Product: Debt collection

SUBJECT MATTER : TEXT MESSAGES OCCURED CLOSE TO XXXX MIDNIGHT AND AFTER XXXX WITHOUT A LEGAL BASIS OR LEGAL REASON FOR THE SOLE PURPOSE OF HARASSMENT. PLEASE SEE AFFIDAVIT OR RESPONDENT ADMISSION. 
McCalla Raymer Leibert Pierce , LLC, is a Law Firm-mill and its Managing Partner, Attorney XXXX XXXX XXXX XXXX XXXX like a mill and violated Federal Law and State Law in Georgia. There is no litigation in any Court between McCalla Raymer Leibert Pierce , LLC, and its Managing Partner, Attorney XXXX XXXX XXXX and Respondent can respond to this Complaint because there is no litigation involved with the subject matter, text messages. 
The Consumer Financial Protection Bureau and the Federal Trade Commission [ XXXX Fair Debt Collection Practices Act ( FDCPA ) ] violations here, arise out of litigation activities offered as part of Managing Partner Attorney XXXX XXXX XXXX practice of law which arguably occur exclusively within the Firms of McCalla Raymer Leibert Pierce , LLC relationship with its clients, particularly XXXX. Consumer Financial Protection Bureau ( CFPB ) filed a lawsuit in a federal district court against a XXXX firm, XXXX XXXX XXXX XXXX XXXX XXXX and its three principal partners for operating a debt collection lawsuit mill that uses illegal tactics to intimidate consumers into paying debts they may not owe. 
Complainant would like to direct the Consumer Financial Protection Bureau to the attachment and admission of McCalla Raymer Leibert Pierce , LLC the Law Firm-mill and its Managing Partner, Attorney XXXX XXXX XXXX XXXX XXXX texting Complainant : Also on Monday, XX/XX/XXXX, at XXXX p.m., Plaintiff sent me a text message that stated that he was adviced [ sic ] to grant the extension. I responded that I would prepare a consent order for Plaintiff to review Respondent willfully and intentionally misrepresented to the Consumer Financial Protection Bureau that, We are a law firm and not a collection agency which will contact borrowers within certain times of the day. There were no communications by text. The Consumer Financial Protection Bureau only need to look at the companys website to confirm McCalla Raymer Leibert Pierce , LLC is a debt collection agency. The misleading admission to Complainant and Public, " Pursuant to the Fair Debt Collection Practices Act, you are advised that this office may be deemed to be a debt collector and any information obtained may be used for that purpose is misleading and a material fact that is not in dispute. Respondent admission, There were no communications by text, is contradicted by Respondent own admission in the below Complaints and the attached affidavit that is not in dispute that communications by text occurred between Complainant and Managing Partner, Attorney XXXX XXXX XXXX. Furthermore, the text messages failed to identify the senders as debt XXXX, and XXXX received several text messages close to 12 midnight when XXXX was asleep. Respondent, Managing Partner, Attorney XXXX XXXX XXXX never received permission to text message Complainant and the Managing Partner, Attorney XXXX XXXX XXXX text message Complainant several times while he was working mostly from home and traveling a lot. There was no company phone at the airport ( s ) or at the hotel ( s ) for Managing Partner, Attorney XXXX XXXX XXXX to conduct McCalla Raymer Leibert Pierce , LLC business for their client ( s ). Communications by text occurred to respond in a timely manner. 
XXXX XXXX, Attorney XXXX XXXX XXXX admitted to the XXXX that he work mostly from home and travels a lot. But he did not disclose that none Attorneys at McCalla Raymer Leibert Pierce , LLC are researching his cases, drafting affidavits for him, drafting pleadings for him, signing those pleading for him and filing those pleadings and affidavits with the Court for him while he works mostly from home and travels a lot. 
It may be true, but not certain that McCalla Raymer Leibert Pierce , LLC, and its Managing Partner, Attorney XXXX XXXX XXXX is above the law, even after admitting to violations of the law both Federal and State. Complainant can only assume that the Consumer Financial Protection Bureau must have overlooked the admission and competent evidence on record that would allow the Consumer Financial Protection Bureau to enforce the unlawful violations that was willful. 
DEBT VAILIDATION LETTER : McCalla Raymer Leibert Pierce , LLC, and its Managing Partner, Attorney XXXX XXXX XXXX misrepresented to the Consumer Financial Protection Bureau that a debt validation letter was attached in a previous response. The debt validation letter will prove that Complainant was not in default when XXXX declared default. The debt validation letter is not on record with the XXXX and will prove that Respondent XXXX XXXX is improper. Furthermore, McCalla Raymer Leibert Pierce , LLC, and its Managing Partner, Attorney XXXX XXXX XXXX relieved Complainant of a legal duty to make payments and admitted that Complainant should hold any payments until XXXX decide what terms is required on a pre-approved Loan Modification and Settlement. 
Complainant was working in Florida in XXXX on a Friday when XXXX outside XXXX XXXX, XXXX XXXX XXXX XXXX XXXX XXXX XXXX Partner, Attorney XXXX XXXX XXXX XXXX XXXX from his cell phone and admitted Complainant should hold any payments until XXXX decide what terms is required on the pre-approved Loan Modification and Settlement. Complainant took good notes that day because he did not have permission to record Chase outside Law Firm-mill, XXXX XXXX XXXX XXXX XXXX XXXX XXXX Partner, Attorney XXXX XXXX XXXX XXXX Complainant is relieved of his financial obligations until a pre-approve XXXX XXXX and XXXX occurs with the terms and conditions that both parties can agree upon. The real reason Complainant account has been in default and been in default since, is because of XXXX continuous unfair business practice, XXXX declaring default in early XXXX for non-payment, when XXXX was not in default for non-payment that is shown by the record with the XXXX. Complainant has demonstrated his legal basis and reason for non-payment that is not in dispute. 
McCalla Raymer Leibert Pierce , LLC is a Law Firm-mill and admitted to Complainant that XXXX was working on a pre-approve Loan Modification and Settlement. The Law Firm-mill admitted that Complainant should hold any payments until XXXX decide what terms is required on a Loan Modification and Settlement. McCalla Raymer Leibert Pierce , LLC, and its Managing Partner, Attorney XXXX XXXX XXXX did not disclose this material fact to the Court and willfully misrepresented to the Court Complainant has not made a payment since XX/XX/XXXX. 
This Complaint is about the willful misrepresentation to the Consumer Financial Protection Bureau that there was no communication by text message that is factual incorrect. See Company responses : Company responded on XX/XX/XXXX -- -- - Complaint # XXXX MRLP does not have a practice, nor do we ever contact borrowers by text message. This allegation is false. 
XXXX responded on XX/XX/XXXX -- -- Complaint # XXXX MRLP was not named in this lawsuit. XXXX does not have a practice, nor do we ever contact borrowers by text message. This allegation is false. In addition, MRLP does not have a policy in which we affirmatively call borrowers about debt collection. 

XXXX responded on XX/XX/XXXX -- -- Complaint # XXXX With regard to the first allegation, MRLP and its attorneys do not have outbound solicitation of borrower. We are a law firm and not a collection agency which will contact borrowers within certain times of the day. There were no communications by text. 

Company responded on XX/XX/XXXX -- - Complaint # XXXX With regard to the first allegation, MRLP and its attorneys do not have outbound solicitation/routine collection calls of borrowers. We are a law firm and not a collection agency which will contact borrowers within certain times of the day. XXXX was not trying to misrepresent the text messages to the XXXX by XXXX XXXX in our previous response to the XXXX CFPB Complaint. As you can see from the exhibits provided by the XXXX, the text messages relate to pleadings and settlement negotiations because the XXXX was XXXX XXXX and did not have outside legal counsel. Those text messages were appropriate in the legal setting to move the case along. 
McCalla Raymer Leibert Pierce , LLC, and its Managing Partner, Attorney XXXX XXXX XXXX willfully violated XXXX XXXX XXXX Reform and Consumer Protection Acts that is not in dispute and willfully misrepresented to the Consumer Financial Protection Bureau XXXX We are a law firm and not a collection agency which will contact borrowers within certain times of the day. There were no communications by text. 
Those text messages received were not appropriate in a legal setting to move the case along. Demanding Complainant to vacate his property within 90 days while the case is being appealed, before the appeal, after XXXX and close to 12 midnight is wholly without a legal basis or reason. Respondent continue to attempt to willfully misrepresent and justify Respondent unlawful text messages that was for the sole purpose of harassment. Respondent continue to harass Complainant to date that is not in dispute.