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Case 3:13-cv-01017-WWE Document 1 Filed 07/16/13 Page 1 of 2

UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT





JURY TRIAL DEMANDED

CASE NO. 3:13 CV




CHRISTOPHER BURKI

v.

AMERASSIST A/R SOLUTIONS, INC.
CANNONDALE GENERATORS, INC.


















COMPLAINT

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

15 U.S.C. § 1692, and other applicable laws, including 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. Plaintiff is a resident of Westport CT.

4. Defendant Amerassist is licensed as a Consumer Collection Agency in Connecticut

and has been a member of a collectors’ trade association since 2005.

5. Defendant Cannondale is a Connecticut corporation located in Wilton Ct.

6. Defendants reported Mr. Burki’s debt to Cannondale to one or more credit bureaus

without reporting it as disputed even though they knew the account was disputed because it

was due to be paid by homeowner’s insurance, State Farm.

7. Cannondale promised to remove the account from credit reporting once paid by

State Farm, but once paid, refused do so.

8. Defendants did not report the account to credit bureaus as paid even after payment

was made in May, 2013.

9. In the collection efforts within one year prior to the date of this action, defendants

Case 3:13-cv-01017-WWE Document 1 Filed 07/16/13 Page 2 of 2

violated the FDCPA, or the parallel provisions of the CCPA.

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 as to Cannondale under 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









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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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