Product: Debt collection

XXXX, and XXXX XXXX Firm both XXXX Party Debt XXXX have each Violated FDCPA and Title XXXX on multiple occasions by filing suit and causing me to be served via process server/ summoned under duress without ever notifying me that either of them were ever attempting to collect a debt. The summons/ service of process was the very first communication I received from either XXXX or Kohn Law Firm. I ( Pro se ) am in current litigation with both of the companies who have failed to provide any evidence of a dunning letter nor other communication prior to service of summons nor has either company provided any contracts at all much less any that I am party to as evidence of standing to sue. XXXX and Kohn Law firms only 'evidence ' is a photocopy of a singular credit card statement, nothing more. 

Below are XXXX 's Title 15 and FDCPA violations, following are the violations of Kohn Lawfirm. 

XXXX violated Title 15 U.S.C. 1692d Harassment or Abuse, which states, A debt collector may not engage in any conduct the natural consequence of which is to harass, oppress, or abuse any person in connection with the collection of a debt. emphasis added. 
Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX letter, oral communication nor any notice of an attempt to collect a debt, instead choosing to directly send a process server, from which no summons was delivered. This is harassment and an abusive practice carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ). 

XXXX. XXXX violated Title 15 U.S.C. 1692g ( d ) Validation of Debts, which states, ( d ) Legal pleadings A communication in the form of a formal pleading in a civil action shall not be treated as an initial communication for purposes of subsection ( a ). emphasis added Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt. Counterclaim defendants initial communication was a summons/ service of process with formal pleading, as such, this is harassment, an unfair and abusive practice and unconscionable in nature carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C.1692k ( a ) ( 2 ) ( A ). 

XXXX. XXXX violated Title 15 U.S.C. 1692g ( c ) Validation of Debts, which states, ( c ) Admission of liability the failure of a consumer to dispute the validity of a debt under this section may not be construed by any court as an admission of liability by the consumer. emphasis added Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt. Counterclaim defendants initial communication was a summons/ service of process with formal pleading so therefore a court can not construe the failure of a consumer to dispute the validity of a debt as an admission of liability, as such, this is harassment, an unfair and abusive practice and unconscionable in nature carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C.1692k ( a ) ( 2 ) ( A ). 

XXXX. XXXX violated Title 15 U.S.C. 1692g ( b ) Validation of Debts, which states, ( b ) Disputed debts If the consumer notifies the debt collector in writing within the thirty-day period described in subsection ( a ) that the debt, or any portion thereof, is disputed, or that the consumer requests the name and address of the original creditor, the debt collector shall cease collection of the debt, or any disputed portion thereof, until the debt collector obtains verification of the debt or a copy of a judgment, or the name and address of the original creditor, and a copy of such verification or judgment, or name and address of the original creditor, is mailed to the consumer by the debt collector. Collection activities and communications that do not otherwise violate this subchapter may continue during the 30-day period referred to in subsection ( a ) unless the consumer has notified the debt collector in writing that the debt, or any portion of the debt, is disputed or that the consumer requests the name and address of the original creditor. Any collection activities and communication during the 30-day period may not overshadow or be inconsistent with the disclosure of the consumers right to dispute the debt or request the name and address of the original creditor. emphasis added. 
Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact Dunning Letter, oral communication nor any official notice of an attempt to collect a debt, as such, this is harassment, an unfair and abusive practice and unconscionable in nature carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ). 

XXXX. XXXX violated ( XXXX separate violations ) Title 15 U.S.C. 1692g ( a ) Validation of Debts, which states, ( a ) Notice of debt ; contents Within five days after the initial communication with a consumer in connection with the collection of any debt, a debt collector shall, unless the following information is contained in the initial communication or the consumer has paid the debt, send the consumer a written notice containing ( 1 ) the amount of the debt ; ( 2 ) the name of the creditor to whom the debt is owed ; ( 3 ) a statement that unless the consumer, within thirty days after receipt of the notice, disputes the validity of the debt, or any portion thereof, the debt will be assumed to be valid by the debt collector ; ( 4 ) a statement that if the consumer notifies the debt collector in writing within the thirty-day period that the debt, or any portion thereof, is disputed, the debt collector will obtain verification of the debt or a copy of a judgment against the consumer and a copy of such verification or judgment will be mailed to the consumer by the debt collector ; and ( 5 ) a statement that, upon the consumers written request within the thirty-day period, the debt collector will provide the consumer with the name and address of the original creditor, if different from the current creditor. emphasis added.

Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt, nor any communication containing ANY of the XXXX aforementioned stipulations in section a. Only upon counterclaim plaintiffs receipt of summons, mailed to plaintiff by the Court, were stipulations ( a1 ) and ( a2 ) revealed. Stipulations ( a3 ), ( a4 ) and ( a5 ) have yet to be communicated to counterclaim plaintiff by the counterclaim defendants, as such, this is harassment, an unfair and abusive practice and unconscionable in nature carrying a fine of {$1000.00} USD per missing stipulation ( {$5000.00} total ) as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ). 

XXXX. XXXX violated Title 15 U.S.C. 1692i ( a ) ( 2 ) ( B ) in conjunction with 15 U.S.C. 1692i ( b ) Legal actions by debt collectors, which states, ( a ) Venue Any debt collector who brings any legal action on a debt against any consumer shall ( XXXX ) in the case of an action to enforce an interest in real property securing the consumers obligation, bring such action only in a judicial district or similar legal entity in which such real property is located ; or ( XXXX ) in the case of an action not described in paragraph ( XXXX ), bring such action only in the judicial district or similar legal entity ( A ) in which such consumer signed the contract sued upon ; or ( B ) in which such consumer resides at the commencement of the action. 
b ) Authorization of actions Nothing in this subchapter shall be construed to authorize the bringing of legal actions by debt collectors. emphasis added Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt. Counterclaim defendants initial communication was a summons/ service of process with formal pleading. Living in specific county does not authorize suit to be filed without proper notice and compliance with standard debt collection practices, as such, this is harassment, an unfair and abusive practice and unconscionable in nature carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C.1692k ( a ) ( XXXX ) ( A ). 

XXXX. XXXX violated ( XXXX violation ) Title 15 U.S.C. 1692e ( 5 ) False or Misleading Representations, which states, The threat to take any action that can not legally be taken or that is not intended to be taken. Emphasis added.

Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt, counterclaim defendants caused process server to arrive at plaintiffs domicile on XX/XX/year> ( XXXX attempt ), no summons was left, only a scribbled solicitation note with unfamiliar name and number to call me back was stuck into a door, thus threatening to take legal action, without complying with required fair debt collection practices. This is false, deceptive and misleading because counterclaim plaintiff was not afforded proper notice of debt collection activity, carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C. 1692k ( a ) ( XXXX ) ( A ). 

XXXX. XXXX violated ( XXXX violation ) Title 15 U.S.C. 1692e ( 5 ) False or Misleading Representations, which states, The threat to take any action that can not legally be taken or that is not intended to be taken. Emphasis added. 
Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt, defendants caused a process server to arrive at counterclaim plaintiffs domicile a second time on XX/XX/year> ( XXXX attempt ), no summons was left nor notice of debt given, again threatening to take legal action, without following required fair debt collection practices, this time in front of a small audience causing undue stress, embarrassment and emotional harm to the counterclaim plaintiff and his wife. Counterclaim plaintiff was not afforded proper notice of debt collection activity, as such, this is abusive, false, deceptive and misleading debt collection activity, carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ). 

XXXX. XXXX violated ( XXXX violation ) Title 15 U.S.C. 1692e ( 5 ) False or Misleading Representations, which states, The threat to take any action that can not legally be taken or that is not intended to be taken. Emphasis added. 
Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt nor completing a XXXX service attempt via process server, counterclaim defendants caused a publication summons to publicly broadcast the alleged indebtedness of the counterclaim plaintiff, causing undue stress, embarrassment and emotional harm to the counterclaim plaintiff, his wife and family members. This is again, threatening to take legal action, without following required fair debt collection practices, this time in front of a large public audience. Counterclaim plaintiff was not afforded proper notice of debt collection activity, as such, this is abusive, false, deceptive and misleading debt collection activity, carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ). 

XXXX. XXXX violated Title 15 U.S.C. 1692e ( 11 ) False or Misleading Representations, which states, The use of any false representation or deceptive means to collect or attempt to collect any debt or to obtain information concerning a consumer. Emphasis added. 
Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt nor completing a XXXX service attempt via process server, counterclaim defendants filed suit against counterclaim plaintiff asserting counterclaim defendants have contracts, rights of collection and a debt owed to them by plaintiff without filing any proof of these documents. Counterclaim plaintiff was not afforded proper notice of debt collection activity, and counterclaim defendants have brought fraud before the court by asserting claims without evidence or affidavits, as such, this is abusive, false, deceptive and misleading debt collection activity, carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ). 

XXXX. XXXX violated Title 15 U.S.C. 1692e ( 10 ) False or Misleading Representations, which states, The failure to disclose in the initial written communication with the consumer and, in addition, if the initial communication with the consumer is oral, in that initial oral communication, that the debt collector is attempting to collect a debt and that any information obtained will be used for that purpose, and the failure to disclose in subsequent communications that the communication is from a debt collector, except that this paragraph shall not apply to a formal pleading made in connection with a legal action. Emphasis added. 
Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt nor completing a XXXX service attempt, counterclaim defendants filed suit against counterclaim plaintiff. Counterclaim defendants never provided any initial oral or written communication, much less any statement that the debt collector is attempting to collect a debt and that any information obtained will be used for that purpose. The first notice of this was upon counterclaim plaintiff receiving a copy of the filed summons in the mail from the XXXX on or about XX/XX/year>, as such, this is abusive, false, deceptive and misleading debt collection activity, carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ). 

XXXX. XXXX violated Title 15 U.S.C. 1692f ( 1 ) Unfair Practices, which states, A debt collector may not use unfair or unconscionable means to collect or attempt to collect any debt. Without limiting the general application of the foregoing, the following conduct is a violation of this section : ( XXXX ) The collection of any amount ( including any interest, fee, charge, or expense incidental to the principal obligation ) unless such amount is expressly authorized by the agreement creating the debt or permitted by law. emphasis added. 
Counterclaim plaintiff has no contract with counterclaim defendants and counterclaim defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt. Instead, the counterclaim defendants chose to directly send a process server to the counterclaim plaintiffs domicile on XXXX occasions, but leaving no documents. The summons arrived to the counterclaim plaintiffs house via postal mail from the XXXX on or about XX/XX/year> and within that summons included statements that the counterclaim defendants have contracts, rights to collection and debts owed to them without putting forth evidence of any contracts, any rights to collect nor any bona fide proof of any debt is owed to them by the counterclaim plaintiff, as such, this is harassment, an unfair and abusive practice and unconscionable in nature carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ). 

XXXX has itself violated Title 15 and FDCPA a total of XXXX times. 


The following are the independent Title 15 and FDCPA violations of Kohn Law Firm.

1. Kohn Law Firm violated Title 15 U.S.C. 1692d Harassment or Abuse, which states, A debt collector may not engage in any conduct the natural consequence of which is to harass, oppress, or abuse any person in connection with the collection of a debt. emphasis added.

Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX letter, oral communication nor any notice of an attempt to collect a debt, instead choosing to directly send a process server, from which no summons was delivered. This is harassment and an abusive practice carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ).

2. Kohn Law Firm violated Title 15 U.S.C. 1692g ( d ) Validation of Debts, which states, ( d ) Legal pleadings A communication in the form of a formal pleading in a civil action shall not be treated as an initial communication for purposes of subsection ( a ). emphasis added Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt. Counterclaim defendants initial communication was a summons/ service of process with formal pleading, as such, this is harassment, an unfair and abusive practice and unconscionable in nature carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C.1692k ( a ) ( 2 ) ( A ).

3. Kohn Law Firm violated Title 15 U.S.C. 1692g ( c ) Validation of Debts, which states, ( c ) Admission of liability the failure of a consumer to dispute the validity of a debt under this section may not be construed by any court as an admission of liability by the consumer. emphasis added Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt. Counterclaim defendants initial communication was a summons/ service of process with formal pleading so therefore a court can not construe the failure of a consumer to dispute the validity of a debt as an admission of liability, as such, this is harassment, an unfair and abusive practice and unconscionable in nature carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C.1692k ( a ) ( 2 ) ( A ).

4. Kohn Law Firm violated Title 15 U.S.C. 1692g ( b ) Validation of Debts, which states, ( b ) Disputed debts If the consumer notifies the debt collector in writing within the thirty-day period described in subsection ( a ) that the debt, or any portion thereof, is disputed, or that the consumer requests the name and address of the original creditor, the debt collector shall cease collection of the debt, or any disputed portion thereof, until the debt collector obtains verification of the debt or a copy of a judgment, or the name and address of the original creditor, and a copy of such verification or judgment, or name and address of the original creditor, is mailed to the consumer by the debt collector. Collection activities and communications that do not otherwise violate this subchapter may continue during the 30-day period referred to in subsection ( a ) unless the consumer has notified the debt collector in writing that the debt, or any portion of the debt, is disputed or that the consumer requests the name and address of the original creditor. Any collection activities and communication during the 30-day period may not overshadow or be inconsistent with the disclosure of the consumers right to dispute the debt or request the name and address of the original creditor. emphasis added. 
Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact Dunning Letter, oral communication nor any official notice of an attempt to collect a debt, as such, this is harassment, an unfair and abusive practice and unconscionable in nature carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ).

5. Kohn Law Firm violated ( 5 violations ) Title 15 U.S.C. 1692g ( a ) Validation of Debts, which states, ( a ) Notice of debt ; contents Within five days after the initial communication with a consumer in connection with the collection of any debt, a debt collector shall, unless the following information is contained in the initial communication or the consumer has paid the debt, send the consumer a written notice containing ( XXXX ) the amount of the debt ; ( XXXX ) the name of the creditor to whom the debt is owed ; ( XXXX ) a statement that unless the consumer, within XXXX days after receipt of the notice, disputes the validity of the debt, or any portion thereof, the debt will be assumed to be valid by the debt collector ; ( XXXX ) a statement that if the consumer notifies the debt collector in writing within the thirty-day period that the debt, or any portion thereof, is disputed, the debt collector will obtain verification of the debt or a copy of a judgment against the consumer and a copy of such verification or judgment will be mailed to the consumer by the debt collector ; and ( XXXX ) a statement that, upon the consumers written request within the thirty-day period, the debt collector will provide the consumer with the name and address of the original creditor, if different from the current creditor. emphasis added. 
Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt, nor any communication containing ANY of the XXXX aforementioned stipulations in section a. Only upon counterclaim plaintiffs receipt of summons, mailed to plaintiff by the Court, were stipulations ( a1 ) and ( a2 ) revealed. Stipulations ( a3 ), ( a4 ) and ( a5 ) have yet to be communicated to counterclaim plaintiff by the counterclaim defendants, as such, this is harassment, an unfair and abusive practice and unconscionable in nature carrying a fine of {$1000.00} USD per missing stipulation as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ).

6. Kohn Law Firm violated Title 15 U.S.C. 1692i ( a ) ( 2 ) ( B ) in conjunction with 15 U.S.C. 1692i ( b ) Legal actions by debt collectors, which states, ( a ) Venue Any debt collector who brings any legal action on a debt against any consumer shall ( 1 ) in the case of an action to enforce an interest in real property securing the consumers obligation, bring such action only in a judicial district or similar legal entity in which such real property is located ; or ( 2 ) in the case of an action not described in paragraph ( 1 ), bring such action only in the judicial district or similar legal entity ( A ) in which such consumer signed the contract sued upon ; or ( B ) in which such consumer resides at the commencement of the action.

b ) Authorization of actions Nothing in this subchapter shall be construed to authorize the bringing of legal actions by debt collectors. emphasis added Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt. Counterclaim defendants initial communication was a summons/ service of process with formal pleading. Living in XXXX XXXX does not authorize suit to be filed without proper notice and compliance with standard debt collection practices, as such, this is harassment, an unfair and abusive practice and unconscionable in nature carrying a fine of {$1000.00} USD as allowed by XXXX XXXX XXXX ( a ) ( XXXX ) ( A ). 

XXXX. XXXX XXXX XXXX violated ( XXXX violation ) Title XXXX XXXX. XXXX ( XXXX ) False or Misleading Representations, which states, The threat to take any action that can not legally be taken or that is not intended to be taken. Emphasis added. 
Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt, counterclaim defendants caused process server to arrive at plaintiffs domicile on XX/XX/year> ( XXXX attempt ), no summons was left, only a scribbled solicitation note with unfamiliar name and number to call me back was stuck into a door, thus threatening to take legal action, without complying with required fair debt collection practices. This is false, deceptive and misleading because counterclaim plaintiff was not afforded proper notice of debt collection activity, carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ).

8. Kohn Law Firm violated ( 2nd violation ) Title 15 U.S.C. 1692e ( 5 ) False or Misleading Representations, which states, The threat to take any action that can not legally be taken or that is not intended to be taken. Emphasis added. 
Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an intial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt, defendants caused a process server to arrive at counterclaim plaintiffs domicile a second time on XX/XX/year> ( XXXX attempt ), no summons was left nor notice of debt given, again threatening to take legal action, without following required fair debt collection practices, this time in front of a small audience causing undue stress, embarrassment and emotional harm to the counterclaim plaintiff and his wife. Counterclaim plaintiff was not afforded proper notice of debt collection activity, as such, this is abusive, false, deceptive and misleading debt collection activity, carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ).

9. Kohn Law Firm violated ( 3rd violation ) Title 15 U.S.C. 1692e ( 5 ) False or Misleading Representations, which states, The threat to take any action that can not legally be taken or that is not intended to be taken. Emphasis added. 
Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt nor completing a XXXX service attempt via process server, counterclaim defendants caused a publication summons to publicly broadcast the alleged indebtedness of the counterclaim plaintiff, causing undue stress, embarrassment and emotional harm to the counterclaim plaintiff, his wife and family members. This is again, threatening to take legal action, without following required fair debt collection practices, this time in front of a large public audience. Counterclaim plaintiff was not afforded proper notice of debt collection activity, as such, this is abusive, false, deceptive and misleading debt collection activity, carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ).

10. Kohn Law Firm violated Title 15 U.S.C. 1692e ( 11 ) False or Misleading Representations, which states, The use of any false representation or deceptive means to collect or attempt to collect any debt or to obtain information concerning a consumer. Emphasis added. 
Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt nor completing a XXXX service attempt via process server, counterclaim defendants filed suit against counterclaim plaintiff asserting counterclaim defendants have contracts, rights of collection and a debt owed to them by plaintiff without filing any proof of these documents. Counterclaim plaintiff was not afforded proper notice of debt collection activity, and counterclaim defendants have brought fraud before the court by asserting claims without evidence or affidavits, as such, this is abusive, false, deceptive and misleading debt collection activity, carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ).

11. Kohn Law Firm violated Title 15 U.S.C. 1692e ( 10 ) False or Misleading Representations, which states, The failure to disclose in the initial written communication with the consumer and, in addition, if the initial communication with the consumer is oral, in that initial oral communication, that the debt collector is attempting to collect a debt and that any information obtained will be used for that purpose, and the failure to disclose in subsequent communications that the communication is from a debt collector, except that this paragraph shall not apply to a formal pleading made in connection with a legal action. Emphasis added. 
Counterclaim Defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt nor completing a XXXX service attempt, counterclaim defendants filed suit against counterclaim plaintiff. Counterclaim defendants never provided any initial oral or written communication, much less any statement that the debt collector is attempting to collect a debt and that any information obtained will be used for that purpose. The first notice of this was upon counterclaim plaintiff receiving a copy of the filed summons in the mail from the XXXX on or about XX/XX/year>, as such, this is abusive, false, deceptive and misleading debt collection activity, carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ).

12. Kohn Law Firm violated Title 15 U.S.C. 1692f ( 1 ) Unfair Practices, which states, A debt collector may not use unfair or unconscionable means to collect or attempt to collect any debt. Without limiting the general application of the foregoing, the following conduct is a violation of this section : ( XXXX ) The collection of any amount ( including any interest, fee, charge, or expense incidental to the principal obligation ) unless such amount is expressly authorized by the agreement creating the debt or permitted by law. emphasis added. 
Counterclaim plaintiff has no contract with counterclaim defendants and counterclaim defendants violated FDCPA by not contacting counterclaim plaintiff with an initial contact XXXX XXXX, oral communication nor any official notice of an attempt to collect a debt. Instead, the counterclaim defendants chose to directly send a process server to the counterclaim plaintiffs domicile on XXXX occasions, but leaving no documents. The summons arrived to the counterclaim plaintiffs house via postal mail from the XXXX on or about XX/XX/year> and within that summons included statements that the counterclaim defendants have contracts, rights to collection and debts owed to them without putting forth evidence of any contracts, any rights to collect nor any bona fide proof of any debt is owed to them by the counterclaim plaintiff, as such, this is harassment, an unfair and abusive practice and unconscionable in nature carrying a fine of {$1000.00} USD as allowed by Title 15 U.S.C. 1692k ( a ) ( 2 ) ( A ).

**Kohn Law Firm has itself violated Title 15 and FDCPA a total of XXXX times.