UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION NETTIE B. WHITLOW, Plaintiff, Case No. 25-11458 v. Honorable Shalina D. Kumar Magistrate Judge Elizabeth A. Stafford VMC REO, LLC, et al., Defendants.

ORDER ADOPTING REPORT AND RECOMMENDATION (ECF NO. 24), AND DENYING PLAINTIFF’S MOTION FOR TEMPORARY RESTRAINING ORDER (ECF NO. 16)

Plaintiff Nettie Whitlow (“Whitlow”), proceeding pro se, initiated this case against multiple defendants alleging violations of her civil rights arising out of the alleged wrongful foreclosure of her home. ECF No. 1. This case was referred to the assigned magistrate judge for all pretrial matters pursuant to 28 U.S.C. § 636(b). ECF No. 4. Whitlow filed a motion for a temporary restraining order to enjoin further activity in the 14A District Court of Washtenaw County, Michigan eviction proceeding, because the eviction case had been removed to federal court. ECF No. 16. On July 30, 2025, the magistrate judge issued a Report and Recommendation (“R&R”). ECF No. 24. The R&R recommends Page 1 of 3 that Whitlow’s motion be denied because the eviction action was remanded to the state court. Id.

Whitlow did not file an objection to the R&R, and the time to do so has expired. See Fed. R. Civ. P. 72(b)(2). The failure to file a timely objection to an R&R constitutes a waiver of the right for further judicial review. See Thomas v. Arn, 474 U.S. 140, 150 (1985) (“It does not appear that Congress intended to require district court review of a magistrate’s factual or legal conclusion, under a de novo or any other standard, when neither party objects to those findings”); Smith v. Detroit Fed’n of Teachers, 829 F.2d 1370, 1373–74 (6th Cir. 1987) (failure to file objection to R&R “waived subsequent review of the matter”); Lardie v. Birkett, 221 F. Supp. 2d 806, 807 (E.D. Mich. 2002) (“As to the part of the report and recommendation to which no party has objected, the Court need not conduct a review by any standard.”). However, there is some authority that a district court is required to review the R&R for clear error. See Fed. R. Civ. P. 72 Advisory Committee Note Subdivision (b) (“When no timely objection is filed, the court need only satisfy itself that there is no clear error on the face of the record in order to accept the recommendation.”). Therefore, the Court has reviewed the R&R for clear error and finds none.

Page 2 of 3 Accordingly, the Court ADOPTS the R&R (ECF No. 24) and DENIES Whitlow’s motion for temporary restraining order (ECF No. 16).

IT IS SO ORDERED. s/ Shalina D. Kumar SHALINA D. KUMAR Dated: August 14, 2025 United States District Judge

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