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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

Stanley Shumake, ) 

 ) 

Plaintiff, ) 

 ) No: 

v. ) 

 ) 

Leading Edge Recovery Solutions, L.L.C., an ) 

Illinois Limited Liability Company; Unknown ) 

Debt Collectors, Individually, and as Agents, ) 

Apparent Agents, Servants, and/or Employees ) 

of Leading Edge Recovery Solutions, L.L.C., ) 

) 

) JURY DEMANDED 

Defendants. ) 

COMPLAINT AT LAW

NOW COMES Plaintiff, Stanley Shumake, by his Attorneys, Robert J. Semrad & 

Associates, L.L.C., and pursuant to this Complaint at Law, states the following against 

the above named Defendants: 

JURISDICTION

1. The jurisdiction of the court is invoked pursuant to the Fair Debt Collection 

Practices Act, 15 U.S.C. § 1692 et seq. (“FDCPA”). Venue is proper as the actions that 

give rise to this complaint occurred, Plaintiff resides in this District, and Defendants

reside and conduct business within this District. 

PARTIES

2. Plaintiff is a citizen of the County of Cook, State of Illinois, and is a “consumer” 

as that term is defined by 15 U.S.C. § 1692(a)(3). 

3. Defendant, Leading Edge Recovery Solutions, L.L.C., (hereinafter “Leading 

Edge”) is an Illinois limited liability company, residing and conducting business in the 

County of Cook, State of Illinois, and is a “debt collector” as that term is defined by 15 

U.S.C. § 1692(a)(6). 

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4. Defendants, Unknown Debt Collectors, are each natural persons conducting 

business in the County of Cook, State of Illinois, and are each a “debt collector” as that 

term is defined by 15 U.S.C. § 1692(a)(6). 

5. At all relevant times, Unknown Debt Collectors were the agents, apparent agents, 

servants, and/or employees of Leading Edge, and were acting in the course and scope of 

their agency, servitude and/or employment with Leading Edge. 

FACTUAL ALLEGATIONS

6. On or around January, 2012, Plaintiff received telephone calls from Unknown 

Debt Collectors in an attempt to collect a debt. 

7. Unknown Debt Collectors told Plaintiff that they were attempting to collect a 

consumer debt owed to Chase Bank in the approximate amount of $240.00. 

8. This alleged debt was a “debt” as that term is defined by 15 U.S.C. § 1692(a)(5). 

9. During said telephone conversation, Plaintiff told Unknown Debt Collectors that 

he did not have any debt with Chase Bank and that he in fact did not owe Chase Bank said 

debt. 

10. During said telephone conversation, Plaintiff also told Unknown Debt Collectors 

that the alleged debt probably was his son’s debt and that their names were identical. 

11. Unknown Debt Collectors made the following threats as to what would happen if 

Plaintiff did not pay the debt or make payment arrangements immediately, even after being 

told by Plaintiff that no debt was owed: 

A. that Plaintiff would be taken to Court; and 

B. that Leading Edge and Unknown Debt Collectors would continue to call 

and harass Plaintiff every day until the debt was paid or a repayment plan was 

entered into. 

12. Defendants did not have the ability or the present intent to carry out these threats. 

13. As a direct and proximate result of the aforesaid harassment, Plaintiff suffered 

injuries of a personal and pecuniary nature including, but not limited to: anxiety, 

embarrassment, and emotional harm, physical harm. 

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COUNT I 

Plaintiff v. All Defendants 

Fair Debt Collection Practices Act

1-13. Plaintiff restates and re-alleges paragraphs 1-13, as and for paragraphs 1-13 of 

Count I, as though fully set forth herein. 

14. The aforementioned telephone calls from Unknown Debt Collectors to Plaintiff

were collection communications in violation of provisions of the FDCPA, as aforesaid. 

15. As a direct and proximate result of the aforementioned actions, Plaintiff suffered 

injuries of a personal and pecuniary nature including, but not limited to: anxiety, 

embarrassment, and emotional harm, physical harm. 

16. As a result of Defendants’ violations of the FDCPA, Plaintiff is entitled to actual 

damages pursuant to 15 U.S.C. § 1692(k)(a)(1); statutory damages in an amount up to 

$1,000.00 per incident pursuant to 15 U.S.C. § 1692(k)(a)(2)(A); and reasonable 

attorney’s fees and costs pursuant to 15 U.S.C. § 1692(k)(a)(3) from Defendants. 

WHEREFORE, Plaintiff prays that judgment be entered 

 against Leading Edge; and Unknown Debt Collectors, individually, and as agents, 

apparent agents, servants, and/or employees of Leading Edge, and each of them, and in 

favor of Plaintiff, for an award of actual damages pursuant to 15 U.S.C. § 1692(k)(a)(1); 

 against Leading Edge; and Unknown Debt Collectors, individually, and as agents, 

apparent agents, servants, and/or employees of Leading Edge, and each of them, and in 

favor of Plaintiff, for an award of statutory damages of $1,000.00 pursuant to 15 U.S.C. § 

1692(k)(a)(2)(A);

 against Leading Edge; and Unknown Debt Collectors, individually, and as agents, 

apparent agents, servants, and/or employees of Leading Edge, and each of them, and in 

favor of Plaintiff, for an award of costs of litigation and reasonable attorney’s fees pursuant 

to 15 U.S.C. § 1692(k)(a)(3); and;

 for any other such further relief as may be just and proper.

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COUNT II 

Plaintiff v. Leading Edge 

Negligence

1-13. Plaintiff restates and re-alleges paragraphs 1-13, as and for paragraphs 1-13 of 

Count II, as though fully set forth herein. 

14. At all times relevant, Leading Edge, by and through its agents, servants, and/or 

employees, knew, or should have known, that Unknown Debt Collectors were likely to 

violate provisions of the FDCPA when collecting debts from Plaintiff and others, at the 

time it hired Unknown Debt Collectors. 

15. At all times relevant, Leading Edge, by and through its agents, servants, and/or 

employees, knew, or should have known, that Unknown Debt Collectors were violating 

provisions of the FDCPA when collecting debts from Plaintiff and others, throughout the 

employ of Unknown Debt Collectors.

16. At all times relevant, Leading Edge, by and through its agents, servants, and/or 

employees, knew, or should have known, that Unknown Debt Collectors required proper 

training in order to comply with the FDCPA, and that without proper training, were likely 

to violate the FDCPA. 

17. At all times relevant, Leading Edge had a duty to exercise due care in the hiring, 

retention, training, and supervision of the debt collectors in its employ. 

18. Notwithstanding the aforesaid duty, Leading Edge, by and through its agents, 

apparent agents, servants, and or employees breached their duty in one or more of the 

following ways: 

a. Carelessly and negligently hired Unknown Debt Collectors; 

b. Carelessly and negligently failed to properly train Unknown Debt 

Collectors; 

c. Carelessly and negligently retained Unknown Debt Collectors; and 

d. Carelessly and negligently, failed to properly supervise Unknown Debt 

Collectors. 

19. As a direct and proximate result of the aforementioned actions and/or omissions, 

Unknown Debt Collectors violated the FDCPA as aforesaid while attempting to collect a 

debt from Plaintiff. 

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20. As a direct and proximate result of the aforementioned actions and/or omissions, 

Plaintiff suffered injuries of a personal and pecuniary nature including, but not limited to: 

stress, anxiety, embarrassment, and emotional and physical harm. 

WHEREFORE, Plaintiff prays that judgment be entered: 

 against Leading Edge, in favor of Plaintiff, for an award of actual damages; 

 against Leading Edge, in favor of Plaintiff, for an award of costs of suit; and

 For any other such further relief as may be just and proper.

COUNT III 

Plaintiff v. Leading Edge 

Willful, Wanton Behavior 

1-13. Plaintiff restates and re-alleges paragraphs 1-13 of the common counts, as and for 

paragraphs 1-13 of Count III, as though fully set forth herein. 

14. At all times relevant, Leading Edge, by and through its agents, servants, and/or 

employees, knew, or should have known, that Unknown Debt Collectors were likely to 

violate provisions of the FDCPA when collecting debts from Plaintiff and others, at the 

time it hired Unknown Debt Collectors.

15. At all times relevant, Leading Edge, by and through its agents, servants, and/or 

employees, knew, or should have known, that Unknown Debt Collectors were violating 

provisions of the FDCPA when collecting debts from Plaintiff and others, throughout the 

employ of Unknown Debt Collectors. 

16. At all times relevant, Leading Edge, by and through its agents, servants, and/or 

employees, knew, or should have known, that Unknown Debt Collectors required proper 

training in order to comply with the FDCPA, and that without proper training, was likely 

to violate the FDCPA. 

17. At all times relevant, Leading Edge, had a duty to exercise due care in the hiring, 

retention, training, and supervision of the debt collectors in its employ. 

18. Notwithstanding the aforesaid duty, in conscious disregard to, and in utter 

disregard for the rights of those it was attempting to collect from, including Plaintiff, 

Leading Edge, by and through its agents, apparent agents, servants, and or employees 

acted willfully and wantonly in one or more of the following ways: 

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a. Willfully and wantonly hired Unknown Debt Collectors;

b. Willfully and wantonly failed to properly train Unknown Debt 

Collectors; 

c. Willfully and wantonly retained Unknown Debt Collectors; and 

d. Willfully and wantonly failed to properly supervise Unknown Debt 

Collectors. 

19. As a direct and proximate result of the aforementioned actions and/or omissions, 

Unknown Debt Collectors violated the FDCPA as aforesaid while attempting to collect a 

debt from Plaintiff. 

20. As a direct and proximate result of the aforementioned actions and/or omissions, 

Plaintiff suffered injuries of a personal and pecuniary nature including, but not limited to: 

anxiety, embarrassment, and emotional and physical harm. 

WHEREFORE, Plaintiff prays that judgment be entered: 

 against Leading Edge, in favor of Plaintiff, for an award of actual damages; 

 against Leading Edge, in favor of Plaintiff, for an award of punitive damages;

 against Leading Edge, in favor of Plaintiff, for an award of costs of suit; and

 For any other such further relief as may be just and proper.

Respectfully Submitted, 

/s/ Christian D. Elenbaas

Christian D. Elenbaas 

ARDC 6291530 

Robert J. Semrad & Associates, L.L.C. 

Attorneys for Plaintiff 

20 S. Clark St., 28th Floor 

Chicago, Illinois 60603 

Ph 312-913-0625 ext. 1170 

Fax 312-476-8530 

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