NOTICE OF REMOVAL – 1 FIDELITY NATIONAL LAW GROUP

1200 – 6TH AVENUE, SUITE 620

SEATTLE, WA 98101

(206) 223-4525

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Matthew R. Cleverley, OSB #93235

Fidelity National Law Group 

1200 – 6th Avenue, Suite 620

Seattle, WA 98101

(206) 223-4525, ext. 103

Matthew.Cleverley@fnf.com

Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

MEDFORD DIVISION

DONALD L. OLSON, as TRUSTEE OF THE 

OLSON LIVING TRUST,

Plaintiff,

v.

CHICAGO TITLE INSURANCE COMPANY, 

successor to TICOR TITLE INSURANCE 

COMPANY,

Defendant.

Case No. 1:15-cv-1692

NOTICE OF REMOVAL

(Josephine County Case #15-CV-20794)

TO: Clerk, United States District Court for the District of Oregon

And to: Plaintiff, DONALD L. OLSON, as TRUSTEE OF THE OLSON LIVING 

TRUST

And to: Carl A. Clyde, Esq., Attorney for Plaintiff

Defendant, Chicago Title Insurance Company (“CTIC”) hereby Removes the 

captioned cause, originally filed in Josephine County, Oregon Circuit Court, Case number 15-

CV-20794, to the United States District Court for the District of Oregon. CTIC Removes the 

case pursuant to 28 U.S.C. §1332 and 28 U.S.C. §1441(b), on the following grounds:

Case 1:15-cv-01692-CL Document 1 Filed 09/08/15 Page 1 of 4
NOTICE OF REMOVAL – 2 FIDELITY NATIONAL LAW GROUP

1200 – 6TH AVENUE, SUITE 620

SEATTLE, WA 98101

(206) 223-4525

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1. On or about August 6, 2015, Plaintiff filed a Complaint in Josephine County, 

Oregon Circuit Court, Case number 15-CV-207944. 

2. CTIC received a copy of the Summons and Complaint on August 13, 2015. This 

Notice of Removal is timely under 28 U.S.C. §1446(b) because it is within 30 days 

after CTIC received notice of the Summons and Complaint. 

3. Copies of all additional records and proceedings in the State Court will be filed 

together with the Verification of State Court Records as required by 28 U.S.C. 

§1446(a).

4. Plaintiff is a citizen of the State of Oregon. 

5. Defendant CTIC is a Nebraska corporation. 

6. CTIC is the only Defendant having been served with a summons and complaint in 

this action.

7. This action is a civil action of which this Court has original jurisdiction under 28 

U.S.C. §1332, and which may be removed to this court by Defendant CTIC 

pursuant to 28 U.S.C. §1441(b) as a civil action between citizens of different states 

and the matter in controversy exceeds the sum of $75,000 exclusive of interest and 

costs. 

8. The original case was filed in Josephine County, Oregon Circuit Court. 

Accordingly, this case should be assigned to the United States District Court for 

the District of Oregon, at Medford, pursuant to 12 U.S.C. §632 and Local Rule 3-

2(a).

Case 1:15-cv-01692-CL Document 1 Filed 09/08/15 Page 2 of 4
NOTICE OF REMOVAL – 3 FIDELITY NATIONAL LAW GROUP

1200 – 6TH AVENUE, SUITE 620

SEATTLE, WA 98101

(206) 223-4525

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9. CTIC will promptly file a copy of this Notice with Deschutes County Circuit

Court and all parties.

10. Pursuant to 28 U.S.C. §1332 and 28 U.S.C. 1441(b), no further action may occur 

in the state court unless and until the action is remanded.

Wherefore, Defendant CTIC respectfully gives notice that the above-entitled action is 

removed from the Deschutes County, Oregon Circuit Court to the U.S. District Court for the 

District of Oregon, Medford Division.

Dated: September 8, 2015 /s/ Matthew Cleverley

Matthew R. Cleverley, WSBA #32055

Fidelity National Law Group 

1200 – 6th Avenue, Suite 620

Seattle, WA 98101

(206) 223-4525, ext. 103

Matthew.Cleverley@fnf.com

Attorney for CTIC

Case 1:15-cv-01692-CL Document 1 Filed 09/08/15 Page 3 of 4
NOTICE OF REMOVAL – 4 FIDELITY NATIONAL LAW GROUP

1200 – 6TH AVENUE, SUITE 620

SEATTLE, WA 98101

(206) 223-4525

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CERTIFICATE OF SERVICE

The undersigned certifies under the penalty of perjury under the laws of the State of 

Washington that I am now and at all times herein mentioned, a citizen of the United States, a 

resident of the State of Washington, over the age of eighteen years, not a party to or interested 

in the above-entitled action, and competent to be a witness herein.

On the date given below I caused to be served the foregoing NOTICE OF REMOVAL

on the following individuals in the manner indicated:

Carl A. Clyde OSB #095782

Sorenson, Ransom & Ferguson, LLP

133 NW D Street

Grants Pass OR 97526

541-476-3883 – Phone

541-474-4495 – Fax

cclyde@roguevalleylaw.com

Attorney for Plaintiff

 X U.S. Mail, proper postage affixed

___ Legal Messenger

___ Facsimile

___ Hand Delivery

__X_ ECF/email

Dated: September 8, 2015 /s/ Matthew Cleverley

Matthew R. Cleverley, WSBA #32055

Case 1:15-cv-01692-CL Document 1 Filed 09/08/15 Page 4 of 4