XXXX XXXX XXXX XXXX a partner at XXXX XXXX XXXX is the former Chairperson of the, XXXX XXXX XXXX XXXX, of the Illinois State Bar Association, allegedly, filed a foreclosure complaint on behalf of PNC Bank, NA on XX/XX/XXXX.

PNC Bank NA is fully aware that a foreclosure was allegedly filed and that I filed a counter-complaint to defend this illegal action.

PNC Bank, NA and XXXX XXXX XXXX XXXX similarly to XXXX XXXX  holds a lot of financial and political power.

I was deceived into thinking a foreclosure complaint was filed with the court when in truth no foreclosure was every filed.

PNC has been collecting fees from this foreclosure that was never filed continues to charge me these illegal fees.

PNC Bank, NA has committed numerous violations to the Fair Debt and Collections Practices Act as listed in the attached exhibits in addition numerous false documents have been submitted to the XXXX County Circuit Court.

I recently found out that a foreclosure was not filed in accordance to common law and the rules and regulations that are required by the state of Illinois and federal law.

That it was XXXX XXXX XXXX XXXX on behalf of PNC Bank, NA who submitted the documents pertaining to the foreclosure on XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXXandXX/XX/XXXX.

The law firm paid the filing fee of {$880.00} and billed it to me along with other illegal charges but they only made it appear that a foreclosure complaint had been filed with the XXXX  County Circuit Court.

There are many legal steps that have to be taken before a foreclosure complaint is filed such as follows : That as a condition precedent to initiating a foreclosure the following must be done pe

r 12 CFR 1024.41 ( f ) ( 1 ) - ( 2 ) : Servicers must engage in a single track for considering foreclosure alternatives up to the 120th day of delinquency. The foreclosure process may not commence if the borrower and servicer are engaged in a good-faith effort to resolve the delinquency. Also, prior to referral for foreclosure, the servicer must perform a formal review of the case to confirm that the borrower has been considered for a foreclosure alternative. Even after the foreclosure process has begun, servicers must continue to work with homeowners on foreclosure alternatives to ensure borrowers have additional opportunity to avoid foreclosure beyond the initial four-month period. At any rate I believe the documents I have attached will speak for themselves VIOLATION 1692e OF THE FDCPA 1. That the PNC Bank, NA is in alleged violation of the following : per 15 USC 1692e 807 False or misleading representations : A debt collector may not use any false, deceptive, or misleading representation or means in connection with the collection of any debt. Without limiting the general application of the foregoing, the following conduct is a violation of this section : ( 2 ) The false representation of -- ( A ) the character, amount, or legal status of any debt ; or ( B ) any services rendered or compensation which may be lawfully received by any debt collector for the collection of a debt. ( 4 ) The representation or implication that nonpayment of any debt will result in the arrest or imprisonment of any person or the seizure, garnishment, attachment, or sale of any property or wages of any person unless such action is lawful and the debt collector or creditor intends to take such action. ( 5 ) The threat to take any action that can not legally be taken or that is not intended to be taken. ( 6 ) The false representation or implication that a sale, referral, or other transfer of any interest in a debt shall cause the consumer to -- ( A ) lose any claim or defense to payment of the debt ; or ( B ) become subject to any practice prohibited by this subchapter. ( 7 ) The false representation or implication that the consumer committed any crime or other conduct in order to disgrace the consumer. ( 8 ) Communicating or threatening to communicate to any person credit information which is known or which should be known to be false, including the failure to communicate that a disputed debt is disputed. ( 9 ) The use or distribution of any written communication which simulates or is falsely represented to be a document authorized, issued, or approved by any court, official, or agency of the United States or any State, or which creates a false impression as to its source, authorization, or approval. ( 10 ) The use of any false representation or deceptive means to collect or attempt to collect any debt or to obtain information concerning a consumer. ( 13 ) The false representation or implication that documents are legal process. ( 15 ) The false representation or implication that documents are not legal process forms or do not require action by the consumer. 2. That the PNC Bank, NA is in alleged violation of the following : per 15 USC 1692e 807 False or misleading representations : 3. That the PNC Bank, NA, intentionally failed to disclose important facts that were known to it that being a foreclosure complaint was never filed and fraudulent documents were filed with the Court. 4. The representations described above in section 1692 ( e ) were false when PNC Bank, NA made them, and PNC Bank, NA knew they were false when the collected them and continued charges and/or collections of attorney fees, legal fees, foreclosure costs, property inspection fees, filing fees, broker price opinions, predatory lending fees, and other charges and advances and are still collecting these fees. 5. That in reasonable reliance on the false and fraudulent representations described above and believing them to be true did not ask the Court to dismiss and award judgment and cost when the Defendants foreclosure complaint was allegedly filed on XX/XX/XXXX. 6. That the PNC Bank, NA made the representations described above with the intent and for the purpose of defrauding plaintiff. 7. That the PNC Bank, NAs concealment was a substantial factor in causing me harm. USC 1692f ; 808. Unfair practices 8. 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 : ( 1 ) 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. ( 6 ) Taking or threatening to take any non-judicial action to effect dispossession or disablement of property if -- ( A ) there is no present right to possession of the property claimed as collateral through an enforceable security interest ; ( B ) there is no present intention to take possession of the property ; or ( C ) the property is exempt by law from such dispossession or disablement. 9. That PNC Bank, NA knew it was in violation of the foregoing subsections when it attempted to collect a debt that was not permitted by law. 10. That subsections A, B and C constituted taking a non-judicial action 11. That the PNC Bank, NA knew these actions were not legal when it collected and continues to charges, attorney fees, attorney advancement, foreclosure fees, property inspection fees, court filing fees. 12. That the PNC Bank, NA intended me to believe that these fees were proper. 13. That, in reasonable reliance on the false and fraudulent representations described above paid these fees and continues to be billed these fees. 14. That the PNC Bank, NA was harmed by these unauthorized charges. 812. Furnishing certain deceptive forms 39. That subsection ( a ) of the foregoing states as follows : ( a ) It is unlawful to design, compile, and furnish any form knowing that such form would be used to create the false belief in a consumer that a person other than the creditor of such consumer is participating in the collection of or in an attempt to collect a debt such consumer allegedly owes such creditor, when in fact such person is not so participating. ( b ) Any person who violates this section shall be liable to the same extent and in the same manner as a debt collector is liable under section 1692k of this title for failure to comply with a provision of this subchapter. 15. That the PNC Bank, NA represented to me that documents it submitted to me and the court were true and correct, when in truth they were not. 16. That the PNC Bank, NA knew these documents were fraudulent when they submitted them. 17. That I repeats and re-alleges each allegation including each Exhibit contained in my Affidavit attached herein with the same effect as if repeated in its entirety in this paragraph. 18. That I in reasonable reliance on the false and fraudulent representations described above and believing them to be true did not ask the Court to dismiss and award judgment and cost when the Complaint was allegedly filed on XX/XX/XXXX. 19. That the PNC Bank, NA made the representations described above with the intent and for the purpose of defrauding plaintiff. 20. That the PNC Bank, NAs concealment was a substantial factor in causing me harm. VIOLATION OF 1692f OF THE FDCPA 21. A debt collector violates the FDCPA when it attempts to collect a debt that is not authorized by law or an underlying agreement, see 15 U.S.C.A. 1692f. 22. The PNC Bank, NA has made derogatory entries on my Consumer Credit Report she has the right to bring additional claims under the Fair Credit Reporting Act, 15 U.S.C.A. 1681 et seq. 1692 ( b ) States as follows : ( b ) Disputed debts If the consumer notifies the debt collector in writing within the thirty-day period described in subsection ( a ) of this section 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. 23. That Plaintiff suing under the Illinois Consumer Fraud Act need not allege all elements of fraudulent misrepresentation, because the Act prohibits any deception or false promise or omission of material fact. XXXX XXXX XXXX. v. XXXX XXXX XXXX. XXXX XXXX XXXX XXXX XXXX XXXX XXXX 24. That any conduct in business which creates a likelihood of consumer confusion or misunderstanding is potentially actionable under the Illinois Consumer Fraud and Deceptive practices Act and the Uniform Deceptive Trade Practices Act. Statements made need not be actually have been false but only misleading. XXXX XXXX XXXX v. XXXX XXXX XXXXXX/XX/XXXX XXXX XXXX XXXX XXXX. 25. That unlike a common law fraud claim, a successful claim under the Illinois Consumer Fraud Act does not require that the plaintiff have relied on the deception. XXXX v. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ) XX/XX/XXXX. 26. That cost that are imposed on an unwilling consumer can constitute a substantial injury for purposed of claim under the Illinois Consumer Fraud Act ( ICFA )
. XXXX XXXX XXXX v. XXXX XXXX XXXX , XXXX XXXX XXXX XXXX XX/XX/XXXX XXXX XXXX XXXX XXXX. VIOLATION OF ( 815 ILCS 205/6 ) 27. Plaintiff suing under the Illinois Consumer Fraud Act need not allege all elements of fraudulent misrepresentation, because the Act prohibits any deception or false promise or omission of
material fact. XXXX XXXX XXXX v. XXXX XXXX XXXX  XXXX XXXX XXXX XXXX XXXX XXXX XXXX 28. Any conduct in business which creates a likelihood of consumer confusion or misunderstanding is potentially actionable under the Illinois Consumer Fraud and Deceptive practices Act and the Uniform Deceptive Trade Practices Act. Statements made need not be actually have been false but only misleading. XXXX XXXX XXXX v. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX 29. Unlike a common law fraud claim, a successful claim under the Illinois
Consumer Fraud Act does not require that the plaintiff have relied on the deception. XXXX v. XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX. ) XX/XX/XXXX. 30. Cost that ar
e imposed on an unwilling consumer can constitute a substantial injury for purposed of claim under the Illinois Consumer Fraud Act ( ICFA ). XXXX XXXX XXXX v. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XX/XX/XXXXXXXX XXXX XXXX XXXX XXXX

31. That the PNC Bank, NA knowingly charge meinterest, attorney fees, attorney advancement fees, property inspection fees, foreclosure fees. 32. That the PNC Bank, NA knew that these fees were not proper when the PNC Bank, NA charged and continues to charge them. 33. Plaintiff suing under the Illinois Consumer Fraud Act
need not allege all elements of fraudulent misrepresentation, because the Act prohibits any deception or false promise or omission of material fact. XXXX XXXX XXXX v. XXXX XXXX XXXX XXXX XXXX XX/XX/XXXX XXXX XXXX XXXX XXXX 34. Any conduct in business which creates a likelihood of consumer confusion or misunderstanding is potentially actionable under the Illinois Consumer Fraud and Deceptive practices Act and the Uniform Deceptive Trade Practices Act. Statements made need not be actually have been false but only misleading. XXXX XXXX XXXX v. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX 35. Unlike a common law fraud claim, a successful claim
under the Illinois Consumer Fraud Act does not require that the plaintiff have relied on the deception. XXXX v. XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX. ) XX/XX/XXXX. 36. Cost that are imposed on an unwilling consumer can constitute a substantial injury for purposed of claim under the Illinois Consumer Fraud Act ( ICFA ). XXXX XXXX XXXX v. XXXX XXXX XXXX , XXXX XXXX XXXXXX/XX/XXXX XXXX XXXX XXXX XXXX. 37. That the PNC Bank, NA intended me to rely on allegations that these fees were proper. 38. That the deception occurred in the course of conduct trade or commerce. 39. That the PNC Bank, NAs concealment was a substantial factor in causing the me harm. 40. That the PNC Bank, NA continu
es to charge the aforementioned fees and interest and these fees continue to occur.