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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

Kristen Leet,

 Plaintiff,

v.

Enhanced Recovery Company, LLC

c/o LexisNexis Document Solutions

801 Adlai Stevenson Drive

Springfield, IL 62703,

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 Indiana.

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

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- On or around February 16, 2012, Plaintiff filed a voluntary bankruptcy petition 

(“Petition”) that included the Debt.

10- On or around March 9, 2012, Defendant sent Plaintiff a letter to collect the Debt.

11- At the time of these communications, Defendant knew or should have known about the 

Petition.

12- Defendant damaged Plaintiff.

13- Defendant violated the FDCPA.

COUNT I

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

15- Defendant violated 15 USC §1692c(a)(2) by communicating with a consumer after 

having notice that the consumer was represented by an attorney.

COUNT II

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

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

legal status of the Debt. 

COUNT III

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

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

to collect, or attempt to collect, the Debt.

 COUNT IV

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

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

methods to collect a debt. 

JURY DEMAND

22- Plaintiff demands a trial by jury.

PRAYER FOR RELIEF

23- 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); and

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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