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Legal Memorandum: ABC, Inc., was incorporated in the state of Delaware. It has a principal place of business in the state of Georgia.

On January 1, 2001, ABC, Inc., borrowed $50,000 from JoAnne Fields, a resident and citizen of Georgia, and $25,000 from Robert Fader, a resident and citizen of New York. ABC, Inc., executed and delivered notes (dated January 2, 2001) for the amounts of the loans, the notes being payable on or before June 30, 2006, and bearing simple interest at the rate of 12% per annum. The notes have not been paid.

JoAnne Fields and Robert Fader have contacted a partner of the law firm with which you are associated, to represent them in the collection of the amounts due. Prepare a memorandum for the partner addressing the following:

1. Definition of federal diversity jurisdiction. (5 points)
2. The determination of citizenship for diversity purposes insofar as it relates to the bringing of an action in the United States district court by JoAnne Fields against ABC, Inc. (10 points)
3. The determination of whether the amount in controversy, insofar as it relates to the claim of JoAnne Fields against ABC, Inc., is sufficient for the purposes of federal diversity jurisdiction. (10 points)
4. The determination of citizenship for diversity purposes insofar as it relates to the bringing of an action in the United States district court by Robert Fader against ABC, Inc. (10 points)
5. The determination of whether the amount in controversy, insofar as it relates to the claim of Robert Fader against ABC, Inc., is sufficient for the purposes of federal diversity jurisdiction. (10 points)
6. A determination of whether JoAnne Fields and Robert Fader can bring a single action in the United States district court against ABC, Inc., and whether they can, in said action, aggregate the claims to meet the requisite amount to be within the diversity jurisdiction of the United States district court. (10 points)