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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

NICHOLAS MARTIN 

 Plaintiff, 

 vs. 

CELLCO PARTNERSHIP d/b/a VERIZON 

WIRELESS; VANTAGE SOURCING, LLC; 

and CREDIT BUREAU OF NAPA COUNTY, 

INC. d/b/a CHASE RECEIVABLES 

 Defendants. 

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Case No.: 12-cv-5147 

Judge Ronald A. Guzman 

Magistrate Sheila M. Finnegan 

 

STATEMENT IN RESPONSE TO JUDGE GUZMAN’S DECEMBER 3, 2012 ORDER

 Pursuant to Judge Guzman’s December 3, 2012 minute order directing the parties to file a 

statement which clarifies which claims and cross-claims remain pending in the above captioned 

case, the following is provided to the Court: 

PLAINTIFF’S CLAIMS WHICH REMAIN PENDING:

Count V – FDCPA claim against defendant CREDIT BUREAU OF NAPA COUNTY, 

INC. d/b/a CHASE RECEIVABLES. Plaintiff and defendant have agreed to a settlement in 

principle and are currently working on finalizing a written settlement agreement and release 

which would fully resolve all issues relating to Count V. 

Count VI- TCPA claim against defendants CELLCO PARTNERSHIP d/b/a VERIZON 

WIRELESS and VANTAGE SOURCING, LLC. Plaintiff and defendants have agreed to a 

settlement in principle and are currently working on finalizing a written settlement agreement 

and release which would fully resolve all issues relating to Count VI. 

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Count VII- TCPA claim against defendants CELLCO PARTNERSHIP d/b/a VERIZON 

WIRELESS and CREDIT BUREAU OF NAPA COUNTY, INC. d/b/a CHASE 

RECEIVABLES. Plaintiff and defendant CREDIT BUREAU OF NAPA COUNTY, INC. d/b/a 

CHASE RECEIVABLES have agreed to a settlement in principle and are currently working on 

finalizing a written settlement agreement and release which would fully resolve all issues 

relating to Count VII. 

Counts IV and VIII have previously been voluntarily dismissed. 

CELLCO PARTNERSHIP’S CROSS-CLAIMS WHICH REMAIN PENDING:

 CELLCO PARTNERSHIP d/b/a VERIZON WIRELESS has filed cross-claims against 

Defendants VANTAGE SOURCING, LLC and CREDIT BUREAU OF NAPA COUNTY, INC 

d/b/a CHASE RECEIVABLES. These cross-claims remain pending. Cellco Partnership and 

both Cross-Defendants have agreed to a settlement in principle on Cellco Partnership’s crossclaims and these cross-claims will be dismissed once the above settlement agreements of Counts 

VI and VII are fully executed. 

Respectfully submitted, 

/s/ Nicholas Martin

Plaintiff 

Nicholas Martin 

Pro Se

PO Box 4030 

Chicago, IL 60654-4030 

(312) 725-9103 

/s/ Dean C. Kalant

Counsel for Defendant Vantage 

Sourcing, LLC

Rick Del Giudice 

Dean Kalant 

GOZDECKI, DEL GIUDICE, 

AMERICUS & FARKAS LLP 

1 East Wacker Drive 

Suite 1700 

Chicago, IL 60601 

Phone: 312-782-5010 

Fax: 312-782-4324 

/s/ Elizabeth A. Thompson 

Counsel for Defendant Cellco 

Partnership 

Hal Morris 

Elizabeth Thompson 

ARNSTEIN & LEHR LLP 

120 South Riverside Plaza 

Suite 1200 

Chicago, IL 60606-3910 

Phone: 312-876-7833 

Fax: 312-876-0288 

Case: 1:12-cv-05147 Document #: 40 Filed: 12/05/12 Page 2 of 3 PageID #:213
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VERIFICATION OF SERVICE

I, Nicholas Martin, pursuant to Fed.R.Civ.P. 5(a), verify that on December 5, 2012, I 

electronically filed the foregoing STATEMENT IN RESPONSE TO JUDGE GUZMAN’S 

DECEMBER 3, 2012 ORDER with the Clerk of Court using the CM/ECF system, which will 

serve electronic notice to all counsel of record. 

I verify under penalty of perjury that the foregoing is true and correct. 

Executed on December 5, 2012. 

 /s/ Nicholas Martin

Case: 1:12-cv-05147 Document #: 40 Filed: 12/05/12 Page 3 of 3 PageID #:214