IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

Dennis R. Prieve, individually, and on ) 

behalf of all others similarly situated, )

)

Plaintiff, )

 )

v. ) No. 12 C 2446

)

Stoneleigh Recovery Associates, LLC, )

an Illinois limited liability company, The )

Bureaus, Inc., an Illinois corporation, and )

Bureaus Investment Group Portfolio )

No. 15, LLC, an Illinois limited liability )

company, )

)

Defendants. ) Jury Demanded

CLASS ACTION COMPLAINT

Plaintiff, Dennis R. Prieve, individually, and on behalf of all others similarly 

situated, brings this action under the Fair Debt Collection Practices Act, 15 U.S.C. § 

1692, et seq. ("FDCPA"), for a finding that Defendants’ form debt collection letter 

violated the FDCPA, and to recover damages for Defendants’ violations of the FDCPA, 

and alleges:

JURISDICTION AND VENUE

1. This Court has jurisdiction pursuant to § 1692k(d) of the FDCPA, and 28 

U.S.C. § 1331.

2. Venue is proper in this District because: a) the acts and transactions 

occurred here; b) Plaintiff resides here; and, c) Defendants reside and transact business 

here.

Case: 1:12-cv-02446 Document #: 1 Filed: 04/03/12 Page 1 of 7 PageID #:1
2

PARTIES

3. Plaintiff, Dennis R. Prieve ("Prieve"), is a citizen of the State of Illinois, 

residing in the Northern District of Illinois, from whom Defendants attempted to collect a

delinquent consumer debt, which was owed for a HSBC account.

4. Defendant, Stoneleigh Recovery Associates, LLC (“SRA”), is an Illinois 

limited liability company that acts as a debt collector, as defined by § 1692a of the 

FDCPA, because it regularly uses the mails and/or the telephone to collect, or attempt 

to collect, delinquent consumer debts. Defendant SRA operates a nationwide debt 

collection business and attempts to collect debts from consumers in virtually every 

state, including consumers in the State of Illinois. In fact, Defendant SRA was acting as 

a debt collector as to the delinquent consumer debt it attempted to collect from Plaintiff.

5. Defendant, The Bureaus, Inc. (“Bureaus”), is an Illinois corporation that 

acts as a debt collector, as defined by § 1692a of the FDCPA, because it regularly uses 

the mails and/or the telephone to collect, or attempt to collect, directly or indirectly, 

delinquent consumer debts. Defendant Bureaus operates a nationwide debt collection 

business and attempts to collect debts from consumers in virtually every state, including 

consumers in the State of Illinois. In fact, Defendant Bureaus was acting as a debt 

collector, as that term is defined in the FDCPA, as to the delinquent consumer debt it 

attempted to collect from Plaintiff. 

6. Defendant, Bureaus Investment Group Portfolio No. 15, LLC (“Bureaus 

Investment”), is an Illinois limited liability company that acts as a debt collector, as 

defined by § 1692a of the FDCPA, because it regularly uses the mails and/or the 

telephone to collect, or attempt to collect, directly or indirectly, delinquent consumer 

Case: 1:12-cv-02446 Document #: 1 Filed: 04/03/12 Page 2 of 7 PageID #:2
3

debts. Defendant Bureaus Investment operates a nationwide debt collection business 

and attempts to collect debts from consumers in virtually every state, including 

consumers in the State of Illinois. In fact, Defendant Bureaus Investment was acting as 

a debt collector, as that term is defined in the FDCPA, as to the delinquent consumer 

debt it attempted to collect from Plaintiff. 

7. Defendants are authorized to conduct business in Illinois, and maintain

registered agents here, see, records from the Illinois Secretary of State, attached as 

Group Exhibit A. In fact, Defendants conduct business in Illinois.

8. Moreover, Defendants SRA and Bureaus are licensed as collection 

agencies in Illinois, see, records from the Illinois Division of Professional Regulation, 

attached as Group Exhibit B. In fact, Defendants SRA and Bureaus act as collection 

agencies in Illinois.

FACTUAL ALLEGATIONS

9. Mr. Prieve fell behind on paying his bills. At some point in time after a 

debt he allegedly owed to HSBC became delinquent, it was allegedly sold to a bad debt 

buyer – either Bureaus or Bureaus Investment, who then began trying to collect upon it, 

by having SRA send Ms. Prieve an initial form collection letter, dated March 15, 2012. 

This collection letter twice stated: “Debt Owed To: THE CLIENT, THE BUREAUS INC.”, 

but also stated that: “BUREAUS INVESTMENT GROUP PORTFOLIO NO 15 LLC has 

referred your delinquent account of $3,053.91 to this agency for collection”. 

Defendants’ letter failed to explain what the relationship or difference was between The 

Bureaus, Inc. and Bureaus Investment Group Portfolio No. 15, LLC. A copy of 

Defendants’ letter is attached as Exhibit C.

Case: 1:12-cv-02446 Document #: 1 Filed: 04/03/12 Page 3 of 7 PageID #:3
4

10. In fact, Defendant Bureaus Investment is likely the bad debt buyer which 

allegedly bought the debt and Defendant Bureaus was likely not the owner of the debt;

rather, it merely placed the debt, which Bureaus Investment allegedly owned, with 

Defendant SRA for collection. 

11. Defendants’ collection actions complained of herein occurred within one 

year of the date of this Complaint. 

12. Defendants’ collection communications are to be interpreted under the 

“unsophisticated consumer” standard. See, Gammon v. GC Services, Ltd. Partnership, 

27 F.3d 1254, 1257 (7th Cir. 1994).

COUNT I

Violation Of § 1692g(a)(2)

Failure To Identify Effectively The Current Creditor

13. Plaintiff adopts and realleges ¶¶’s 1-12.

14. Section 1692g of the FDCPA requires that, within 5 days of Defendants’ 

first communication to a consumer, they had to provide Mr. Prieve with an effective 

validation notice, containing, among other disclosures, “(2) the name of the creditor to 

whom the debt is owed;” see, 15 U.S.C. § 1692g(a)(2). 

15. Defendants’ form collection letter violates § 1692g(2) of the FDCPA

because it failed to identify effectively that Defendant Bureaus Investment was allegedly 

the current creditor to whom the debt was owed. 

16. Defendants’ violation of § 1692g of the FDCPA renders them liable for 

statutory damages, costs, and reasonable attorneys’ fees. See, 15 U.S.C. § 1692k.

Case: 1:12-cv-02446 Document #: 1 Filed: 04/03/12 Page 4 of 7 PageID #:4
5

COUNT II

Violation Of § 1692e Of The FDCPA --

Making A False Statement Of The Name Of Creditor

17. Plaintiff adopts and realleges ¶¶’s 1-12.

18. Section 1692e of the FDCPA prohibits a debt collector from using any 

false and/or any deceptive or misleading representation or means in connection with the 

collection of a debt. See, 15 U.S.C. § 1692e.

19. Defendants violated § 1692e of the FDCPA by falsely stating in their 

collection letter (Exhibit C), that the debt was owed to the Bureaus, when, in fact, the 

debt was owed to Bureaus Investment.

20. Defendants’ violation of § 1692e of the FDCPA render them liable for 

statutory damages, costs, and reasonable attorneys’ fees. See, 15 U.S.C. § 1692k.

CLASS ALLEGATIONS

21. Plaintiff, Dennis R. Prieve, brings this action individually and as a class

action on behalf of all persons similarly situated in the State of Illinois from whom 

Defendants attempted to collect a delinquent consumer debt allegedly owed originally 

for an HSBC account that was then allegedly owed to Bureaus and/or Bureaus 

Investment, via the same form collection letter (Exhibit C), that Defendants sent to 

Plaintiff, from one year before the date of this Complaint to the present. This action

seeks a finding that Defendants’ form collection letter violates the FDCPA, and asks that 

the Court award damages as authorized by § 1692k(a)(2) of the FDCPA.

22. Defendants regularly engage in debt collection, using the same form 

collection letter they sent Plaintiff Prieve, in their attempts to collect delinquent 

consumer debts from other consumers.

Case: 1:12-cv-02446 Document #: 1 Filed: 04/03/12 Page 5 of 7 PageID #:5
6

23. The Class consists of more than 35 persons from whom Defendants 

attempted to collect delinquent consumer debts by sending other consumers the same 

form collection letter they sent Plaintiff Prieve.

24. Plaintiff Prieve’s claims are typical of the claims of the Class. Common 

questions of law or fact raised by this class action complaint affect all members of the 

Class and predominate over any individual issues. Common relief is therefore sought 

on behalf of all members of the Class. This class action is superior to other available 

methods for the fair and efficient adjudication of this controversy.

25. The prosecution of separate actions by individual members of the Class 

would create a risk of inconsistent or varying adjudications with respect to the individual 

members of the Class, and a risk that any adjudications with respect to individual 

members of the Class would, as a practical matter, either be dispositive of the interests 

of other members of the Class not party to the adjudication, or substantially impair or 

impede their ability to protect their interests. Defendant has acted in a manner 

applicable to the Class as a whole such that declaratory relief is warranted.

26. Plaintiff Prieve will fairly and adequately protect and represent the 

interests of the Class. The management of the class action proposed is not 

extraordinarily difficult, and the factual and legal issues raised by this class action 

complaint will not require extended contact with the members of the Class, because 

Defendants’ conduct was perpetrated on all members of the Class and will be 

established by common proof. Moreover, Plaintiff Prieve has retained counsel 

experienced in class action litigation, including class actions brought under the FDCPA.

Case: 1:12-cv-02446 Document #: 1 Filed: 04/03/12 Page 6 of 7 PageID #:6
7

PRAYER FOR RELIEF

Plaintiff, Dennis R. Prieve, individually and on behalf of all others similarly 

situated, prays that this Court:

1. Certify this action as a class action;

2. Appoint Plaintiff Prieve as Class Representative of the Class, and his

attorneys as Class Counsel;

3. Find that Defendants’ form collection letter violates the FDCPA;

4. Enter judgment in favor of Plaintiff Prieve and the Class, and against 

Defendants, for statutory damages, costs, and reasonable attorneys’ fees as provided 

by § 1692k(a) of the FDCPA; and,

5. Grant such further relief as deemed just.

JURY DEMAND

Plaintiff, Dennis R. Prieve, individually, and on behalf of all others similarly 

situated, demands trial by jury.

Dennis R. Prieve, individually, and on 

behalf of all others similarly situated.

By: /s/ David J. Philipps___________

One of Plaintiff’s Attorneys

Dated: April 3, 2012

David J. Philipps (Ill. Bar No. 06196285)

Mary E. Philipps (Ill. Bar No. 06197113)

Philipps & Philipps, Ltd.

9760 S. Roberts Road

Suite One

Palos Hills, Illinois 60465

(708) 974-2900

(708) 974-2907 (FAX)

davephilipps@aol.com

mephilipps@aol.com

Case: 1:12-cv-02446 Document #: 1 Filed: 04/03/12 Page 7 of 7 PageID #:7