Product: Debt collection

HARASSMENT BY A DEBT COLLECTOR AND DEBT COLLECTION AGENCY THAT HAS BEEN WILLFUL AND INTENTIONAL CAUSING HARM AND INJURIES TO RESPONDENT, HARASSMENT BY MCCALLA RAYMER LEIBERT PIERCE , LLC AND ITS MANAGING PARTNER ATTORNEY XXXX XXXX XXXX SINCE XXXX, SINCE AND TO DATE. COMPLAINANT IS RECEIVING THERATING TEXT MESSAGES, EMAILS AND PHONE CALLS AFTER XXXX PM. Harassment by Respondent that has been continuously and systematic before, since and to date and again on XX/XX/XXXX at XXXX XXXX  about via email attempting to get Complainant to vacate his home withing 60 days. Statement by Respondent on their website, Our litigators are not foreclosure attorneys. This is a foreclosure case, XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX There is no litigation between XXXX XXXX XXXX XXXX MCCALLA RAYMER LEIBERT PIERCE , LLC AND ITS MANAGING PARTNER ATTORNEY XXXX XXXX XXXX. XXXX IS HARASSING COMPLAINANT AND WILL NOT STOP. 

XXXX XXXX XXXX, ( hereinafter ) Complainant files his Complaint against, McCalla Raymer Leibert Pierce , LLC, its Managing Partner, Attorney XXXX XXXX XXXX, ( hereinafter ) Respondent, ( collectively ) Respondent for the unlawful misconduct and willful misconduct as follows : 1. Violation of the Cease-and-Desist request from Complaint that complied with the statutory requirements of Georgia Law and Federal Law. 
2. Violation of Regulation F, 3. Violation of 15 U.S. Code 1692c Communication in connection with debt collection that violated the Consumer Financial Protection Bureau and the Federal Trade Commission [ Federal Fair Debt Collection Practices Act ( FDCPA ) ] starting around and about XX/XX/XXXX to date that has been continuously and systematic causing harm, damages, injuries, monetary damages and mental pain and suffering. 
4. Harassment by Respondent that has been continuously and systematic before, since and to date and again on XX/XX/XXXX at XXXX XXXX about via email attempting to get Complainant to vacate his home withing 60 days. 
5. Civil conspiracy 6. Aiding and abetting fraud, 7. Fraud. 
8. Aiding and abetting Foreclosure Fraud PROCEDURAL HISTORY Respondent client is XXXX that is not in dispute. XXXX admitted to misapplying XXXX ( XXXX ) of Complainant mortgage payments that was received by XXXX, on-time and in full. XXXX has wrongfully maintained that Complainant has not made a payment since, XX/XX/XXXX, XX/XX/XXXX or XX/XX/XXXX and has been in default since. Respondent is factual incorrect. Even, if it was true, Courts recognize certain exceptions to the tender rule, such as when the borrower challenges the validity of the underlying debt, asserts a counterclaim or setoff against the beneficiary or demonstrates the deed of trust is void on its face. Complainant has correctly maintained that no sums were due under the notes involved because the notes were void and unenforceable and void on its face and is shown by affidavit ( XXXX ), direct evidence, factual evidence, competent evidence, and documentary evidence that is self-authenticating, that is not in dispute and on the record with the XXXX. 
Respondent client used another debt collection agency in Georgia. Respondent client XXXX was fined. Respondent was fined and banned. See The Consumer Financial Protection Bureau and the Federal Trade Commission that made it clear in F.T.C. v. XXXX, XXXX XXXX XXXX, XXXX ( XXXX XXXX ) ( citing 15 U.S.C. 45 ( a ) ) .See CONSUMER XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX. XXXX XXXX - Dist. Court, ND Georgia, XXXX. 

AIDING AND ABETTING FORECLOSURE FRAUD BY RESPONDENT MRLPs statement, As a recognized leader in the financial services industry, we meet these evolving client needs by providing high-quality, innovative, and efficient litigation services in a manner that reflects our commitment to integrity, professionalism, and excellence. XXXX XXXX XXXX XXXX XXXX is a team of dedicated, skilled and experienced litigators. Our litigators are not foreclosure attorneys who dabble in litigationwe are separate litigation departments comprised of true trial lawyers, with decades of combined experience handling thousands of trials and appeals of all kinds. Simply put, no other firm can offer the combination of XXXX default services expertise and true litigation capabilities. Respondent admitted, Our litigators are not foreclosure attorneys who dabble in litigation. Respondent is dabbling in litigation in a foreclosure action that violates the Consumer Financial Protection Bureau and the Federal Trade Commission. Respondent should be ban and fined as in CONSUMER FIN'L PROTECTION XXXX XXXX XXXX XXXX XXXX XXXX XXXX. XXXX XXXX - Dist. Court, ND Georgia, XXXX RESPONDENT LITIGATION IS AN ATTEMPT TO COLLECT AN ALLEGE DEBT In the instant complaint, Respondent has attempted to collect a allege debt directly and indirectly from Complainant. The Consumer Financial Protection Bureau and the Federal Trade Commission that made it clear in F.T.C. v. XXXX, XXXX XXXX XXXX, XXXX ( XXXX XXXX ) ( citing 15 U.S.C. 45 ( a ) ) .See CONSUMER XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX. XXXX XXXX - Dist. Court, ND Georgia, XXXX Respondent attempts to collect an allege debt directly and indirectly from Complainant viotated The Consumer Financial Protection Bureau and the Federal Trade Commission. 

Respondent is Aiding and abetting Foreclosure Fraud with their client " XXXX ''. 
Respondent Aiding and abetting fraud with their client " XXXX ''. 
Respondent has willfully misrepresented to the Court and Judge that Complainant has not made a payment since XX/XX/XXXX, XX/XX/XXXX or XX/XX/XXXX and has been in default since. Respondent is factual incorrect. Even, if it was true, Courts recognize certain exceptions to the tender rule. Complainant provided proof of payments to Respondent and Respondent continue to willfully and intentional harass Complainant. It is a fact, material fact and undisputed material fact the Tender Rule applies in Complainant foreclosure case because no sums were due, void and the Notes and Deed were unenforceable on its face in accordance with the Tender Rule.

Respondent was aware of the Tender Rule and continue to willfully and intentional harass Complainant. Respondent caused harm, damages, monetary damages, injuries, mental pain and suffering to Complainant. Respondent is liable as a result.

Respondent was asked again via email to stop harassing Complainant and has not stop.