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Case 3:13-cv-00948-VLB Document 1 Filed 07/05/13 Page 1 of 2

UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT





JURY TRIAL DEMANDED

CASE NO. 3:13 cv

COMPLAINT






SABLE HAILEY

v.

WINDSOR LAW, P.C.
UNITED CREDIT RECOVERY LLC










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

l5 U.S.C. § 1692; the Connecticut Creditor’s Collection Practices Act, Conn. Gen. Stat. §36a-

648 (“CCPA”), or the Connecticut Unfair Trade Practices Act ("CUTPA"), Conn. Gen. Stat.

§ 42-110a.

2. The Court has jurisdiction. 15 U.S.C. § 1692k and 28 U.S.C. §133l and § 1367.

3. Plaintiff is a natural person who has resided in Connecticut at all relevant times.

4. Plaintiff is a consumer within the FDCPA, in that the account involved in

defendants’ collection efforts arose out of a personal account with Wachovia Bank in the

amount of $138.18.

5. United Credit claims to have purchased plaintiff’s account after default. It assigned

the plaintiff’s account for collection to Windsor.

6. Windsor regularly collects consumer debts through the use of the telephone or mail.

7. Windsor has an office at 1801 International Parkway, 5th floor, Lake Mary FL

32746 which was not licensed as a consumer collection agency in compliance with chapter 669

Part XII of the Connecticut General Statutes In March, 2013, when communicating in

connection with efforts to collect plaintiff’s personal account.

8. Unlicensed collection activity violates the FDCPA. Goins v. JBC & Associates,

Case 3:13-cv-00948-VLB Document 1 Filed 07/05/13 Page 2 of 2

P.C., 352 F.Supp.2d 262 (D. Conn. 2005).

9. Windsor’s letter of March 19, 2013, obscured the notice required by §1692g.

10. In the collection efforts, the defendants violated the FDCPA, § 1692e, -f(1), or –

g.

WHEREFORE plaintiff respectfully requests this Court to:

1. Award plaintiff such damages as are permitted by law, both compensatory and punitive,

including $1,000 statutory damages against each defendant under the FDCPA;

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

3. Award such other and such 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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