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Case 3:13-cv-00943-RNC Document 1 Filed 07/03/13 Page 1 of 2

UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT



JURY TRIAL DEMANDED

CASE NO. 3:13 cv




GRETCHEN FERRANTE

v.

CONCORD SERVICING CORPORATION
D/B/A BLACKWELL RECOVERY










COMPLAINT


1.

This is an action pursuant to the Fair Debt Collection Practices Act

("FDCPA"), 15 U.S.C. §1692 et seq. and the Connecticut Creditors’ Collection Practices

Act, Conn. Gen. Stat. § 36a-645 et seq. (“CCPA”)

2.

3.

4.

This Court has jurisdiction. 15 U.S.C. §1692k and 28 U.S.C. §1331 and §1367.

Plaintiff is a natural person who resides in Branford Connecticut.

Defendant Concord is an independent accounts receivable servicing company that

provides a range of services, including billing, payment processing and receivables account

management to numerous clients. Concord services more than 600,000 accounts receivable

for its numerous clients.

5.

Plaintiff received a collection letter dated May 16, 2013, from an entity named

Blackwell Recovery regarding an alleged debt to her Condo Association.

6.

7.

8.

The letter was sent by Concord, although it did not mention or refer to Concord.

Blackwell and Concord are unknown to plaintiff.

Concord claims it need not be licensed as a Consumer Collection Agency by the

State of Connecticut, Department of Banking. Accordingly, it is a Creditor subject to the

CCPA.

Case 3:13-cv-00943-RNC Document 1 Filed 07/03/13 Page 2 of 2

9.

The Blackwell letter violates the express “true name” prohibitions of the FDCPA

and the CCPA.

WHEREFORE plaintiff respectfully requests this Court to:

1. Award plaintiff $1,000 statutory damages under each of the FDCPA and the

CCPA.

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

3. 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]