UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF MICHIGAN 

JACQUELINE SZAFRANSKI, 

Plaintiff, 

v. 

DELBERT SERVICES CORPORATION, 

Defendant. 

Gary D. Nitzkin (P41155) 

LAW OFFICES OF NITZKIN & ASSOCIATES 

Attorneys for Jacqueline Szafranski 

22142 W. Nine Mile Road 

Southfield, MI 48033 

(248) 353-2882 

gary@micreditlawyer.com 

TO: Clerk ofthe Court 

CASE NO.-------

Lower Court Case No. 14-11197-GC 

HON. ___________ __ 

NOTICE OF REMOVAL 

Randall J. Groendyk (P37196) 

VARNUMLLP 

Attorneys for Delbert Services Corporation 

Bridgewater Place 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

(616) 336-6000 

rj groendyk@varnumlaw.com 

Jacqueline Szafranski 

c/o Nitzkin & Associates 

22142 W. Nine Mile Road 

Southfield, MI 48033 

PLEASE TAKE NOTICE pursuant to 28 U.S.C. §§ 1232, 1441(a) and (b) and 1446(a), 

(b), and (d), the above-captioned case has been removed by Defendant Delbert Services 

Corporation, to the United States District Court for the Eastern District of Michigan, for the 

following reasons: 

1. This action was commenced in the 19th Judicial District Court, State ofMichigan, 

and was received by Defendant on October 14, 2014 (see Summons and Complaint, attached as 

Exhibit A). 

Case 2:14-cv-14288-GCS-MKM ECF No. 1 filed 11/06/14 PageID.1 Page 1 of 5
2. Pursuant to 28 U.S.C. § 1441(a), any civil action brought in a state court ofwhich 

the district court of the United States has original jurisdiction, may be removed by the Defendant 

to the district court of the United States for the district and division embracing the place where 

such action is pending. 

3. The 19th Judicial District Court in Dearborn, Michigan, is located within the 

jurisdiction of the United States Court for the Eastern District of Michigan. This Court is the 

Court embracing the place where the action is pending. 

4. This Complaint is removable to the United States District Court for the Eastern 

District of Michigan, from the 19th Judicial District Court for the State of Michigan, pursuant to 

28 U.S.C. §§ 1331, 1367, and 1441. 

5. Plaintiffs Complaint alleges that Defendant violated the Telephone Consumer 

Protection Act, 47 U.S.C. § 227. As such, this Court has federal jurisdiction over this action 

pursuant to 28 U.S.C. § 1331. 

6. This Notice of Removal is being filed within 30 days of the date upon which 

Defendant was served with a copy of the Summons and Complaint. 28 U.S.C. § 1446. 

7. Concurrently, Defendant has provided written notice ofthis Notice of Removal to 

Plaintiff, filing a copy with the Clerk of the 19th Judicial District Court for the State of 

Michigan, as required by 28 U.S.C. § 1446(d). 

2 

Case 2:14-cv-14288-GCS-MKM ECF No. 1 filed 11/06/14 PageID.2 Page 2 of 5
WHEREFORE, Defendant removes to this Court the above-entitled action, now pending 

in the 19th Judicial District Court, in the State of Michigan, action be placed on the docket of this 

Court for further proceedings as though this action had originally been instituted in this Court. 

Dated: November 6, 2014 

Respectfully submitted, 

VARNUMLLP 

By: Is/ Randall J. Groendyk 

Randall J. Groendyk (P37196) 

BUSINESS ADDRESS & TELEPHONE: 

Bridgewater Place 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

(616) 336-6000 

CERTIFICATE OF SERVICE 

The undersigned states that he served a copy ofthe Notice of Filing of Removal upon the 

following individual: 

Jacqueline Szafranski 

c/o Nitzkin & Associates 

22142 West Nine Mile Road 

Southfield, MI 48033 

by first class mail, with postage fully prepaid. 

I declare that the statements above are true to the best of my information, knowledge, and 

belief. 

Dated: November 6, 2014 Is/ Randall J. Groendyk 

Randall J. Groendyk (P3 7196) 

8860323 

3 

Case 2:14-cv-14288-GCS-MKM ECF No. 1 filed 11/06/14 PageID.3 Page 3 of 5
STATE OF MICHIGAN 

19TH JUDICIAL DISTRICT COURT 

JACQUELINE SZAFRANSKI, 

Plaintiff, 

v. 

DELBERT SERVICES CORPORATION, 

Defendant. 

Gary D. Nitzkin (P41155) 

LAW OFFICES OF NITZKIN & ASSOCIATES 

Attorneys for Jacqueline Szafranski 

22142 W. Nine Mile Road 

Southfield, MI 48033 

(248) 353-2882 

gary@,micreditlawyer.com 

TO: Clerk ofthe Court 

19th District Court 

16077 Michigan A venue 

Dearborn, MI 48126 

Case No. 14-11197-GC 

HON. SAM SALAMEY 

NOTICE OF FILING REMOVAL 

Randall J. Groendyk (P3 7196) 

VARNUMLLP 

Attorneys for Delbert Services Corporation 

Bridgewater Place 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

(616) 336-6000 

rj groendyk@varnumlaw.com 

Jacqueline Szafranski 

c/o Nitzkin & Associates 

22142 W. Nine Mile Road 

Southfield, MI 48033 

PLEASE TAKE NOTICE that on November 6, 2014, Defendant Delbert Services 

Corporation, filed the attached Notice of Removal with the United States District Court for the 

Eastern District of Michigan by which the above-captioned state court action was moved to 

federal court pursuant to 28 U.S.C. §§ 1441 and 1446. Pursuant to 28 U.S.C. § 1446(d), 

Defendant requests that this Court proceed no further, with respect to Defendant Delbert Services 

Corporation. 

Dated: November 6, 2014 

Respectfully submitted, 

VARNUMLLP 

dyk (P3 7196) 

BUSINESS ADDRESS & TELEPHONE: 

Bridgewater Place, P.O. Box 352 

Grand Rapids, MI 49501-0352 

(616) 336-6000 

8860505_1.docx 

Case 2:14-cv-14288-GCS-MKM ECF No. 1 filed 11/06/14 PageID.4 Page 4 of 5
STATE OF MICHIGAN 

19TH JUDICIAL DISTRICT COURT 

JACQUELINE SZAFRANSKI, 

Plaintiff, 

V. 

DELBERT SERVICES CORPORATION, 

Defendant. 

Gary D. Nitzkin (P41155) 

Case No. 14-11197-GC 

HON. SAM SALAMEY 

PROOF OF SERVICE 

Randall J. Groendyk (P3 7196) 

LAW OFFICES OF NITZKIN & ASSOCIATES VARNUMLLP 

Attorneys for Jacqueline Szafranski 

22142 W. Nine Mile Road 

Attorneys for Delbert Services Corporation 

Bridgewater Place 

Southfield, MI 48033 

(248) 353-2882 

gary({i)micreditlawyer.com 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

(616) 336-6000 

rj groendyk@varnumlaw.com 

I, Kelly Vadeboncoeur, am a legal secretary at Varnum, and state that on 6th day of 

November, 2014, I served Notice of Filing Removal, and a copy of this Proof of Service upon: 

Jacqueline Szafranski 

c/o Nitzkin & Associates 

22142 W. Nine Mile Road 

Southfield, MI 48033 

by putting a copy in a sealed envelope, addressed to each of the above-named individuals, and 

depositing it in our internal office mail pickup for delivery the same day with first-class postage 

fully prepaid thereon to the United States Post Office. 

I declare that the statements above are true to the best of my information, knowledge, and 

belief. 

](~adeboncoeur ~ 

8860604 

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