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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN (DETROIT)

__________________________________________________________________

PAUL TATSEOS and CASE NO. 2:15-cv-11351

EIJA TATSEOS,

Plaintiffs,

vs. Judge

 Magistrate Judge

TRANSUNION, LLC, 

Defendant.

__________________________________________________________________

TRANS UNION, LLC’S NOTICE OF REMOVAL

__________________________________________________________________

Pursuant to 28 U.S.C. §§ 1331, 1441, and 1446, Defendant Trans Union, 

LLC (“Trans Union”) hereby removes the subject action from the 52-3 District 

Court of Oakland County, Michigan to the United States District Court for the 

Eastern District of Michigan, on the following grounds:

1. Plaintiffs Paul Tatseos and Eija Tatseos served Trans Union on or 

about March 25, 2015, with a Complaint filed in the 52-3 District Court of 

Oakland County, Michigan. A copy of the Complaint is attached hereto, redacted 

pursuant to Federal Rule of Civil Procedure 5.2, as Exhibit A. No other process, 

pleadings or orders have been served on Trans Union.

2. Plaintiffs make claims under, allege that Trans Union violated and 

allege that Trans Union is liable under the Fair Credit Reporting Act, 15 U.S.C. § 

1681 et seq. (the “FCRA”). See Complaint ¶¶ 1-6, 14-34.

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3. This Court has original jurisdiction over the subject action pursuant to 

28 U.S.C. § 1331 since there is a federal question. As alleged, this suit falls within 

the FCRA which thus supplies this federal question.

4. Pursuant to 28 U.S.C. § 1441, et seq., this cause may be removed 

from the State 52-3 District Court of Oakland County, Michigan, to the United 

States District Court for the Eastern District of Michigan.

5. No other parties are named in the Complaint.

6. Notice of this removal will promptly be filed with the 52-3 District 

Court of Oakland County, Michigan and served upon all adverse parties.

WHEREFORE, Defendant Trans Union, LLC, by counsel, removes the 

subject action from the 52-3 District Court of Oakland County, Michigan to this 

United States District Court for the Eastern District of Michigan.

Date: April 14, 2015 Respectfully submitted,

s/ Scott E. Brady

Scott E. Brady, Esq. (IN #30534-49)

Schuckit & Associates, P.C.

4545 Northwestern Drive

Zionsville, IN 46077

Telephone: 317-363-2400

Fax: 317-363-2257

E-Mail: sbrady@schuckitlaw.com

Counsel for Defendant, Trans Union, LLC

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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN (DETROIT)

__________________________________________________________________

PAUL TATSEOS and CASE NO. 2:15-cv-11351

EIJA TATSEOS,

Plaintiffs,

vs. Judge 

 Magistrate Judge

TRANSUNION, LLC, 

Defendant.

__________________________________________________________________

CERTIFICATE OF SERVICE

__________________________________________________________________

I, Scott E. Brady, hereby certify that on the 14th day of April, 2015, I 

electronically filed the foregoing with the Clerk of the Court using the ECF 

systems which will automatically send notification of such filing to the following 

counsel of record:

None.

I further certify that on the 14th day of April, 2015, a copy of the foregoing 

was sent via U.S., First Class Mail, postage prepaid to the following non-ECF 

participants:

Pro Se Plaintiffs

Paul Tatseos and Eija Tatseos

905 Buckhorn Drive

Lake Orion, MI 48362

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s/ Scott E. Brady

Scott E. Brady, Esq. (IN #30534-49)

Schuckit & Associates, P.C.

4545 Northwestern Drive

Zionsville, IN 46077

Telephone: 317-363-2400

Fax: 317-363-2257

E-Mail: sbrady@schuckitlaw.com

Counsel for Defendant, Trans Union, LLC

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