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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

Melanie Galasinski,

 Plaintiff,

v.

First Integral Recovery Services

c/o Legal Department

10039 Bissonnet St. Suite 305 

Houston , Texas 77036,

Defendant.

Case No.

COMPLAINT 

Jury Demand Requested

JURISDICTION AND VENUE

1- This court has jurisdiction pursuant to 28 U.S.C. §§1331, 1337, 1367; 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 incurred an obligation to pay money, the primary purpose of which was for 

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

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

5- Defendant is a corporation with its principal office in the State of Texas.

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.

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FACTS COMMON TO ALL COUNTS

9- In or around August 2011, Defendant communicated with Plaintiff to collect the Debt.

10- During this communication, Defendant falsely represented to Plaintiff that the Debt was 

“in litigation.”

11- As a direct and proximate result of Defendant’s misrepresentation, Plaintiff entered into a 

payment arrangement with Defendant.

12- In or around November 2011, defendant communicated with Plaintiff to collect the Debt.

13- During this communication, Plaintiff communicated to defendant that she would not be 

able to continue making the payments.

14- During this communication, Defendant represented to Plaintiff that the account was in the 

legal department.

15- During this communication, Defendant threatened to get a judgment against Plaintiff is the 

debt was not paid.

16- During communication, Defendant threatened to increase the balance of the Debt by 

$2,500 in attorney fees and costs if the Debt was not paid.

17- Defendant damaged Plaintiff.

18- Defendant violated the FDCPA.

COUNT I

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

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

legal status of the Debt. 

COUNT II

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

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22- Defendant violated 15 USC § 1692e(5) by threatening to take action against Plaintiff that 

Defendant cannot legally take.

COUNT III

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

24- Defendant violated 15 USC § 1692e(5) by threatening to take action against Plaintiff that 

Defendant did not intend to take.

COUNT IV

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

26- Defendant violated 15 USC § 1692e(10) by using false representations and/or deceptive 

means to collect, or attempt to collect, the Debt.

COUNT V

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

28- Defendant violated 15 USC § 1692f by engaging in unfair and/or unconscionable means to 

collect, or attempt to collect, the Debt.

COUNT VI

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

30- Defendant violated 15 USC § 1692e by engaging in false, deceptive, or misleading 

methods to collect a debt. 

JURY DEMAND

31- Plaintiff demands a trial by jury.

PRAYER FOR RELIEF

32- Plaintiff prays for the following relief:

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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

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