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Case 3:13-cv-00721-WWE Document 1 Filed 05/18/13 Page 1 of 2

UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT



JURY TRIAL DEMANDED

CASE NO. 3:13 CV




ARTHUR GURDEK

v.

ORIONS MANAGEMENT GROUP, LLC
MARIA CRUZ














COMPLAINT



1. Plaintiff seeks relief pursuant to the Fair Debt Collection Practices Act (“FDCPA”),

15 U.S.C. § 1692, the Connecticut Creditor’s Collection Practices Act, Conn. Gen. Stat. §36a-

648 (“CCPA”), and the Connecticut Unfair Trade Practices Act, §42-110g (CUTPA).

2. The Court has jurisdiction. 15 U.S.C. § 1692k; 28 U.S.C. §1331, § 1367.

3. Defendant Orions is a California entity that sent a letter to plaintiff in Connecticut

seeking to collect a personal credit card originating with GE Money Bank.

4. Defendant Cruz is an active member of Orions, who supervises, controls, manages,

and participates in the debt collection efforts at issue herein.

5. Defendants regularly attempt, directly or indirectly, to collect consumer debts.

6. Defendants sent plaintiff a letter dated Friday April 12, 2013, requesting that the

full balance of the account be received in its office by Thursday, April 18, 2013.

7. The letter did not include the disclosures required by §1692g.

8. The letter implied that Orions was a collection agency acting for the Original

Creditor, in order to elicit payment of a presumably recognized account.

9. Orions has since revealed that it was the owner of the account, and the undisclosed

“current creditor.”

10. A consumer is more likely to make payment if the collector conceals that it is the

Case 3:13-cv-00721-WWE Document 1 Filed 05/18/13 Page 2 of 2

owner of the account rather than an unrecognized debt buyer whose ownership of the account

may be doubtful.

11. The amount demanded was substantially in excess of the amount charged off by the

original creditor.

12. In the collection efforts within one year prior to the date of this action, defendant

violated the FDCPA, § 1692e, –f(1), or –g and the parallel provisions of the CCPA

13. WHEREFORE plaintiff respectfully requests this Court to:

1. Award plaintiff such damages as are permitted by law, including $1,000 statutory damages

under the FDCPA, plus $1,000 statutory damages a the CCPA,

2. Award the plaintiff costs of suit and a reasonable attorney's fee.

2. Award such other and further relief as law or equity may provide

THE PLAINTIFF



BY__/s/ Joanne S. Faulkner__
JOANNE S. FAULKNER ct04137
123 AVON STREET
NEW HAVEN, CT 06511-2422
(203) 772-0395
[email protected]




































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