PLAINTIFF’S VERIFIED COMPLAINT 

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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

BRANDI NEUBERG, ) 

) 

Plaintiff, ) 

) No. 3:12-cv-50119

v. ) 

) VERIFIED COMPLAINT 

CENTRAL CREDIT SERVICES, INC. ) (Unlawful Debt Collection Practices) 

 ) 

Defendant. ) 

PLAINTIFF’S VERIFIED COMPLAINT

 BRANDI NEUBERG (Plaintiff), through attorneys, KROHN & MOSS, LTD., alleges the 

 following against CENTRAL CREDIT SERVICES, INC. (Defendant): 

INTRODUCTION 

1. Count I of Plaintiff’s Complaint is based on the Fair Debt Collection Practices 

Act, 15 U.S.C. 1692 et seq. (FDCPA). 

JURISDICTION AND VENUE 

2. Jurisdiction of this Court arises pursuant to 15 U.S.C. 1692k(d), which states that 

such actions may be brought and heard before “any appropriate United States district court without 

regard to the amount in controversy.” 

3. Defendant conducts business in the state of Illinois; therefore, personal jurisdiction is 

established. 

4. Venue is proper pursuant to 28 U.S.C. 1391(b)(2). 

PARTIES 

5. Plaintiff is a natural person residing in Chicago, Cook County, Illinois. 

6. Plaintiff is a consumer as that term is defined by 15 U.S.C. 1692a(3), and according 

to Defendant, Plaintiff allegedly owes a debt as that term is defined by 15 U.S.C. 1692a(5). 

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7. Defendant is a debt collector as that term is defined by 15 U.S.C. 1692a(6), and 

sought to collect a consumer debt from Plaintiff. 

8. Plaintiff is informed and believes, and thereon alleges, that Defendant is a collections 

business with an office in Jacksonville, Florida. 

9. Defendant acted through its agents, employees, officers, members, directors, heirs, 

successors, assigns, principals, trustees, sureties, subrogees, representatives, and insurers. 

FACTUAL ALLEGATIONS

10. In or around February of 2012, Defendant began placing collection calls to Plaintiff 

seeking and demanding payment on an alleged debt. 

11. Defendant calls Plaintiff from 888-904-1800, 904- 371-5352, 904-562-6655, 800-

419-0746 and possibly other numbers also. 

12. Defendant calls Plaintiff seeking to collect a debt from, Tenell Carr and/or Jc Carr 

(“Carr”). 

13. Since the earliest calls, Plaintiff has informed Defendant that Carr does not live at 

this number, and that further calls cease. 

14. Defendant continues to place collection calls to Plaintiff. 

COUNT I: 

DEFENDANT VIOLATED THE FAIR DEBT 

COLLECTION PRACTICES ACT 

15. Defendant violated the FDCPA based on, but not limited to, the following: 

a. Defendant violated §1692d of the FDCPA by engaging in conduct the 

natural consequence of which is to harass, oppress, or abuse any person 

in connection with the collection of a debt; 

b. Defendant violated §1692d(5) of the FDCPA by causing a telephone to 

ring or engaging any person in telephone conversation repeatedly or 

continuously with intent to annoy, abuse, or harass any person called at 

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PLAINTIFF’S VERIFIED COMPLAINT 

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that number; 

 

 WHEREFORE, Plaintiff, BRANDI NEUBERG, respectfully requests judgment 

be entered against Defendant, CENTRAL CREDIT SERVICES, INC, for the following: 

16. Statutory damages of $1000.00 pursuant to the Fair Debt Collection Practices Act, 15 

U.S.C. 1692k; 

17. Costs and reasonable attorneys’ fees pursuant to the Fair Debt Collection Practices 

Act, 15 U.S.C. 1692k; and 

18. Any other relief that this Court deems appropriate. 

 RESPECTFULLY SUBMITTED, 

 By: _/s/ Adam T. Hill__________ 

 Adam T. Hill 

 KROHN & MOSS, LTD. 

 10 N. Dearborn St. 3rd Fl. 

 Chicago, IL 60602 

 (312) 578-9428 

 ahill@consumerlawcenter.com 

 Attorneys for Plaintiff 

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