IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS, 

EASTERN DIVISION 

TAWNE HEDGES, 

Plaintiff, 

vs. 

EMERGENT BUSINESS GROUP, INC., 

d/b/a EMERGENT SERVICING, 

Defendant. 

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Case No. 20-cv-2301 

NOTICE OF REMOVAL 

Defendant, Emergent Business Group, Inc. d/b/a Emergent Servicing (“Emergent”), 

through its counsel, Gordon Rees Scully Mansukhani, LLP, pursuant to 28 U.S.C. §§ 1331, 1391, 

1441, and 1446, hereby give notice of the removal of this lawsuit from the Circuit Court of Cook 

County, Chancery Division to the United States District Court for the Northern District of Illinois, 

Eastern Division. In support of this Notice of Removal, Emergent respectfully submits the 

following: 

1. On February 24, 2020, Plaintiff Tawne Hedges (“Plaintiff”) filed an action in the 

Circuit Court of Cook County, Chancery Division entitled Tawne Hedges v. Emergent Business 

Group, Inc., d/b/a Emergent Servicing, Case No. 2020 CH 02216. Plaintiff served Emergent with 

a copy of the Complaint on March 12, 2020. True and accurate copies of the Complaint and Proof 

of Service reflecting the service date are attached as Exhibit A. 

2. No other pleadings have been filed, entered, served, or issued at this time. 

3. Plaintiff’s Complaint asserts TCPA violations pursuant to 47 U.S.C. § 227 and this 

Court has original jurisdiction over such action. 

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4. Pursuant to 28 U.S.C. § 1391(b)(2), venue is proper in the United States District 

Court for the Northern District of Illinois, Eastern Division, as a substantial part of the alleged 

events giving rise to the Plaintiff’s claims purportedly occurred within this judicial district. 

5. Further, pursuant to 28 U.S.C. § 1446(a), this Notice of Removal is properly 

directed to this Court, as the United States District Court for the Northern District of Illinois, 

Eastern Division, is the District Court embracing the Circuit Court of Cook County, Illinois, where 

Plaintiff’s Complaint is currently pending. 

6. Pursuant to 28 U.S.C. § 1446(b), removal is timely because this Notice is being 

filed within 301 days of March 12, 2020, when Emergent was served with the Complaint. 

7. As required by 28 U.S.C. § 1446(d), Emergent has issued written notice of the filing 

of this Notice of Removal to Tawne Hedges, through his counsel and Emergent has filed this 

Notice of Removal with the Circuit Court of Cook County. 

WHEREFORE, pursuant to 28 U.S.C. §§ 1331, 1391, 1441, and 1446, Defendant 

Emergent Business Group, Inc. d/b/a Emergent Servicing, respectfully give notice that the above 

action, now pending against it in the Circuit Court of Cook County, Chancery Division, is removed 

to the United States District Court for the Northern District of Illinois, Eastern Division.

Respectfully submitted, 

GORDON REES SCULLY MANSUKHANI, LLP 

By: /s/ Avanti D. Bakane 

Attorneys for Defendant 

Emergent Business Group, Inc. 

d/b/a Emergent Servicing 

1 The 30 day computation from service is extended by Rule to April 13, 2020, as 30 days from service 

fell on a Saturday. Fed. R. Civ. P. 6(a)(1)(C) (“if the last day is a Saturday, Sunday, or legal holiday, 

the period continues to run until the end of the next day that is not a Saturday, Sunday, or legal 

holiday.”)

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Avanti D. Bakane, # 6299022 

Benjamin R. Kinney, # 6317720 

GORDON REES SCULLY MANSUKHANI, LLP 

One North Franklin, Suite 800 

Chicago, IL 60606 

Phone: (312) 565-1400 

Fax: (312) 565-6511 

abakane@grsm.com 

bkinney@grsm.com 

Case: 1:20-cv-02301 Document #: 1 Filed: 04/13/20 Page 3 of 4 PageID #:3
CERTIFICATE OF SERVICE 

I hereby certify that on April 13, 2020, a copy of the foregoing document was electronically 

filed and served to counsel of record via the Court’s CM/ECF PACER System and U.S. Mail as 

follows: 

Daniel Edelman 

Edelman, Combs, Latturner 

& Goodwin, LLC 

20 S. Clark Street, Suite 1500 

Chicago, Illinois, 60603 

courtecl@edcombs.com 

By: /s/ Avanti D. Bakane 

DPOCICA/51083521v.1 

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