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Jacob C. Jones (#029971)

SNELL & V/ILMER L.L.P.

One Arizona Center

40LE Van Buren, Suitç 1900

Phoenix, Arizona 85004-2202

Telephone : 602.382.6562

Facsimile: 602.382.6070

E-Mail : j cj ones @,swlaw. com

Attorneys for Defendant Equifax Inc

GEORGE KRZYSTOFCZYK and

DOLORES KRZYSTOFCZYK,

Plaintiff,

IN THE UNITED STATES DISTzuCT COURT

FOR THE DISTRICT OF ARIZONA

No.

NOTICE OF REMOVAL

DEER VALLEY CREDIT UNION,

EQUIFAX INC., and EXPERIAN

INFORMATION SOLUTIONS, INC.,

Defendants.

Defendant, Equifax Inc., by Counsel, hereby gives Notice of Removal of this

action from the Manistee Justice Court, Maricopa County, Arizona, wherein it is now

pending as Case No. CC15-178066, to the United States District Court for the District of

Arizona. This Notice of Removal is filed pursuant to 28 U.S.C. $$ 1441 and 1446. In

support hereof, Defendants show this Court as follows:

1. An action was filed on September 17,2015 inthe Manistee Justice Court,

Maricopa County, Arizona, entitled Krzystofczyk, et al. v. Deer Valley Credit Union, et al.

Case No. CC15-178066 (the "State Court Action").

2. Equifax Inc. was served with the Complaint on September 25,2015.

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

Equifax Inc. was served with a copy of Plaintifß' initial pleading setting forth the grounds

their action and their claims for relief.

v

22181403

Case 2:15-cv-02154-DLR Document 1 Filed 10/26/15 Page 1 of 3
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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"), âs 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. $ 1681þ), 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 f,tling of this Notice of Removal, Equifax Inc. shall give

written notice of the removal to Plaintiff and to the Manistee Justice Court, Maricopa

County, Arizona, as required by 28 U.S.C. $ 1446(d).

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

served upon Equifax Inc. in the State Court Action.

7. Attached hereto, as Exhibit 2, are copies of the Consent to Removal of codefendants Deer Valley Credit Union and Experian Information Solutions, Inc.

WHEREFORE, Equifax Inc. requests that the above-described action be removed

to this Court.

DATED this 26th day of October, 2015.

SNELL & V/ILMER L.L.P.

By: s/Jacob C. Jones

Jacob C. Jones

One Arizona Center

400 E. Van Buren, Suite 1900

Phoenix, Arizona 85004-2202

Attorneys for Plaintiff Equifax Inc.

LR Civ 3.6(b) Verification

I verifu that Exhibit 1 contains a true and correct copy of all pleadings and other

documents hfed in the State Court proceeding.

Dated: October 26,2015 By s/Jacob C. Jones

22181403

a,

Case 2:15-cv-02154-DLR Document 1 Filed 10/26/15 Page 2 of 3
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CERTIFICATE OF SERVICE

I hereby certit/ that on the 26th day of October, 2015,I electronically transmiued

the foregoing document and any attachments to the U.S. DistiiCt Court Clerk's Officè

using the CMÆCF System for filing and caused to be mailed via U.S. Mail, postage

prepaid, to the last known address of the parties or their attorneys, as follows:

Kevin Fallon McCarthy

er Blvd., Suite 320

Scottsdale, AZ 8525I

22781403

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Case 2:15-cv-02154-DLR Document 1 Filed 10/26/15 Page 3 of 3