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
ORIONS MANAGEMENT GROUP, LLC
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
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
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
BY__/s/ Joanne S. Faulkner__
JOANNE S. FAULKNER ct04137
123 AVON STREET
NEW HAVEN, CT 06511-2422