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Kevin C. Barrett, State Bar No. 020104

Amanda J. Taylor, State Bar No. 024006

Graif Barrett & Matura, P.C.

1850 North Central Avenue, Suite 500

Phoenix, Arizona 85004

Telephone: (602) 792-5700

Facsimile: (602) 792-5710

kbarrett@gbmlawpc.com

ataylor@gbmlawpc.com

Attorneys for Defendant American Family

Mutual Insurance Company 

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

TYLER JACOBSON, an individual,

Plaintiff,

v.

AMERICAN FAMILY MUTUAL. 

INSURANCE COMPANY, a foreign 

corporation; XYZ Corporations I-X; and

Partnerships I-X,

Defendants.

Case No.: 

NOTICE OF REMOVAL

Defendant American Family Mutual Insurance Company (“American Family”), by and 

through counsel undersigned, submits this Notice of Removal pursuant to 28 U.S.C. § 1446(a) and 

provides the following grounds for removal.

1. This matter was commenced in the Superior Court of the State of Arizona in and for 

the County of Maricopa on October 30, 2017 with the filing of a Complaint, Certificate of 

Arbitration, Demand for Jury Trial, and Offer of Judgment. 

2. The Summons, Affidavit of Service, Complaint, Certificate of Arbitration, Civil 

Cover Sheet, and Demand for Jury Trial constitutes all process and proceedings filed and served on 

American Family in the case, copies of which are attached hereto at Exhibit A.

3. Defendant American Family is a stock insurance company, whose parent company is 

AmFam Holdings, Inc., a wholly owned subsidiary of American Family Insurance Mutual Holding 

Case 2:17-cv-04373-GMS Document 1 Filed 11/29/17 Page 1 of 3
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Company, a domestic insurance holding company with its principal place of business and 

citizenship in the State of Wisconsin. Plaintiff Tyler Jacobson is a resident of the State of Arizona

(see Complaint, attached as Exhibit A).

4. This action is one over which the United States District Courts have jurisdiction 

pursuant to 28 USC § 1332, by reason of the diversity of the citizenship of the parties.

5. Defendant American Family has not pled, answered, or otherwise appeared in this 

action. 

6. Defendant American Family has filed this Notice within 30 days after receipt of the 

initial pleading setting forth the claim for relief upon which the action is based, and within one year 

after the commencement of the action. Removal is therefore timely pursuant to 28 U.S.C. § 

1446(b).

7. The amount in controversy exceeds the requisite $75,000. (See Complaint, attached 

as Exhibit A).

8. A copy of this Notice is being filed with the Clerk of the Superior Court of the State 

of Arizona in and for the County of Maricopa. 

WHEREFORE, Defendant American Family respectfully requests that this action be 

removed from the Superior Court of Arizona in and for the County of Maricopa to the United 

States District Court for the District of Arizona, and that further proceedings in the Superior Court 

of Arizona in and for the County of Maricopa regarding the action be stayed pursuant to 28 U.S.C. 

§ 1446.

/ / / /

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Dated this 29th day of November, 2017.

GRAIF BARRETT & MATURA, P.C.

By /s/ Kevin C. Barrett

Kevin C. Barrett

Amanda J. Taylor

1850 North Central Avenue, Suite 500

Phoenix, Arizona 85004

Attorneys for Defendant American Family 

Mutual Insurance Company

ORIGINAL e-filed on 

November 29th, 2017 with:

Clerk of the Court

Maricopa County Superior Court

101 West Jefferson Street

Phoenix, Arizona

COPY mailed this same date to:

Brett L. Slavicek

James E. Fucetola

Trevor R. Orme

The Slavicek Law Firm

5500 N. 24th Street

Phoenix, AZ 85016

Attorneys for Plaintiff

By: /s/Leanna Levine

Leanna Levine

Case 2:17-cv-04373-GMS Document 1 Filed 11/29/17 Page 3 of 3