticeProtection’s 	Executive 	Vice 	President 	and 	General 	Counsel, 	William
Saunders Bliss, testified in an affidavit submitted with PracticeProtection’s Response
that as of April 30, 2025, none of PracticeProtection’s corporate officers were located
in Illinois. (Id., Ex. 1, ¶ 12). More specifically, Bliss testified that three of five of the
company’s corporate officers were located in and worked out of the company’s
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 13 of 28 Page ID
#<pageID>

Page 14 of 28
Jacksonville, Florida, headquarters, while the Chief Financial Officers primarily
worked remotely from his home in Florida, and the Vice President of Claims worked
remotely from his home in Indiana.3 (Id., Ex. 1, ¶ 11). Bliss additionally testified that,
as of April 30, 2025: all managerial decisions made by corporate officers were made
out of the company’s Jacksonville, Florida, headquarters; the company conducted all
of its underwriting, claims, marketing, accounting, and finance operations, and
issued 	all 	insurance 	policies 	and 	renewals 	out 	of 	its 	Jacksonville, 	Florida,
headquarters; and the company’s physical files were all located at its Jacksonville,
Florida, headquarters. (Id., Ex. 1 ¶¶ 13−16).
The Court finds that the evidence presented in the Motion to Dismiss and
Plaintiff’s Response indicate that, on the day Plaintiff filed suit in this Court, its
“nerve center” was located in Florida. Defendants’ arguments that this Court should
infer the location of Plaintiff’s headquarters, without concrete factual support, and
reliance on where Plaintiff was headquartered in the past do nothing to establish
where Plaintiff’s corporate officers conducted day-to-day business and made decisions
on April 30, 2025. Defendants’ argument that PracticeProtection’s website lists an
Illinois address as the company’s Main Office is irrelevant evidence under Hertz: the
Supreme 	Court 	expressly 	held 	that 	public 	perception 	does 	not 	determine 	a
corporation’s principal place of business. (See Doc. 28, Ex. 14); Hertz, 559 U.S. at 96
3 The Court notes that attached to Defendant Douglas’ Motion to Dismiss were filings by Plaintiff in
the State of Florida in the years 2021−24, which listed the names and address of the company’s
directors and officers. (Doc. 28, p. 4; id., Exs. 9−12). In 2022 and 2023, it appears the company had
seven corporate directors/officers, with two located in Florida, two in Indiana, and three in Illinois.
(Doc. 28, Exs. 10−11). In 2024, it appears the company had eight corporate officers/directors, with two
located in Florida, four located in Illinois, and two in Indiana. (Doc. 28, Ex. 12).
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 14 of 28 Page ID
#<pageID>

Page 15 of 28
(“For example, if the bulk of a company’s business activities visible to the public take
place in New Jersey, while its top officers direct those activities just across the river
in New York, the ‘principal place of business’ is New York.”). Evidence regarding
Plaintiff’s headquarters or purported place of business prior to April 30, 2025, also
does not bear on the relevant question of where Plaintiff was headquartered on the
date it filed this suit. 	The Hertz inquiry looks to where corporate officers actually
direct, control, and coordinate activities on behalf of the business, not to whether
every filing in every jurisdiction has been updated. See 559 U.S. at 92−93, 96. This
Court finds that Plaintiff’s Executive Vice President and General Counsel presents
credible testimony in his sworn affidavit that PracticeProtection, as of April 30, 2025,
issued insurance policies and renewals from its Jacksonville, Florida, location, and
that this location was also where managerial decisions were made by officers,
business 	such 	as 	underwriting, 	claims, 	marketing, 	accounting, 	and 	finance
operations was conducted, and where its physical files were located. (Doc. 38, Ex. 1).
Accordingly, this Court finds that, for purposes of diversity jurisdiction,
PracticeProtection was incorporated under the laws of the State of Florida and was
headquartered in Florida on the date it filed suit in this Court, thereby making it a
citizen only of the State of Florida. As Defendants are all residents of the State of
Illinois, this Court finds that complete diversity exists amongst the parties, such that
this Court has subject matter jurisdiction under 28 U.S.C. § 1332 to hear this case.
In the alternative, Douglas argues that PracticeProtection was undisputedly a
citizen of Illinois on September 6, 2023, the date which this Court should consider
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 15 of 28 Page ID
#<pageID>

Page 16 of 28
operative because it was on that date that PracticeProtection incurred the obligation
to file the instant declaratory judgment action. (Doc. 28, pp. 2, 7−8). Under the Illinois
doctrine of estoppel, Douglas argues, an insurance company that issued a policy that
allegedly provided coverage for a legal complaint must either defend the suit under a
reservation of rights or seek a declaratory judgment that there is no coverage. (Id.,
pp. 7−8 (citing Emps. Ins. of Wausau v. Ehlco Liquidating Trust, 708 N.E.2d 1122,
1134−35 (Ill. 1999). Douglas argues that PracticeProtection provided legal defense to
the defendants she named in her underlying St. Clair County medical malpractice
suit until counsel for those defendants withdrew on September 6, 2023. (Id., p. 8). On
that 	date, 	Douglas 	asserts, 	when 	PracticeProtection 	stopped 	defending 	the
underlying suit under a reservation of rights, it had an obligation to seek a
declaratory judgment on the issue of coverage. (Id.). As such, Douglas maintains, this
Court should consider Plaintiff PracticeProtection’s citizenship as of that date, the
day the obligation to sue arose, which was “undisputedly Illinois.” (Id.).
This Court notes that Defendant Douglas fails to cite any case law supporting
her position that this Court should disregard the time-of-filing rule in favor of using
the date at which she alleges Plaintiff’s obligation to sue arose. The one case that
Defendant does cite, Employers Insurance of Wausau, provides that the estoppel
doctrine applies only where an insurer has breached its duty to defend, and in that
instance, operates to bar the insurer from raising policy defenses to coverage. See 708
N.E.2d at 1135. Employers Insurance of Wausau provides no basis for this Court to
deviate from well-settled precedent announced by the Supreme Court that “all
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 16 of 28 Page ID
#<pageID>

Page 17 of 28
challenges to subject-matter jurisdiction premised upon diversity of citizenship
against the state of facts that existed at the time of filing.” Grupo Dataflux, 541 U.S.
at 571. PracticeProtection filed this lawsuit on April 30, 2025, and according to the
citizenship of the parties on that date, this Court has jurisdiction over the matter. As
such, this Court’s finding that complete diversity exists is not altered by this
argument.
II. 	Motion to Dismiss based on Wilton-Brillhart Abstention
Defendant Center for Gastrointestinal Health additionally filed a separate
Motion to Dismiss, arguing that this Court should decline to exercise jurisdiction
pursuant to the Brillhart abstention doctrine. (Doc. 34). CGH argues that abstention
is warranted here because they filed a lawsuit in the Circuit Court for St. Louis
County, Missouri on February 11, 2025, that is duplicative of the proceedings before
this Court such that this Court should abstain from issuing a declaratory judgment
the matter. (See id., pp. 1−2). Specifically, CGH states that abstention is appropriate
here because: (1) the suit they filed in St. Louis County seeks damages for breach of
the very same insurance contract and coverage as the present suit before this Court;
(2) CGH and PracticeProtection are parties to both suits, (3) the issue of whether
PracticeProtection is obligated to defend and indemnify the underlying medical
malpractice suits is present in both suits; and (4) PracticeProtection can obtain
comparable relief in the St. Louis County case as they can in the present case. (Doc.
34, pp. 3−4). In Response, PracticeProtection argues that abstention is not warranted
because the Missouri lawsuit does not include all the necessary parties, such that
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 17 of 28 Page ID
#<pageID>

Page 18 of 28
there is no parallel proceeding justifying this Court’s declination to exercise its
jurisdiction. (Doc. 39, p. 1). Plaintiff states that CGH seeks a determination of
PracticeProtection’s coverage obligations with respect to the three underlying St.
Clair County medical malpractice suits but has failed to include the five individual
claimants (Douglas, the Porters, and the Francos) in that suit, such that the parties
are not substantially the same for purposes of the Brillhart abstention doctrine. (See
id., p. 2).
Defendant CGH filed a Petition in St. Louis County Circuit Court on February
11, 2025, naming the Hilb Group Central, LLC and Doctors Direct Insurance, Inc.
(PracticeProtection) as Defendants. (Doc. 34, Ex. 1). CGH’s first claim is against the
Hilb Group Central, LLC, which CGH alleges is a Missouri limited liability company
that operates an insurance brokerage business. (See id.). CGH alleges that the Hilb
Group Central, LLC, breached its fiduciary duties of loyalty, care, and prudence to
CGH by failing to obtain appropriate coverage for its staff, failing to warn and advise
CGH of a potential coverage gap, failing to include Dr. Kurt Sprunger as a covered
employee, 	and 	failing 	to 	ensure 	the 	coverage 	provided 	by 	Doctors
Direct/PracticeProtection was identical to its previous policy. (Id., Ex. 1, p. 7). CGH
seeks money damages in excess of $25,000 from the Hilb Group. (Id., Ex. 1, p. 8).
CGH’s Missouri Petition further states that Counts II and III, which are brought
against Doctors Direct/PracticeProtection, “are pleaded hypothetically and in the
alternative to Count I.” (Id.). CGH alleges that Doctors Direct/PracticeProtection
breached its contract with CGH to insure, cover, indemnify, and/or defend the St.
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 18 of 28 Page ID
#<pageID>

Page 19 of 28
Clair County medical malpractice lawsuits (Count II), and seeks money damages in
the amount of $25,000, attorney fees and costs, and a finding that PracticeProtection
breached its contract with CGH. (Id., Ex. 1, pp. 8−9). CGH further alleges that
PracticeProtection violated M O. REV . STAT . §§ 375.296 and 375.240 by vexatiously
refusing to pay insurance benefits (Count III). (Id., Ex. 1, p. 9).
As both parties note, Veronica Douglas, Vickie and Efrain Franco, and Robert
and Melissa Porter are not named parties to the Missouri lawsuit. (See Doc. 34, p. 4;
Doc. 39, p. 6). Defendant CGH, in its Motion to Dismiss, argues that abstention is
still appropriate here because they are not necessary parties to the Missouri suit.
(Doc. 34, p. 4). The individual Defendants, CGH argues, have a mere expectancy or
future contingent interest by manner of their allegations in their underlying medical
malpractice claims, and thus, are not required to be joined by law. (Id.). Plaintiff
Practice Protection argues in opposition to the Motion to Dismiss that underlying
claimants are indeed necessary parties to litigation regarding insurance coverage,
and 	because 	they 	are 	not 	parties 	in 	St. 	Louis 	County, 	not 	all 	interests 	are
satisfactorily 	adjudicated 	in 	the 	state 	court 	proceeding. 	(Doc. 	39, 	pp. 	7−8).
Accordingly, PracticeProtection argues, abstaining from the present matter is not
appropriate because the parallel suits are not substantially the same. (See id.).
“[T]he 	Wilton/Brillhart 	abstention 	doctrine 	appropriately 	applies 	in 	a
diversity case where a declaratory judgment is sought and a parallel state proceeding
also exists.” Envision Healthcare, Inc., 604 F.3d at 986 (citing Wilton, 515 U.S. at 283;
Provident Tradesmens Bk. & Tr. Co. v. Patterson, 390 U.S. 102, 126 (1968)). A
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 19 of 28 Page ID
#<pageID>

Page 20 of 28
threshold requirement for Wilton-Brillhart abstention is the existence of parallel
proceedings. “Two actions are parallel when substantially the same parties are
contemporaneously litigating substantially the same issues in two fora.” Envision
Healthcare, Inc., 604 F.3d at 986 (citing Sta-Rite Indus., Inc. v. Allstate Ins. Co., 96
F.3d 281, 287 (7th Cir. 1996)). The district court’s inquiry should focus on “whether
the questions in controversy between the parties to the federal suit, and which are
not foreclosed under the applicable substantive law, can better be settled in the
proceeding pending in the state court.” Hartford Fire Ins. Co. v. Williams Bros.
Constr., Inc., 149 F. Supp. 3d 1009, 1012 (C.D. Ill. 2016) (citing Brillhart, 316 U.S. at
495). Relevant factors include:
(a) The scope of the pending state court proceeding and the nature of the
defenses there,
(b) Whether the claims of all parties in interest can satisfactorily be
adjudicated in that proceeding,
(c) Whether necessary parties have been joined,
(d) Whether such parties are amenable to process in that proceeding,
and
(e) Whether going forward with the declaratory action will serve a useful
purpose in clarifying the legal obligations and relationships among
the parties or will merely amount to duplicative and piecemeal
litigation.
Id. (citing Brillhart, 316 U.S. at 495; Nationwide Ins., 52 F.3d at 692).
In 	Hartford 	Fire, 	the 	Central 	District 	of 	Illinois 	analyzed 	the 	factors
enumerated in Brillhart to determine abstention from a declaratory action brought
by an insurance provider was appropriate where there was a parallel state court
proceeding. See 149 F. Supp. 3d at 1014. In that matter, Hartford Fire Insurance
Company (“Hartford Fire”) brought a declaratory action against Defendants Williams
Brothers Construction Company, Inc. (“Williams Brothers”), The Pipco Companies,
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 20 of 28 Page ID
#<pageID>

Page 21 of 28
Ltd. (“Pipco”), Bituminous Casualty Corporation n/k/a Bitco General Insurance
Corporation (“Bitco”), and James Goff. Id. at 1010−11. Williams Brothers was a
general contractor who contracted with Pipco in working on repairing a building in
Urbana, Illinois. Id. at 1011. James Goff was an employee for Pipco who was injured
when he slipped on ice while on the job. Id. Goff sued Williams Brothers in the Circuit
Court of Champaign County in November 2014 seeking damages for his injuries on
the 	theory 	of 	Williams 	Brothers’ 	negligence 	(hereinafter 	referred 	to 	as 	the
“Underlying State Tort Claim”). Id. In August 2015, Williams Brothers filed a
declaratory judgment action in the Circuit Court for Madison County, Illinois, against
Hartford Fire Insurance Company, Pipco, and Goff (hereinafter referred to as the
“State Declaratory Action”); Williams Brothers sought a declaration that Hartford
had a duty to defend and indemnify Williams Brothers under an insurance policy for
injuries claimed by Goff in the Underlying State Tort Claim lawsuit. Id. Two months
later, in October 2015, Hartford filed a declaratory judgment action in the Central
District of Illinois against Williams Brothers, Pipco, Goff, and Bitco, seeking a
declaration that it did not have a duty to defend and indemnify Williams Brothers
(hereinafter referred to as the “Federal Declaratory Action”). Id. Bitco, Williams
Brothers’ insurer, was not a party to the Underlying State Tort Claim suit brought
by the injured employee nor to the State Declaratory Action; Hartford Fire had joined
Bitco in the Federal Declaratory Action litigation “solely as an interested party to be
bound by the judgment herein.” Id. at 1013.
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 21 of 28 Page ID
#<pageID>

Page 22 of 28
The 	Central District 	began 	its 	analysis 	under Brillhart 	by 	determining
whether the State Declaratory Action and the Federal Declaratory Action in Hartford
Fire were parallel proceedings. Id. at 1012. First, the court found that the issue in
both matters was the same, namely, whether Hartford Fire owed a duty to defend
and indemnify Williams Brothers in the Underlying State Tort Claim litigation. Id.
The court found that resolution of that question by the Circuit Court for Madison
County in the State Declaratory Action would resolve the present federal claim before
the Central District. Id. Hartford Fire, in opposition to abstention, argued that
because Bitco, Williams Brothers’ insurer, was not a party to the State Declaratory
Action, the two proceedings were not, in fact, parallel. Id. at 1013. The Central
District clarified that while indeed no claims were brought against Bitco in state
court, no claims were brought against Bitco in federal court, either—they were
present in the federal action for purposes of Hartford Fire’s desire for Bitco to be
bound by the federal judgment. Id. The court further concluded that the fact that
Bitco was not a party to the State Declaratory Action did not determine the outcome
of the court’s analysis of the two proceedings because Bitco’s presence or absence
would not change the “‘the substantial likelihood that the state court litigation will
dispose of all claims presented in the federal case.’” Id. (quoting Envision Healthcare,
Inc. v. PreferredOne Ins. Co., 604 F.3d 983, 986 (7th Cir. 2010)). In addition, the
Central District found that the Circuit Court for Madison County could satisfactorily
adjudicate the declaratory judgment action and determine Hartford Fire’s coverage
obligations to Williams Brothers with or without Bitco’s presence in the suit. Id.
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 22 of 28 Page ID
#<pageID>

Page 23 of 28
As to the other Brillhart factors, including whether the claims of all parties in
interest can satisfactorily be adjudicated in that proceeding, and whether necessary
parties have been joined, the Central District found these factors additionally favored
abstention. See id. at 1013. First, the Central District emphasized that Hartford Fire,
in opposing abstention, did not argue that Bitco could not be brought into the State
Declaratory Action by means available under the Illinois Rules of Civil Procedure,
nor had it asserted it had made attempts to bring in Bitco to that action.4 Id. Second,
the court stated that under Illinois law, a party is necessary in a suit when its
presence is required to (1) protect an interest which the absentee has in the subject
matter which would be materially affected by a judgment entered in their absence;
(2) reach a decision which will protect the interests of those who are before the court;
or (3) enable the court to make a complete determination of the controversy. Id. (citing
State Farm Fire & Cas. Co. v. John J. Rickhoff Sheet Metal Co., 914 N.E.2d 577 (Ill.
2009)). Thus, the Central District reasoned that “if Bitco has an interest that would
be affected by its absence, it could intervene; if Hartford [Fire] feels that joining Bitco
would protect its interest, Hartford [Fire] could join Bitco as a defendant; and if the
court finds that Bitco is necessary in order to make a complete determination, the
court may join them to the suit.” Id. Third, the Central District stated that Bitco may
not have been a necessary party to the State Declaratory Action because the interests
4 For instance, the Central District stated that the Circuit Court for Madison County could potentially
direct a party to be brought into the action if a complete determination of a controversy cannot be had
without them at any stage of the cause under 735 I LL . C OMP . STAT . 5/2−406 and 5/2−407; a defendant
could file a third-party complaint either within the time for filing an answer or by leave of court to
bring a party to the action under 735 I LL . C OMP . STAT . 5/2−406(b)); or Bitco could choose to intervene
in the action under 735 I LL . C OMP . STAT . 5/2−408.
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 23 of 28 Page ID
#<pageID>

Page 24 of 28
of Bitco and Williams Brothers, its insured, were the same in that action: for Hartford
Fire to be found liable for insurance obligations to Williams Brothers with respect to
the Underlying State Tort Claim litigation. Id. at 1014. As to the Brillhart factor of
whether the parties were amendable to the process in the state court proceeding, the
Central District noted that Hartford Fire also failed to argue that the state court
lacked jurisdiction over Bitco. Id. Finally, the Central District stated that it was in
no better position than the Circuit Court for Madison County to clarify the legal
obligations and relationships among the parties and, based on its analysis, concluded
that abstention was appropriate and dismissed the action. Id. at 1014−15.
Turning to the present matter, the legal question presented in the matter
Plaintiff 	PracticeProtection 	has 	brought 	before 	this 	Court 	is 	whether
PracticeProtection is obligated to defend and indemnify Center for Gastrointestinal
Health with respect to the underlying St. Clair County medical malpractice lawsuits,
which is also an issue presented before the Circuit Court for St. Louis County,
Missouri, in Counts II and III of the Petition brought there by CGH. In accordance
with the Central District’s reasoning, whether the underlying St. Clair County
plaintiffs are part of that suit does not change the “‘the substantial likelihood that
the state court litigation will dispose of all claims presented in the federal case.’”
Hartford Fire at 1013 (quoting Envision Healthcare, Inc., 604 F.3d at 986). In
addition, both CGH and PracticeProtection are parties to the St. Louis County
litigation as well as the instant litigation. Accordingly, this Court finds that the two
actions are parallel.
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 24 of 28 Page ID
#<pageID>

Page 25 of 28
As 	to 	the 	factors 	of 	whether 	the 	claims 	of 	all 	parties 	in 	interest 	can
satisfactorily be adjudicated in that proceeding, whether necessary parties have been
joined, and whether the parties are amenable to process in the state court proceeding,
the analysis is not as straightforward. As an initial matter, in the St. Louis County
lawsuit, CGH, an Illinois citizen, has haled the Hilb Group Central, LLC (a Missouri
citizen), and PracticeProtection (potentially an Illinois or a Florida citizen, depending
on the application of Missouri law) into Missouri Court. CGH’s first claim is a
Missouri common law claim for breach of fiduciary duty against the Hilb Group
Central, LLC, its insurance broker. (Doc. 34, Ex. 1, pp. 5−7). Count II is a breach of
contract claim by CGH against PracticeProtection, which PracticeProtection asserts
is governed by Illinois law per a choice of law provision in the insurance agreement.
(Id., Ex. 1, pp. 8−9; Doc. 39, p. 7, n.1). CGH seeks damages in excess of $25,000 and
a finding that PracticeProtection breached its insurance agreement. (Id.). And, in
Count III, CGH brings a claim for vexatious refusal to pay against PracticeProtection
under MO. R EV . STAT . §§ 375.296 and 375.240. (Id., Ex. 1, p. 9). As to the breach of
contract claim in which PracticeProtections’ obligation to defend and indemnify CGH
would be determined, it is not immediately clear to this Court which state’s law the
Missouri Circuit Court will apply under its choice of law analysis or whether it would
determine the choice of law provision to be binding. The Court finds that this
uncertainty supports keeping the action in federal court under the Wilton-Brillhart
analysis.
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 25 of 28 Page ID
#<pageID>

Page 26 of 28
As to the Brillhart factor of whether the claims of all parties in interest can
satisfactorily be adjudicated in that proceeding, PracticeProtection claims that the
underlying tort claimants cannot be brought into the Missouri action because they
are not amenable to process in that court, which differentiates this case from Hartford
Fire. 	For 	example, 	upon 	a 	reading 	of 	Missouri’s 	long-arm 	statute, 5 it 	is 	not
immediately clear to this Court whether the Francos, the Porters, or Douglas are
amenable to process in Missouri courts. CGH has not argued in its Motion to Dismiss
that the individual defendants are amenable to process in Missouri. The Court finds
that this uncertainty additionally supports keeping the action in federal court.
PracticeProtection also argues in opposition to dismissal that the Francos, the
Porters, and Douglas are necessary parties to the Missouri action. The individual
Defendants, CGH argues, have a mere expectancy or future contingent interest by
manner of their allegations in their underlying medical malpractice claims, and thus,
are not required to be joined by law. (Doc. 38). However, this argument is not
consistent with Illinois law, which states that the tort claimant is a necessary party
5 Missouri’s long-arm statute provides:
“Any person or firm, whether or not a citizen or resident of this state, or any corporation, who
in person or through an agent does any of the acts enumerated in this section, thereby submits
such person, firm, or corporation, and, if an individual, his personal representative, to the
jurisdiction of the courts of this state as to any cause of action arising from the doing of any of
such acts:
(1) 	The transaction of any business within this state;
(2) 	The making of any contract within this state;
(3) 	The commission of a tortious act within this state;
(4) 	The ownership, use, or possession of any real estate situated in this state;
(5) 	The contracting to insure any person, property or risk located within this state
at the time of contracting;
(6) 	Engaging in an act of sexual intercourse within this state with the mother of a
child on or near the probable period of conception of that child.
MO. R EV. STAT . 506.500.1.
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 26 of 28 Page ID
#<pageID>

Page 27 of 28
to a suit to determine coverage. See Great West Gas. Co. v. Mayorga, 342 F.3d 816,
817 (7th Cir. 2003) (interpreting Illinois law). Moreover, CGH does not argue that it
is in a position to adequately represent the interests of the Francos, the Porters, or
Douglas in the Missouri action. CGH and the underlying tort claimants are not in
privity of contract such that their interests are identical; they are, in fact, opposing
parties in the underlying St. Clair County litigation in which they seek to hold CGH
liable for injuries sustained while in care at their facility. Thus, unlike in the Hartford
Fire case, in which the Central District concluded that the absent party may not have
been a necessary party because its interests were adequately represented by another
party in the action, the Court cannot readily reach the same conclusion here. In light
of this, under the Wilton-Brillhart analysis, the Court finds that this factor, too,
favors keeping the action in federal court.
Accordingly, based on the foregoing analysis, the Court finds that abstention
pursuant to the Wilton-Brillhart doctrine is not appropriate in this matter due to the
complex procedural nature and the interests at stake. This Court, in exercising its
discretion under the Declaratory Judgment Act, finds that reaching a judgment on
the merits of this matter is warranted and will not abstain from reaching the merits
of the matter despite parallel state court proceedings.
C ONCLUSION
For the reasons set forth above, Defendant Veronica Douglas's Motion to
Dismiss for Lack of Subject Matter Jurisdiction (Doc. 28) is DENIED, and Defendant
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 27 of 28 Page ID
#<pageID>

Page 28 of 28
Center for Gastrointestinal Health, S.C.’s Motion to Dismiss Based on Brillhart
Abstention (Doc. 34) is DENIED.
IT IS SO ORDERED.
DATED: January 7, 2026
s/ Stephen P. McGlynn
STEPHEN P. McGLYNN
U.S. District Judge
Case 3:25-cv-00784-SPM Document 41 Filed 01/07/26 Page 28 of 28 Page ID
#<pageID>