201497181.1 19933/158819

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

EMILY SHAW,

Plaintiff,

v.

EQUIFAX INFORMATION

SERVICES, LLC, and CONSUMERS

CREDIT UNION,

Defendants.

Civil Action No.:

Judge

Magistrate Judge

NITZKIN & ASSOCIATES

Gary D. Nitzkin

Travis Shackelford

22142 West Nine Mile Road

Southfield, MI 48033

(248) 353-2882

Email: gnitzkin@creditor-law.com

Attorneys for Plaintiffs

CLARK HILL PLC

Jordan S. Bolton

500 Woodward Avenue, Ste. 3500

Detroit, MI 48226-3435

(313) 965-8300

Email: JBolton@clarkhill.com

Attorneys for Equifax Information

Services LLC

NOTICE OF REMOVAL

Defendant, Equifax Information Services LLC (“Equifax”), by Counsel, and

hereby file this Notice of Removal of this action from the 74th District Court,

Michigan, wherein it is now pending as Case No. 14-8027-GC-DK, to the United

States District Court for the Eastern District of Michigan. This Notice of Removal

is filed pursuant to 28 U.S.C. §§ 1441 and 1446. In support hereof, Defendants

show this Court as follows:

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1. An action was filed on September 15, 2014 in the 74th District Court,

Michigan, entitled Shaw v. Equifax Information Services LLC, et al., Case No. 14-

8027-GC-DK (the “State Court Action”).

2. Equifax was served with the Complaint on September 29, 2014.

3. This Notice is being filed with this Court within thirty (30) days after

Equifax was served with a copy of Plaintiff’s initial pleading setting forth the

grounds for her action and her claims for relief.

4. This Court has original jurisdiction over this case pursuant to 28

U.S.C. § 1331, in that this is a civil action arising under the Constitution, laws or

treaties of the United States; specifically 15 U.S.C. § 1681 et seq., otherwise

known as the Fair Credit Reporting Act (“FCRA”), as follows:

(a) Plaintiff’s Complaint, on its face, alleges a violation of the FCRA.

(See Plaintiff’s Complaint).

(b) The FCRA, pursuant to 15 U.S.C. § 1681(p), provides that any action

alleging a violation of its provisions “may be brought in any appropriate United

States district court without regard to the amount in controversy . . .”

5. Promptly after the filing of this Notice of Removal, Equifax shall give

written notice of the removal to Plaintiff and to the Clerk of the 74th District Court,

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

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6. Attached hereto, as Exhibit A, are copies of the Summons and

Complaint served upon Equifax in the State Court Action.

WHEREFORE, Equifax requests that the above-described action be

removed to this Court.

Respectfully submitted this 17th day of October, 2014.

/s/Jordan S. Bolton

Jordan S. Bolton (P66309)

CLARK HILL, PLC

500 Woodward Avenue, Suite 3500

Detroit, MI 48226

Tel. (313) 965-8300

Fax (313) 965-8252

jbolton@clarkhill.com

Attorneys for Equifax Information Services

LLC

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201497181.1 19933/158819

CERTIFICATE OF SERVICE

I hereby certify that on the 17th day October, 2014, I electronically filed the

foregoing NOTICE OF REMOVAL with the Clerk of Court using the CM/ECF

system, and have sent a copy via U.S. Mail to the following:

Gary D. Nitzkin

Travis Shackelford

Nitzkin & Assoc.

22142 W. Nine Mile Rd.

Southfield, MI 48034

Attorneys for Plaintiffs

/s/Jordan S. Bolton

Jordan S. Bolton (P66309)

CLARK HILL, PLC

500 Woodward Avenue, Suite 3500

Detroit, MI 48226

Tel. (313) 965-8300

Fax (313) 965-8252

jbolton@clarkhill.com

Attorneys for Equifax Information Services

LLC

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