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Nicholas R. Nowicki

AZ Lic. # 029740

McDonough & Nowicki PLLC

3011 36th Avenue South, #6

Minneapolis, MN 55406

Telephone: 612-217-0257

Email: nik@mcnowick.com

Of Counsel to:

Nitzkin & Associates

22142 West Nine Mile Road

Southfield, MI 48033

Telephone: (248) 353-2882

Facsimile: (248) 353-4840

Attorneys for Plaintiff,

Fred Crandell

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

Fred Crandell,

Plaintiff,

vs.

Experian Information Solutions, Inc.

an Ohio corporation; Trans Union, LLC,

a Delaware limited liability company;

Equifax Information Services, LLC, a 

Georgia corporation; Chase Bank USA, 

NA, a national association; Capital One 

Bank USA, NA, a national association;

Discover Financial Services, Inc., a 

Delaware corporation; and Synchrony 

Bank, an Ohio corporation,

Defendants.

Case No.: 

COMPLAINT

JURY TRIAL DEMANDED

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NOW COMES THE PLAINTIFF, FRED CRANDELL, BY AND THROUGH 

COUNSEL, Nicholas Nowicki, and for his Complaint against the Defendants, pleads

as follows:

JURISDICTION

1. Jurisdiction of this court arises under the Fair Credit Reporting Act (“FCRA”)

15 U.S.C. §1681p., and 28 U.S.C. §§1331, 1337.

2. This is an action brought by a consumer for violation of the Fair Credit 

Reporting Act (15 U.S.C. §1681 et seq. [hereinafter “FCRA”]).

VENUE

3. The transactions and occurrences which give rise to this action occurred in the 

City of Chandler, Maricopa County, Arizona. 

4. Venue is proper in the District of Arizona, Phoenix Division. 

PARTIES

5. The Defendants to this lawsuit are:

a. Experian Information Solutions, LLC, (“Experian”), an Ohio corporation 

that maintains a registered agent in Maricopa County, Arizona;

b. Trans Union, LLC, (“Trans Union”) which is an Delaware company that 

maintains a registered agent in Maricopa County, Arizona;

c. Equifax Information Services, LLC, (“Equifax”) which is a Georgia 

company that maintains a registered agent in Maricopa County, Arizona; 

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d. Chase Bank, USA, NA, (“Chase”) which is a national association that, 

conducts business in Wilmington, Delaware;

e. Capital One Bank, USA, NA (“Capital One”) which is an Ohio company 

that maintains a registered office in Richmond County, Virginia;

f. Discover Financial Services, Inc., (“Discover”), which is a Delaware 

corporation that maintains registered offices in Cook County, Illinois; 

and

g. Synchrony Bank (“Synchrony”), which is an Ohio corporation.

GENERAL ALLEGATIONS

6. The following furnishers are reporting their trade lines (“Errant Trade Lines”) 

on Plaintiff’s Experian, Trans Union and Equifax credit files with multiple 

charge offs in violation of the FCRA:

a. Chase, Account Number: 42668411XXXX;

b. Chase, Account Number: 42668411XXXX;

c. Discover, Account Number: 60110052XXXX;

d. SYNCB/Lowes, Account Number: 798192423523XXXX; and

e. Kohls/Capital One, Account Number: 639305042640XXXX.

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7. On or about May 29, 2015, Mr. Crandell obtained his Experian, Trans Union, 

and Equifax credit files and noticed that Chase, Discover, Synchrony Bank and 

Capital One were reporting multiple “KDs” meaning “Key Derogatory” on his 

credit files. 

8. On or about July 30, 2015, Mr. Crandell submitted letters to the CRAs 

disputing the Errant Trade Lines. 

9. Upon information and belief, Defendants Experian, Trans Union, and Equifax

forwarded Mr. Crandell’s dispute to Defendants Chase, Capital One, Discover, 

and Synchrony.

10. On or about August 24, 2015, Mr. Crandell received Equifax’s investigation 

results which showed that Chase retained multiple charge offs on both of its 

Errant Trade Lines. In addition, Capital One and Discover also retained the 

multiple charge offs on his Equifax credit file.

11.On or about august 25, 2015, Mr. Crandell received Experian’s investigation 

results which showed that Chase, Capital One, Synchrony, and Discover all 

retained the multiple charge offs on the Errant Trade Lines. 

12.On or about August 26, 2015, Mr. Crandell received Trans Union’s 

investigation results which also showed that Discover, Capital One, Synchrony

and Chase had retained the multiple charge offs on the Errant Trade Lines.

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COUNT I

NEGLIGENT VIOLATION OF THE FAIR CREDIT REPORTING ACT

BY CHASE

13.Plaintiff re-alleges the above paragraphs as if recited verbatim.

14.After being informed by Experian, Trans Union, and Equifax of the Plaintiff’s 

consumer dispute regarding the Errant Trade Lines, Chase Bank negligently 

failed to conduct a proper reinvestigation of Mr. Crandell’s dispute as required 

by 15 USC 1681s-2(b). 

15.Chase Bank negligently failed to review all relevant information available to it 

and provided by each credit reporting agency in conducting its reinvestigation 

as required by 15 USC 1681s-2(b). Specifically, it failed to direct Experian, 

Trans Union, and Equifax to remove the multiple charge offs from the Errant

Trade Lines from Mr. Crandell’s consumer credit reports.

16.The Errant Trade Lines are inaccurate and creating a misleading impression on 

Mr. Crandell’s consumer credit file with Experian, Trans Union, and Equifax to 

which it is reporting such trade line.

17.As a direct and proximate cause of Chase’s negligent failure to perform its 

duties under the FCRA, Mr. Crandell has suffered damages, mental anguish, 

suffering, humiliation, and embarrassment.

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18.Chase is liable to Mr. Crandell by reason of its violations of the FCRA in an 

amount to be determined by the trier fact, together with reasonable attorneys’ 

fees pursuant to 15 USC 1681o. 

19.Mr. Crandell has a private right of action to assert claims against Chase arising 

under 15 USC 1681s-2(b).

WHEREFORE, PLAINTIFF PRAYS that this court grant him a judgment 

against Chase for damages, costs, interest, and attorneys’ fees.

COUNT II

WILLFUL VIOLATION OF THE FAIR CREDIT REPORTING ACT BY

CHASE 

20.Plaintiff re-alleges the above paragraphs as if recited verbatim.

21.After being informed by Experian, Trans Union, and Equifax that Mr. Crandell

disputed the accuracy of the information it was providing, Chase willfully failed 

to conduct a proper reinvestigation of Mr. Crandell’s dispute. 

22.Chase willfully failed to review all relevant information available to it and 

provided by each such credit reporting agency as required by 15 USC 1681s2(b).

23.As a direct and proximate cause of Chase’s willful failure to perform its 

respective duties under the FCRA, Mr. Crandell has suffered damages, mental 

anguish, suffering, humiliation, and embarrassment.

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24.Chase is liable to Mr. Crandell for either statutory damages or actual damages 

he has sustained by reason of its violations of the FCRA in an amount to be 

determined by the trier fact, together with an award of punitive damages in the 

amount to be determined by the trier of fact, as well as for reasonable attorneys’ 

fees that he may recover therefore pursuant to 15 USC 1681n.

WHEREFORE, PLAINTIFF PRAYS that this court grant him a judgment 

against Chase for the greater of statutory or actual damages, plus punitive damages, 

along with costs, interest, and attorneys’ fees.

COUNT III

NEGLIGENT VIOLATION OF THE FAIR CREDIT REPORTING ACT

BY CAPITAL ONE

25.Plaintiff re-alleges the above paragraphs as if recited verbatim.

26.After being informed by Experian, Trans Union, and Equifax of the Plaintiff’s 

consumer dispute regarding the Errant Trade Line, Capital One negligently 

failed to conduct a proper reinvestigation of the Plaintiff's disputes as required 

by 15 USC 1681s-2(b). 

27.Capital One negligently failed to review all relevant information available to it 

and provided by each credit reporting agency in conducting its reinvestigation 

as required by 15 USC 1681s-2(b). Specifically, it failed to direct Experian, 

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Trans Union, and Equifax to remove the multiple charge offs from the Errant

Trade Line from Mr. Crandell’s consumer credit report.

28.The Errant Trade Line is inaccurate and creating a misleading impression on 

Mr. Crandell’s consumer credit file with Experian, Trans Union, and Equifax to 

which it is reporting such trade line.

29.As a direct and proximate cause of Capital One’s negligent failure to perform 

its duties under the FCRA, Mr. Crandell has suffered damages, mental anguish, 

suffering, humiliation, and embarrassment.

30.Capital One is liable to Mr. Crandell by reason of its violations of the FCRA in 

an amount to be determined by the trier fact, together with reasonable attorneys’ 

fees pursuant to 15 USC 1681o. 

31.Mr. Crandell has a private right of action to assert claims against Capital One

arising under 15 USC 1681s-2(b).

WHEREFORE, PLAINTIFF PRAYS that this court grant him a judgment 

against Capital One for damages, costs, interest, and attorneys’ fees.

COUNT IV

WILLFUL VIOLATION OF THE FAIR CREDIT REPORTING ACT BY

CAPITAL ONE

32.Plaintiff re-alleges the above paragraphs as if recited verbatim.

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33.After being informed by Experian, Trans Union, and Equifax that Mr. Crandell

disputed the accuracy of the information it was providing, Capital One willfully 

failed to conduct a proper reinvestigation of Mr. Crandell’s dispute. 

34.Capital One willfully failed to review all relevant information available to it and 

provided by each such credit reporting agency as required by 15 USC 1681s2(b).

35.As a direct and proximate cause of Capital One’s willful failure to perform its 

respective duties under the FCRA, Mr. Crandell has suffered damages, mental 

anguish, suffering, humiliation, and embarrassment.

36.Capital One is liable to Mr. Crandell for either statutory damages or actual 

damages he has sustained by reason of its violations of the FCRA in an amount 

to be determined by the trier fact, together with an award of punitive damages 

in the amount to be determined by the trier of fact, as well as for reasonable 

attorneys’ fees that he may recover therefore pursuant to 15 USC 1681n.

WHEREFORE, PLAINTIFF PRAYS that this court grant him a judgment 

against Capital One for the greater of statutory or actual damages, plus punitive 

damages, along with costs, interest, and attorneys’ fees.

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COUNT V

NEGLIGENT VIOLATION OF THE FAIR CREDIT REPORTING ACT

BY DISCOVER

37.Plaintiff re-alleges the above paragraphs as if recited verbatim.

38.After being informed by Experian, Trans Union, and Equifax of the Plaintiff’s 

consumer dispute regarding the Errant Trade Line, Discover negligently failed 

to conduct a proper reinvestigation of the Plaintiff's disputes as required by 15 

USC 1681s-2(b). 

39.Discover negligently failed to review all relevant information available to it and 

provided by each credit reporting agency in conducting its reinvestigation as 

required by 15 USC 1681s-2(b). Specifically, it failed to direct Experian, Trans 

Union, and Equifax to remove the multiple charge offs from the Errant Trade 

Line from Mr. Crandell’s consumer credit report.

40.The Errant Trade Line is inaccurate and creating a misleading impression on 

Mr. Crandell’s consumer credit file with Experian, Trans Union, and Equifax to 

which it is reporting such trade line.

41.As a direct and proximate cause of Discover’s negligent failure to perform its 

duties under the FCRA, Mr. Crandell has suffered damages, mental anguish, 

suffering, humiliation, and embarrassment.

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42.Discover is liable to Mr. Crandell by reason of its violations of the FCRA in an 

amount to be determined by the trier fact, together with reasonable attorneys’ 

fees pursuant to 15 USC 1681o. 

43.Mr. Crandell has a private right of action to assert claims against Discover

arising under 15 USC 1681s-2(b).

WHEREFORE, PLAINTIFF PRAYS that this court grant him a judgment 

against Discover for damages, costs, interest, and attorneys’ fees.

COUNT VI

WILLFUL VIOLATION OF THE FAIR CREDIT REPORTING ACT BY

DISCOVER

44.Plaintiff re-alleges the above paragraphs as if recited verbatim.

45.After being informed by Experian, Trans Union, and Equifax that Mr. Crandell

disputed the accuracy of the information it was providing, Discover willfully 

failed to conduct a proper reinvestigation of Mr. Crandell’s dispute. 

46.Discover willfully failed to review all relevant information available to it and 

provided by each such credit reporting agency as required by 15 USC 1681s2(b).

47.As a direct and proximate cause of Discover’s willful failure to perform its 

respective duties under the FCRA, Mr. Crandell has suffered damages, mental 

anguish, suffering, humiliation, and embarrassment.

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48.Discover is liable to Mr. Crandell for either statutory damages or actual 

damages he has sustained by reason of its violations of the FCRA in an amount 

to be determined by the trier fact, together with an award of punitive damages 

in the amount to be determined by the trier of fact, as well as for reasonable 

attorneys’ fees that he may recover therefore pursuant to 15 USC 1681n.

WHEREFORE, PLAINTIFF PRAYS that this court grant him a judgment 

against Discover for the greater of statutory or actual damages, plus punitive damages, 

along with costs, interest, and attorneys’ fees.

COUNT VII

NEGLIGENT VIOLATION OF THE FAIR CREDIT REPORTING ACT

BY SYNCHRONY

49.Plaintiff re-alleges the above paragraphs as if recited verbatim.

50.After being informed by Trans Union and Experian of the Plaintiff’s consumer 

dispute regarding the Errant Trade Line, Synchrony negligently failed to 

conduct a proper reinvestigation of the Plaintiff's dispute as required by 15 USC 

1681s-2(b). 

51.Synchrony negligently failed to review all relevant information available to it 

and provided by Trans Union and Experian in conducting its reinvestigation as 

required by 15 USC 1681s-2(b). Specifically, it failed to direct Trans Union 

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and Experian to remove the multiple charge offs from the Errant Trade Line

from Mr. Crandell’s consumer credit report.

52.The Errant Trade Line is inaccurate and creating a misleading impression on 

Mr. Crandell’s consumer credit file with Experian and Trans Union to which it 

is reporting such trade line.

53.As a direct and proximate cause of Synchrony’s negligent failure to perform its 

duties under the FCRA, Mr. Crandell has suffered damages, mental anguish, 

suffering, humiliation, and embarrassment.

54.Synchrony is liable to Mr. Crandell by reason of its violations of the FCRA in 

an amount to be determined by the trier fact, together with reasonable attorneys’ 

fees pursuant to 15 USC 1681o. 

55.Mr. Crandell has a private right of action to assert claims against Synchrony

arising under 15 USC 1681s-2(b).

WHEREFORE, PLAINTIFF PRAYS that this court grant him a judgment 

against Synchrony for damages, costs, interest, and attorneys’ fees.

COUNT VIII

WILLFUL VIOLATION OF THE FAIR CREDIT REPORTING ACT BY

SYNCHRONY

56.Plaintiff re-alleges the above paragraphs as if recited verbatim.

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57.After being informed by Experian and Trans Union that Mr. Crandell disputed 

the accuracy of the information it was providing, Synchrony willfully failed to 

conduct a proper reinvestigation of Mr. Crandell’s dispute. 

58.Synchrony willfully failed to review all relevant information available to it and 

provided by Trans Union and Experian as required by 15 USC 1681s-2(b).

59.As a direct and proximate cause of Synchrony’s willful failure to perform its 

respective duties under the FCRA, Mr. Crandell has suffered damages, mental 

anguish, suffering, humiliation, and embarrassment.

60.Synchrony is liable to Mr. Crandell for either statutory damages or actual 

damages he has sustained by reason of its violations of the FCRA in an amount 

to be determined by the trier fact, together with an award of punitive damages 

in the amount to be determined by the trier of fact, as well as for reasonable 

attorneys’ fees that he may recover therefore pursuant to 15 USC 1681n.

WHEREFORE, PLAINTIFF PRAYS that this court grant him a judgment 

against Synchrony for the greater of statutory or actual damages, plus punitive 

damages, along with costs, interest, and attorneys’ fees.

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COUNT IX

NEGLIGENT VIOLATION OF THE FAIR CREDIT REPORTING ACT

BY EXPERIAN

61.Plaintiff re-alleges the above paragraphs as if recited verbatim.

62.Defendant Experian prepared, compiled, issued, assembled, transferred, 

published, and otherwise reproduced consumer reports regarding Mr. Crandell

as that term is defined in 15 USC 1681a.

63.Such reports contained information about Mr. Crandell that was false, 

misleading, and inaccurate.

64.Experian negligently failed to maintain and/or follow reasonable procedures to 

assure maximum possible accuracy of the information it reported to one or 

more third parties pertaining to Mr. Crandell, in violation of 15 USC 1681e(b).

65. After receiving Mr. Crandell’s consumer dispute to the Errant Trade Lines, 

Experian negligently failed to conduct a reasonable reinvestigation as required 

by 15 U.S.C. 1681i.

66.As a direct and proximate cause of Experian’s negligent failure to perform its 

duties under the FCRA, Mr. Crandell has suffered actual damages, mental 

anguish and suffering, humiliation, and embarrassment.

67.Experian is liable to Mr. Crandell by reason of its violation of the FCRA in an 

amount to be determined by the trier fact, together with his reasonable 

attorneys’ fees pursuant to 15 USC 1681o. 

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WHEREFORE, PLAINTIFF PRAYS that the court grant him a judgment 

against Experian for actual damages, costs, interest, and attorneys’ fees.

COUNT X

WILLFUL VIOLATION OF THE FAIR CREDIT REPORTING ACT

BY EXPERIAN

68.Plaintiff re-alleges the above paragraphs as if recited verbatim.

69.Defendant Experian prepared, compiled, issued, assembled, transferred, 

published, and otherwise reproduced consumer reports regarding Mr. Crandell

as that term is defined in 15 USC 1681a.

70.Such reports contained information about Mr. Crandell that was false, 

misleading, and inaccurate.

71.Experian willfully failed to maintain and/or follow reasonable procedures to 

assure maximum possible accuracy of the information that it reported to one or 

more third parties pertaining to Mr. Crandell, in violation of 15 USC 1681e(b).

72. After receiving the Plaintiff’s consumer dispute to the Errant Trade Lines, 

Experian willfully failed to conduct a reasonable reinvestigation as required by 

15 U.S.C. 1681i.

73.As a direct and proximate cause of Experian’s willful failure to perform its 

duties under the FCRA, Mr. Crandell has suffered actual damages, mental 

anguish and suffering, humiliation, and embarrassment.

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74.Experian is liable to Mr. Crandell by reason of its violations of the FCRA in an 

amount to be determined by the trier of fact, together with his reasonable 

attorneys’ fees pursuant to 15 USC 1681n. 

WHEREFORE, PLAINTIFF PRAYS that this court grant him a judgment 

against Defendant Experian for the greater of statutory or actual damages, plus 

punitive damages along with costs, interest, and reasonable attorneys’ fees.

COUNT XI

NEGLIGENT VIOLATION OF THE FAIR CREDIT REPORTING ACT BY 

TRANS UNION

75.Plaintiff re-alleges the above paragraphs as if recited verbatim.

76.Defendant Trans Union prepared, compiled, issued, assembled, transferred, 

published, and otherwise reproduced consumer reports regarding Mr. Crandell

as that term is defined in 15 USC 1681a.

77.Such reports contained information about Mr. Crandell that was false, 

misleading, and inaccurate.

78.Trans Union negligently failed to maintain and/or follow reasonable procedures 

to assure maximum possible accuracy of the information it reported to one or 

more third parties pertaining to Mr. Crandell, in violation of 15 USC 1681e(b).

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79. After receiving Mr. Crandell’s consumer dispute to the Errant Trade Lines, 

Trans Union negligently failed to conduct a reasonable reinvestigation as 

required by 15 U.S.C. 1681i.

80.As a direct and proximate cause of Trans Union’s negligent failure to perform 

its duties under the FCRA, Mr. Crandell has suffered actual damages, mental 

anguish and suffering, humiliation, and embarrassment.

81.Trans Union is liable to Mr. Crandell by reason of its violation of the FCRA in 

an amount to be determined by the trier fact together with his reasonable 

attorneys’ fees pursuant to 15 USC 1681o. 

WHEREFORE, PLAINTIFF PRAYS that this court grant him a judgment 

against Trans Union for actual damages, costs, interest, and attorneys’ fees.

COUNT XII

WILLFUL VIOLATION OF THE FAIR CREDIT REPORTING ACT BY 

TRANS UNION

82.Plaintiff re-alleges the above paragraphs as if recited verbatim.

83.Defendant Trans Union prepared, compiled, issued, assembled, transferred, 

published and otherwise reproduced consumer reports regarding Mr. Crandell

as that term is defined in 15 USC 1681a.

84.Such reports contained information about Plaintiff that was false, misleading,

and inaccurate.

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85.Trans Union willfully failed to maintain and/or follow reasonable procedures to 

assure maximum possible accuracy of the information that it reported to one or 

more third parties pertaining to Mr. Crandell, in violation of 15 USC 1681e(b).

86. After receiving Mr. Crandell’s consumer dispute to the Errant Trade Lines, 

Trans Union willfully failed to conduct a reasonable reinvestigation as required 

by 15 U.S.C. 1681i.

87.As a direct and proximate cause of Trans Union‘s willful failure to perform its 

duties under the FCRA, Mr. Crandell has suffered actual damages, mental 

anguish and suffering, humiliation, and embarrassment.

88.Trans Union is liable to Mr. Crandell by reason of its violations of the FCRA in 

an amount to be determined by the trier of fact, together with his reasonable 

attorneys’ fees pursuant to 15 USC 1681n. 

1. WHEREFORE, PLAINTIFF PRAYS that this court grant him a judgment 

against Defendant Trans Union for the greater of statutory or actual damages, plus 

punitive damages along with costs, interest, and reasonable attorneys’ fees.

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COUNT XIII

NEGLIGENT VIOLATION OF THE FAIR CREDIT REPORTING ACT

BY EQUIFAX

89.Plaintiff re-alleges the above paragraphs as if recited verbatim.

90.Defendant Equifax prepared, compiled, issued, assembled, transferred, 

published, and otherwise reproduced consumer reports regarding Mr. Crandell

as that term is defined in 15 USC 1681a.

91.Such reports contained information about Mr. Crandell that was false, 

misleading, and inaccurate.

92.Equifax negligently failed to maintain and/or follow reasonable procedures to 

assure maximum possible accuracy of the information it reported to one or 

more third parties pertaining to Mr. Crandell, in violation of 15 USC 1681e(b).

93. After receiving Mr. Crandell’s consumer dispute to the Errant Trade Lines, 

Equifax negligently failed to conduct a reasonable reinvestigation as required 

by 15 U.S.C. 1681i.

94.As a direct and proximate cause of Equifax’s negligent failure to perform its 

duties under the FCRA, Mr. Crandell has suffered actual damages, mental 

anguish and suffering, humiliation, and embarrassment.

95.Equifax is liable to Mr. Crandell by reason of its violation of the FCRA in an 

amount to be determined by the trier fact, together with his reasonable 

attorneys’ fees pursuant to 15 USC 1681o. 

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WHEREFORE, PLAINTIFF PRAYS that the court grant him a judgment 

against Equifax for actual damages, costs, interest, and attorneys’ fees.

COUNT XIV

WILLFUL VIOLATION OF THE FAIR CREDIT REPORTING ACT

BY EQUIFAX

96.Plaintiff re-alleges the above paragraphs as if recited verbatim.

97.Defendant Equifax prepared, compiled, issued, assembled, transferred, 

published, and otherwise reproduced consumer reports regarding Mr. Crandell

as that term is defined in 15 USC 1681a.

98.Such reports contained information about Mr. Crandell that was false, 

misleading, and inaccurate.

99.Equifax willfully failed to maintain and/or follow reasonable procedures to 

assure maximum possible accuracy of the information that it reported to one or 

more third parties pertaining to Mr. Crandell, in violation of 15 USC 1681e(b).

100. After receiving the Plaintiff’s consumer dispute to the Errant Trade 

Lines, Equifax willfully failed to conduct a reasonable reinvestigation as 

required by 15 U.S.C. 1681i.

101. As a direct and proximate cause of Equifax’s willful failure to perform its 

duties under the FCRA, Mr. Crandlel has suffered actual damages, mental 

anguish and suffering, humiliation, and embarrassment.

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102. Equifax is liable to Mr. Crandell by reason of its violations of the FCRA 

in an amount to be determined by the trier of fact, together with his reasonable 

attorneys’ fees pursuant to 15 USC 1681n. 

WHEREFORE, PLAINTIFF PRAYS that this court grant him a judgment 

against Defendant Equifax for the greater of statutory or actual damages, plus punitive 

damages along with costs, interest, and reasonable attorneys’ fees.

JURY DEMAND

Plaintiff hereby demands a trial by Jury.

DATED: November 19, 2015 McDonough & Nowicki PLLC

By: /s/ Nicholas R. Nowicki 

Nicholas R. Nowicki

AZ Lic. # 029740

McDonough & Nowicki PLLC

3011 36th Avenue South, #6

Minneapolis, MN 55406

Telephone: 612-217-0257

Email: nik@mcnowick.com

Attorneys for Plaintiff,

Fred Crandell

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