1

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

Lashonda Ash,

 Plaintiff,

v.

Global Recovery Systems, Inc.

a/k/a GRS Management

c/o Inna Verona, registered agent

3363 NE 163 Street, Suite 204

Miami, FL 33179

Defendant.

Case No.

COMPLAINT 

Jury Demand Requested

JURISDICTION AND VENUE

1- This court has jurisdiction pursuant to 28 U.S.C. §1331 and 15 U.S.C. §1692k(d).

2- Venue is proper because a substantial part of the events giving rise to this claim occurred 

in this District.

PARTIES

3- Plaintiff is a resident of the State of Illinois. 

4- Plaintiff incurred an obligation to pay money, the primary purpose of which was for 

personal, family, or household uses (the “Debt”).

5- Defendant is a corporation with its principal place of business in the State of Florida.

6- Defendant uses instruments of interstate commerce for its principal purpose of business, 

which it the collection of debts.

7- Defendant regularly attempts to collects, or attempts to collect, debts owed or due another.

8- At all times relevant, Defendant owned the Debt or was retained to collect the Debt.

Case: 1:11-cv-09094 Document #: 1 Filed: 12/22/11 Page 1 of 4 PageID #:1
2

FACTS COMMON TO ALL COUNTS

9- On or around August 12, 2011, Defendant telephone Plaintiff’s mother (“Mother”).

10- During this communication, Mother notified Defendant that Plaintiff did not live with 

Mother.

11- On or around August 15, 2011, despite having notice, Defendant telephoned Mother 

again.

12- During this communication, Defendant disclosed the existence, nature, and/or amount of 

the Debt to Mother.

13- During this communication, Defendant falsely represented to Mother that Defendant was 

“in the area” trying to serve Plaintiff with papers.

14- On or around August 17, 2011, Defendant communicated with Plaintiff.

15- During this communication, Plaintiff notified Defendant that she retained an attorney to 

file for bankruptcy and provided the attorney’s contact information to Defendant.

16- During this communication, Defendant threatened to issue a warrant for Plaintiff’s arrest if 

the Debt was not paid.

17- During this communication, Defendant threatened to file a lawsuit against Plaintiff if the 

Debt was not paid.

18- During this communication, Defendant threatened to garnish Plaintiff’s wages if the Debt 

was not paid.

19- Defendant damaged Plaintiff.

20- Defendant violated the FDCPA.

Case: 1:11-cv-09094 Document #: 1 Filed: 12/22/11 Page 2 of 4 PageID #:2
3

COUNT I

21- Plaintiff incorporates all the allegations and statements made above as if reiterated herein.

22- Defendant violated 15 USC § 1692b(3) by communicating with a person other than the 

consumer more than once.

COUNT II

23- Plaintiff incorporates all the allegations and statements made above as if reiterated herein.

24- Defendant violated 15 USC § 1692e(2) by misrepresenting the character, amount, and/or 

legal status of the debt.

COUNT III

25- Plaintiff incorporates all the allegations and statements made above as if reiterated herein.

26- Defendant violated 15 USC § 1692e(5) by threatening to take action that Defendant could 

not legally take.

COUNT IV

27- Plaintiff incorporates all the allegations and statements made above as if reiterated herein.

28- Defendant violated 15 USC § 1692e(5) by threatening to take action that Defendant did 

not intend to take.

COUNT V

29- Plaintiff incorporates all the allegations and statements made above as if reiterated herein.

30- Defendant violated 15 USC § 1692e(10) by making false representations during the 

collection, or attempted collection, of a debt. 

COUNT VI

31- Plaintiff incorporates all the allegations and statements made above as if reiterated herein.

Case: 1:11-cv-09094 Document #: 1 Filed: 12/22/11 Page 3 of 4 PageID #:3
4

32- Defendant violated 15 USC § 1692f by using unfair and unconscionable means to collect 

or attempt to collect a debt. 

JURY DEMAND

33- Plaintiff demands a trial by jury.

PRAYER FOR RELIEF

34- Plaintiff prays for the following relief:

a. Judgment against Defendant for Plaintiff’s actual damages, as determined at 

trial, suffered as a direct and proximate result Defendant’s violations of the 

Fair Debt Collection Practices Act, pursuant to 15 U.S.C. §1692k(a)(1);

b. Judgment against Defendant for $1,000 in statutory damages for Defendant’s 

violations of the Fair Debt Collection Practices Act, pursuant to 15 U.S.C. 

§1692k(a)(2)(A);

c. Judgment against Defendant for Plaintiff’s reasonable attorneys’ fees and costs 

incurred in this action, pursuant to 15 U.S.C. §1692k(a)(3);

d. Any other legal and/or equitable relief as the Court deems appropriate.

RESPECTFULLY SUBMITTED,

Meier LLC

By: /s/ Richard J. Meier

Richard J. Meier, Esq

53 W. Jackson Blvd, Suite 709

Chicago, IL 60604

Tel: 312-242-1849

Fax: 312-242-1841

Richard@meierllc.com

Attorney for Plaintiff

Case: 1:11-cv-09094 Document #: 1 Filed: 12/22/11 Page 4 of 4 PageID #:4