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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

RYAN BOSHAW,

Plaintiff,

vs.

CBM SERVICES, INC.,

Defendant.

USDC Case No.: 

State Court Case No. 15-15145-GC

NOTICE OF REMOVAL

Defendant CBM Services, Inc. (“Defendant”), hereby provides notice of 

removal of this action from the 75th Judicial District Court for the State of 

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

pursuant to 28 U.S.C. §§ 1331, 1441 and 1446. In support of this removal,

Defendant states:

1. On or about May 20, 2015, Plaintiff Ryan Boshaw (“Plainitff”) filed 

the above captioned civil action in the 75th Judicial District Court for the State of 

Michigan (Case No.: 15-15145-GC).

2. Defendant was served with the Complaint on June 1, 2015. 

Accordingly, this Notice of Removal has been timely filed pursuant to 28 U.S.C. § 

1446(b).

3. This matter is a civil action over which this Court has original 

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jurisdiction under 28 U.S.C. § 1331, and is one which may be properly removed 

pursuant to 28 U.S.C. §§ 1441 and 1446, as the claims asserted in the Complaint 

arise under the laws of the United States and raise one or more federal questions.

4. Plaintiff’s complaint asserts violations of the Fair Debt Collection 

Practices Act (“FDCPA”), 15 U.S.C. § 1692 et seq.

5. The district courts of the United States have original jurisdiction in 

civil actions arising under the FDCPA.

6. Defendant removes this action to the United States District Court for 

the Eastern District of Michigan because it is the venue that encompasses Midland, 

Michigan. Defendant removes this action without prejudice to Defendant’s right to 

seek transfer of this action pursuant to 28 U.S.C. § 1404, if and as appropriate.

7. True and correct copies of the following are attached to this Notice of

Removal:

(a) all process, pleadings and orders which have been served 

upon Defendant in this action are attached to this filing in 

accordance with 28 U.S.C. § 1446(a) and this Court’s ECF 

guidelines; and

(b) the Notice of Filing of Notice of Removal which has been 

served upon Plaintiff and filed with the Clerk of Court for 

the 6th Judicial Circuit Court is also attached in accordance 

with 28 U.S.C. § 1446(d).

8. Based upon the foregoing, this action is removable on the basis of 

federal question jurisdiction pursuant to 28 U.S.C. §§ 1331, 1441 and 1446.

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WHEREFORE, Defendant CBM Services, Inc., requests that this action 

proceed in the United States District Court for the Eastern District of Michigan

unless or until remanded by further order of this Court. 

Respectfully Submitted,

/s/ Charity A. Olson

Charity A. Olson (P68295)

OLSON LAW GROUP

2723 S. State St., Suite 150

Ann Arbor, MI 48104

Tel: (734) 222-5179

Fax: (866) 941-8712

Dated: June 30, 2015 colson@olsonlawpc.com

CERTIFICATE OF SERVICE

I, Charity A. Olson, hereby certify that on June 30, 2015, a copy of the 

foregoing Notice of Removal was filed via the Court’s ECF system and served via 

first class and electronic mail on the following parties:

State of Michigan

75th Judicial Circuit Court 

301 W. Main St.

Midland, MI 48640

Ryan Boshaw

c/o Gary D. Nitzkin, Esq.

Nitzkin & Associates

22142 West Nine Mile Road, 

Southfield, MI 48033

/s/ Charity A. Olson 

Charity A. Olson

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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

RYAN BOSHAW,

Plaintiff,

vs.

CBM SERVICES, INC.,

Defendant.

State Court Case No. 15-15145-GC

NOTICE OF REMOVAL TO FEDERAL COURT

PLEASE TAKE NOTICE that Defendant CBM Services, Inc., has on this day provided

notice of removal of this action from the 75th Judicial District Court for the State of Michigan to 

the United States District Court for the Eastern District of Michigan pursuant to 28 U.S.C. §§ 

1331, 1441 and 1446, a copy of which is attached hereto. 

Pursuant to 28 U.S.C. § 1446 (b), all future proceedings in the 75th Judicial District Court 

for the State of Michigan are hereby stayed unless or until this action is remanded.

Respectfully Submitted,

/s/ Charity A. Olson

Charity A. Olson (P68295)

OLSON LAW GROUP

2723 S. State St., Suite 150

Ann Arbor, MI 48104

Tel: (734) 222-5179

Fax: (866) 941-8712

Dated: June 30, 2015 colson@olsonlawpc.com

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CERTIFICATE OF SERVICE

I, Charity A. Olson, hereby certify that on June 30, 2015, a copy of this Notice of 

Removal was filed via the Court’s electronic filing system and served via first class mail upon 

these parties:

State of Michigan

75th Judicial Circuit Court 

301 W. Main St.

Midland, MI 48640

Ryan Boshaw

c/o Gary D. Nitzkin, Esq.

Nitzkin & Associates

22142 West Nine Mile Road, 

Southfield, MI 48033

 

/s/ Charity A. Olson 

Charity A. Olson

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