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Jonathan A. Dessaules, State Bar No. 019439

DESSAULES LAW GROUP

5353 North 16th Street, Suite 110

Phoenix, Arizona 85016

Tel. 602.274.5400

Fax 602.274.5401

jdessaules@dessauleslaw.com

Local Counsel for Defendant 

Experian Information Solutions 

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

Andrew King,

Plaintiff,

v.

Experian Information Solutions, Inc.; 

Equifax, Inc.; TransUnion, LLC; and 

Portfolio Recovery Associates, LLC,

Defendants.

JOINT NOTICE OF REMOVAL

Pursuant to 28 U.S.C. § 1441, Defendants Experian Information Solutions, Inc. 

(“Experian”), Equifax, Inc. (“Equifax Inc.”), TransUnion LLC (“TransUnion”), and Portfolio 

Recovery Associates LLC (“PRA”), (collectively, “Defendants”) hereby file their Joint Notice 

of Removal of the above-captioned action to this Court and state as follows:

1. Experian, Equifax Inc., TransUnion, and PRA are named Defendants in Civil 

Action No. CC2015-159812 filed in the McDowell Mountain Justice Court for the State of 

Arizona, County of Maricopa (the “State Court Action”).

2. The Complaint in the State Court Action was filed with the Clerk of the 

McDowell Mountain Justice Court on September 4, 2015.

Case 2:15-cv-01964-JWS Document 1 Filed 10/01/15 Page 1 of 5
 

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

received a copy of Plaintiff’s initial pleading setting forth the claims for relief upon which 

Plaintiff’s action is based.

4. A copy of all process, pleadings, and orders served upon Defendants in the State 

Court Action is attached hereto as Exhibit A.

5. Experian is a corporation which, for monetary fees, regularly engages in whole or 

in part in the practice of assembling consumer credit information or other information on 

consumers for the purpose of furnishing consumer reports to third parties. Experian uses means 

or facilities of interstate commerce for the purpose of preparing or furnishing consumer reports, 

and therefore is a “consumer reporting agency” within the meaning of 15 U.S.C. § 1681a(f).

6. Equifax Inc. is a corporation headquartered in Georgia. Equifax Inc. is a holding 

company and has no income except for that derived from its ownership interests in its 

subsidiaries and affiliates. Equifax Inc. is not a “consumer reporting agency,” as that term is 

defined by the Fair Credit Reporting Act, does not maintain a database of consumer credit 

information, does not handle consumer credit files or issue consumer credit reports, and does not 

investigate consumer disputes regarding information in credit files. Equifax Inc. is not in the 

business of, and does not engage in the practice of, assembling or evaluating consumer credit 

information or any other information on consumers for the purpose of furnishing reports on such 

consumers to third parties.

7. TransUnion is a “consumer reporting agency” within the meaning of 15 U.S.C. 

§ 1681a(f).

8. PRA is a limited liability corporation which sometimes furnishes information to 

Experian, Equifax, and TransUnion regarding its accounts, and therefore is a “furnisher of 

information” within the meaning of 15 U.S.C. § 1681s-2.

9. The claims of relief against Experian, Equifax Inc., and TransUnion alleged in the 

State Court Action arise under the Fair Credit Reporting Act, 15 U.S.C. §§ 1681-1681u. Thus, 

Case 2:15-cv-01964-JWS Document 1 Filed 10/01/15 Page 2 of 5
 

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this Court has original subject matter jurisdiction over the above-captioned action pursuant to 28 

U.S.C. § 1331 and 15 U.S.C. § 1681p. The above-captioned action may properly be removed to 

this United States District Court pursuant to 28 U.S.C. § 1441(a) and (b). 

10. At the present time and at the time of the commencement of the State Court 

Action, Plaintiffs are and were individual citizens of the State of Arizona.

11. At the present time and at the time of the commencement of the State Court 

Action, Experian is and was a corporation incorporated under the laws of the State of Ohio with 

its principal place of business in Costa Mesa, California.

12. At the present time and at the time of the commencement of the State Court 

Action, Equifax Inc. is and was a corporation incorporated under the laws of the State of 

Georgia with its principal place of business in Atlanta, Georgia. 

13. At the present time and at the time of the commencement of the State Court 

Action, TransUnion is and was a corporation incorporated under the laws of the State of

Delaware with its principal place of business in Chicago, Illinois.

14. At the present time and at the time of the commencement of the State Court 

Action, PRA is and was a limited liability corporation formed under the laws of the State of 

Delaware with its principal place of business in Norfolk, Virginia.

15. All Defendants served with the Complaint in the State Court Action consent to 

and join in this Joint Notice of Removal.

16. Promptly after the filing of this Joint Notice of Removal, Defendants shall provide 

notice of the removal to Plaintiffs through their attorney of record in the State Court Action and 

to the clerk of the Court in the State Court action, as required by 28 U.S.C. § 1446(d).

///

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Case 2:15-cv-01964-JWS Document 1 Filed 10/01/15 Page 3 of 5
 

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Dated:October 1st, 2015 Respectfully submitted,

s/ Jonathan A. Dessaules

Jonathan A. Dessaules, State Bar No. 

019439

DESSAULES LAW GROUP

5353 North 16th Street, #110

Phoenix, AZ 85016

Telephone: (602) 274-5400

Facsimile: (602) 274-5401

Attorneys for Defendant

Experian Information Solutions, Inc.

Dated:October 1st, 2015 Respectfully submitted,

s/ Jacob C. Jones

Jacob C. Jones, State Bar No. 029971

SNELL & WILMER L.L.P.

One Arizona Center

400 E. Van Buren, Suite 1900

Phoenix, Arizona 85004-2202

Telephone: 602.382.6562

Facsimile: 602.382.6070

Email: jcjones@swlaw.com

Attorneys for Defendant

Equifax Inc. 

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Dated:October 1st, 2015 Respectfully submitted,

s/ Philip R. Wooten

Philip R. Wooten, State Bar No. 007006

PHILIP R. WOOTEN PC

3413 E. Equestrian Trail 

Phoenix, Arizona 85044

Telephone: (480) 598-4330

Facsimile: (480) 598-4331

Email: Philip.wooten@azbar.org

Attorneys for Defendant

TransUnion, LLC

Dated:October 1st, 2015 Respectfully submitted,

s/ Michael R. Ayers

Michael R. Ayers, State Bar No. 024318

HINSHAW & CULBERTSON, LLP

2375 East Camelback Road, Suite 750

Phoenix, AZ 85016

Telephone: (602) 631-4400

Facsimile: (602) 631-4404

Attorneys for Defendant

Portfolio Recovery Associates, LLC

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