Paros Properties LLC v. Colorado Cas. Ins. Co., — F.3d —, 2016 WL 4502286 (10th Cir. Aug. 29, 2016)

Evaluating whether notice of removal was timely, the Tenth Circuit held, as a matter of first impression, that a pre-suit communication referencing the amount of purported damages does not trigger the notice period for seeking removal from state to federal court, unless the communication is clearly incorporated into the complaint. At the same time, however, the Tenth Circuit held a state civil cover sheet indicating damages exceeded $100,000 triggered the time for filing a notice of removal.