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IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF MICHIGAN 

DAVID PARSONS, 

 Plaintiff, 

 v. 

GC SERVICES LIMITED PARTNERSHIP, 

 Defendant. 

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Case No.: 

Hon.

COMPLAINT

 NOW COMES Plaintiff, DAVID PARSONS (“Plaintiff”), through his attorneys, 

KROHN & MOSS, LTD., and hereby alleges the following against Defendant, GC SERVICES 

LIMITED PARTNERSHIP (“Defendant”): 

INTRODUCTION

1. This action is brought by Plaintiff pursuant to the Fair Debt Collection Practices 

Act (“FDCPA”), 15 U.S.C. § 1692 et seq., and Mich. Comp. Laws § 445.251-258. 

JURISDICTION and VENUE

2. Jurisdiction of this court arises pursuant to 28 U.S.C. § 1331, 28 U.S.C. § 1337 

and 15 U.S.C. § 1692k(d). 

3. Venue is proper pursuant to 28 U.S.C. § 1391(b)(2) as the conduct giving rise to 

this action occurred in this district as Plaintiff resides in this district and Defendant transacts 

business in this district. 

PARTIES

4. Plaintiff is a natural person at times relevant residing in Lapeer County in 

Clifford, Michigan 

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5. Plaintiff owes or allegedly owes a debt as that term is defined by 15 U.S.C. § 

1692a(5) and Mich. Comp. Laws § 445.251(a) and is a consumer as that term is defined by 15 

U.S.C. § 1692a(3) and Mich. Comp. Laws § 445.251(d). 

6. Defendant is a business entity incorporated in Delaware with an office located at 

6330 Gulfton St., Houston, Texas 77081. 

7. Defendant, in the ordinary course of business, regularly, on behalf of itself or 

others, engages in debt collection and is a debt collector as that term is defined by 15 U.S.C. § 

1692a(6) and/or a collection agency as that term is defined by Mich. Comp. Laws § 445.251(b). 

8. Defendant acted through its agents, employees, officers, members, directors, 

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

FACTUAL ALLEGATIONS

9. Prior to the filing of this action, an account was placed with Defendant to collect 

funds from Plaintiff which were alleged to be owed and past due (“debt”). 

10. The debt arises from transactions on a credit card which were for personal use. 

11. In connection with the collection of the debt, Defendant places telephone calls to 

Plaintiff. 

12. On or about January 13, 2015, placed a telephone call to Plaintiff and left the 

following message: 

Hello this message is for David Parsons, my name is Brittany 

Green, I would appreciate you calling me back. You can reach me 

at 866-391-0768 extension 5733. Thank you. 

13. The Defendant placed the aforementioned call to try and collect the alleged debt 

from Plaintiff. 

14. Defendant did not, through its message, disclose Defendant’s identity. 

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15. Defendant did not, through its message, state its name. 

16. Defendant did not, through its message, state its agents’ duties, role or position. 

17. Defendant did not, through its message, state the nature of its business. 

18. Defendant did not, through its message, disclose that it was a debt collector. 

19. Defendant did not, through its message, disclose that the purpose of its call was 

to collect a debt. 

20. Defendant, through its message, withheld its name to deceive Plaintiff as to 

Defendant’s true identity. 

21. Defendant, through its message, withheld the nature of its call to deceive Plaintiff 

as to Defendant’s true purpose to collect funds from Plaintiff. 

COUNT I

DEFENDANT VIOLATED THE FAIR DEBT COLLECTION PRACTICES ACT

22. Defendant violated the FDCPA based on the following: 

a) Defendant violated § 1692d(6) of the FDCPA by failing to provide Plaintiff 

with its identity in its messages for Plaintiff; and 

b) Defendant violated § 1692e(11) of the FDCPA by failing to disclose in its 

messages that it is a debt collector. 

WHEREFORE, Plaintiff, DAVID PARSONS, respectfully requests judgment be entered 

against Defendant, GC SERVICES LIMITED PARTNERSHIP, for the following 

23. Statutory damages of $1,000.00 pursuant to the Fair Debt Collection Practices 

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

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

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

25. Any other relief that this Honorable Court deems appropriate. 

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COUNT II

DEFENDANT VIOLATED MICH. COMP. LAWS § 445.251-258

26. Defendant violated Mich. Comp. Laws § 445.252(e) by concealing or not 

revealing the purpose of a communication when it is made in connection with collecting a debt. 

27. Defendant violated Mich. Comp. Laws § 445.252(g) by communicating with 

Plaintiff without accurately disclosing its identity. 

WHEREFORE, Plaintiff, DAVID PARSONS, respectfully requests judgment be entered 

against Defendant, GC SERVICES LIMITED PARTNERSHIP, for the following 

28. Statutory damages of $50.00 pursuant to Mich. Comp. Laws § 445.257(2); 

29. Statutory damages of $150.00 pursuant to Mich. Comp. Laws § 445.257(2) if the 

Court finds Defendant’s violation(s) was willful; 

30. Reasonable attorneys’ fees and court costs pursuant to t Mich. Comp. Laws § 

445.257(2); and 

31. Any other relief that this Honorable Court deems appropriate 

Respectfully submitted, 

Dated: March 24, 2015 /s/ Adam T. Hill 

Adam T. Hill 

KROHN & MOSS, LTD. 

10 N. Dearborn St., 3rd Fl. 

Chicago, Illinois 60602 

Telephone: 312-578-9428 

Telefax: 866-802-0021 

ahill@consumerlawcenter.com 

Attorneys for Plaintiff 

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