1

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

THOMAS DONNELLY, on behalf of himself )

and others similarly situated, )

)

Plaintiff, )

) Civil Action No. 4:15-cv-11120

v. )

)

EQUITYEXPERTS.ORG, LLC, ) Class Action Complaint

)

Defendant. ) Jury Trial Demanded

______________________________________ )

NATURE OF ACTION

1. Thomas Donnelly (“Plaintiff”) brings this class action against 

EquityExperts.org, LLC (“Defendant”) under the Fair Debt Collection Practices Act 

(“FDCPA”), 15 U.S.C. § 1692 et seq.

2. In particular, Plaintiff alleges that Defendant failed to properly provide him 

with disclosures required by 15 U.S.C. § 1692g(a), and impermissibly charged excessive 

fees and costs incident to the collection of a debt, in violation of 15 U.S.C. § 1692e(2)(A) 

and 15 U.S.C. § 1692f. 

BACKGROUND

3. Congress enacted the FDCPA in 1977 to “eliminate abusive debt collection 

practices by debt collectors.” 15 U.S.C. § 1692(e).

4. It did so in response to “the use of abusive, deceptive, and unfair debt 

collection practices by many debt collectors,” which contributes “to the number of personal 

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.1 Page 1 of 17
2

bankruptcies, to marital instability, to the loss of jobs, and to invasions of individual 

privacy.” 15 U.S.C. § 1692(a).

5. Recently, the Consumer Financial Protection Bureau (“CFPB”)—the federal 

agency tasked with enforcing the FDCPA—explained: “Harmful debt collection practices 

remain a significant concern today. The CFPB receives more consumer complaints about 

debt collection practices than about any other issue.”1

6. Of these complaints about debt collection practices, over one third relate to 

debt collectors’ attempts to collect debts that consumers do not owe.2

7. To combat this problem, the FDCPA requires that debt collectors send 

consumers “validation notices” containing certain information about their alleged debts 

and related rights “[w]ithin five days after the initial communication with a consumer in 

connection with the collection of any debt,” unless the required information was “contained 

in the initial communication or the consumer has paid the debt.” 15 U.S.C. § 1692g(a). 

8. These validation notices must advise consumers of, among other things, the 

right to dispute a respective debt and to request, in writing, that the debt collector provide 

the consumer with certain information. 15 U.S.C. § 1692g(a)(4).

 

1 See Brief for the CFPB as Amicus Curiae, Dkt. No. 14, p. 10, Hernandez v. Williams, 

Zinman, & Parham, P.C., No. 14-15672 (9th Cir. Aug. 20, 2014), 

http://www.ftc.gov/system/files/documents/amicus_briefs/hernandez-v.williams-zinmanparham-p.c./140821briefhernandez1.pdf

2 See Consumer Financial Protection Bureau, Fair Debt Collection Practices Act—CFPB 

Annual Report 2014 at 9-10 (2014) (“CFPB 2014 Report”), 

http://files.consumerfinance.gov/f/201403_cfpb_fair-debt-collection-practices-act.pdf

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.2 Page 2 of 17
3

9. Specifically, if a consumer “notifies the debt collector in writing within the 

thirty-day period that the debt, or any portion thereof, is disputed,” the debt collector must 

“obtain verification of the debt or a copy of a judgment against the consumer,” and mail “a 

copy of such verification or judgment” to the consumer. Id. (emphasis added). 

10. “[T]his validation requirement was a ‘significant feature’ of the law that 

aimed to ‘eliminate the recurring problem of debt collectors dunning the wrong person or 

attempting to collect debts which the consumer has already paid.’”3

11. Separately, the FDCPA prohibits debt collectors from charging fees incident 

to the collection of debt that are not authorized by contract or statute.

JURISDICTION AND VENUE

12. This Court has jurisdiction pursuant to 15 U.S.C. § 1692k(d) and 28 U.S.C. 

§ 1331.

13. Venue is proper before this Court pursuant to 28 U.S.C. § 1391(b), where the 

acts and transactions giving rise to Plaintiff’s action occurred in this district, where Plaintiff 

resides in this district, and where Defendant transacts business in this district.

PARTIES

14. Plaintiff is a natural person who at all relevant times resided in the State of 

Michigan, County of Oakland.

15. Plaintiff is obligated, or allegedly obligated, to pay a debt owed or due, or 

asserted to be owed or due, a creditor other than Defendant.

 

3 Hernandez, No. 14-15672, at 5 (quoting S. Rep. No. 95-382, at 4 (1977)).

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.3 Page 3 of 17
4

16. Plaintiff is a “consumer” as defined by 15 U.S.C. § 1692a(3).

17. Plaintiff’s alleged obligation arises from a transaction in which the money, 

property, insurance, or services that are the subject of the transaction were incurred 

primarily for personal, family, or household purposes—specifically, homeowner’s 

association assessments (the “Debt”).

18. Plaintiff’s Debt was considered by the original creditor to be in default when 

referred to Defendant for collection.

19. Defendant is a Michigan-based limited liability company that at all relevant 

times was engaged, by use of the mails and telephone, in the business of attempting to 

collect a “debt” from Plaintiff, as defined by 15 U.S.C. § 1692a(5).

20. Defendant uses instrumentalities of interstate commerce or the mails in a

business the principal purpose of which is the collection of any debts, and/or regularly 

collects or attempts to collect, directly or indirectly, debts owed or due, or asserted to be 

owed or due, another.

21. Defendant is a “debt collector” as defined by 15 U.S.C. § 1692a(6).

FACTUAL ALLEGATIONS

A. EquityExperts.org, LLC’s debt collection strategy

22. Defendant, a Michigan-based debt collector, utilizes a five-step process to 

collect debts on behalf of its association clients. 

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.4 Page 4 of 17
5

23. As touted on its web site, Defendant first notifies an alleged debtor that his 

debt has been referred to a collection agency and that if full payment is not made within 30 

days, a lien will be filed on the consumer’s home.4 

24. Defendant charges consumers a fee for sending this initial collection letter. 

25. If full payment is not made within 30 days, Defendant then files a lien on the 

consumer’s home, and charges the consumer additional fees for doing so. 

26. At that point, if the consumer does not resolve his debt—and Defendant’s 

resulting fees—the consumer’s file would move to the “constant contact” phase, whereby 

Defendant repeatedly calls and sends letters to the consumer in an attempt to collect the 

alleged debt. At the same time, Defendant tacks on an additional fee. 

27. Thereafter, if the outstanding debt still is not resolved, Defendant notifies the 

consumer of its intent to foreclose on the consumer’s home and move forward with 

foreclosure by advertisement. 

B. EquityExperts.org, LLC’s efforts to collect an alleged debt from Plaintiff

28. In connection with the collection of the Debt, Defendant sent Plaintiff an 

initial written communication dated February 26, 2015. A true and correct copy of 

Defendant’s February 26, 2015 communication is attached hereto as Exhibit A.

29. Defendant’s February 26, 2015 communication was Defendant’s initial 

communication to Plaintiff regarding the Debt.

 

4 See http://www.equityexperts.org/faq-page#n34 (last visited March 18, 2015).

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.5 Page 5 of 17
6

30. Defendant’s February 26, 2015 communication demanded payment of a 

current balance of $560.00. Ex. A.

31. Defendant’s February 26, 2015 communication stated, in pertinent part:

NOTICE OF IMPORTANT RIGHTS

Equity Experts.org, LLC is a debt collector. This communication is from a 

debt collector. This communication is an attempt to collect a debt and any 

information obtained will be used for that purpose. The name of the creditor 

to whom the debt is owed is Stonegate Pointe. The amount of the debt owed 

is $560.00 for property 296 ARUSHA.

Unless you dispute the validity of the debt, or any part of the debt, within 30 

days from the date of this letter Equity Experts.org will obtain verification of 

the debt or a copy of judgment against you, if any, and mail a copy of the 

verification or judgment to you. If you request the name of the original 

creditor, IN WRITING, within 30 days from the date of this letter, Equity 

Experts.org will provide the name and address of the original creditor, if 

different from the current creditor.

Ex. A.

32. Defendant did not otherwise communicate with Plaintiff within the five days 

following its initial communication to him regarding the Debt. 

33. Defendant’s February 26, 2015 communication to Plaintiff violated 15 

U.S.C. § 1692g(a)(4) by failing to inform Plaintiff that Defendant need only have mailed 

to Plaintiff verification of the Debt, or a copy of the judgment, if Plaintiff requested, in 

writing, that Defendant do so. 

34. That is, Defendant was not required to mail verification of the debt, or a copy 

of the judgment, to Plaintiff if he orally requested that Defendant do so, or in the absence 

of any request by Plaintiff. 

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.6 Page 6 of 17
7

35. Defendant’s February 26, 2015 communication, however, states verification 

will automatically be provided, which is not the case, and that there is one standard if a 

consumer wants to obtain the name and address of the original creditor within the subject 

thirty-day time period—send a written request—and a different standard if the consumer 

wants to obtain verification of the debt or a copy of any judgment—do nothing at all.

36. Moreover, Defendant incorrectly states that requests for the name and 

address of the original creditor must be made within 30 days of the date of the letter, as 

opposed to within 30 days of Plaintiff’s receipt of the letter.

37. This misstatement of the rights afforded by the FDCPA would cause the 

least-sophisticated consumer to understand, incorrectly, that requests for debt validation 

need not be made at all, and that requests for the name and address of the original creditor 

must be made within 30 days of the date of the letter, as opposed to within 30 days of its 

receipt. 

38. Such a misunderstanding could lead the least-sophisticated consumer to 

waive or otherwise not properly vindicate his or her rights under the FDCPA. 

39. Moreover, failing to request verification in writing would cause a consumer 

to waive the important protections afforded by 15 U.S.C. § 1692g(b)—namely, that a debt 

collector cease contacting the consumer until the debt collector provides the consumer with 

verification of the alleged debt.

40. As one district court explained:

An oral notice of dispute of a debt’s validity has different legal 

consequences than a written notice. Section 1692g(b) provides that if 

the consumer notifies the collector of a dispute in writing within the 

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.7 Page 7 of 17
8

30–day period, the collector must cease collection activities until he 

obtains the verification or information required by subsections 

1692g(a)(4) and (a)(5). But if the consumer disputes the debt orally 

rather than in writing, the consumer loses the protections afforded by 

§ 1692g(b); the debt collector is under no obligation to cease all 

collection efforts and obtain verification of the debt. Withers v. 

Eveland, 988 F. Supp. 942, 947 (E.D.Va.1997). An oral dispute 

“triggers multiple statutory protections,” but these protections are not 

identical to those triggered by a written dispute. Camacho v. 

Bridgeport Fin. Inc., 430 F.3d 1078, 1081 (9th Cir. 2005). As the 

Ninth Circuit has explained the FDCPA “assigns lesser rights to 

debtors who orally dispute a debt and greater rights to debtors who 

dispute it in writing.” Id. at 1082.

Osborn v. Ekpsz, LLC, 821 F. Supp. 2d 859, 869-70 (S.D. Tex. 2011) (“Every district court 

to consider the issue has held that a debt collector violates § 1692g(a) by failing to inform 

consumers that requests under subsections (a)(4) and (a)(5) must be made in writing.”).

41. In response to Defendant’s February 26, 2015 communication, Plaintiff sent 

email correspondence to Defendant requesting verification of the alleged Debt. In so 

doing, Plaintiff specifically disputed the validity of the alleged Debt.

42. In response, Defendant stated that Plaintiff’s alleged Debt of $560.00 

consisted, in part, of $270.00 in “collection fees” owed to Defendant, which Defendant 

explained is for its “standard account setup fee and intent to record lien.”

43. Upon information and good faith belief, Defendant’s “collection fees” were 

neither expressly authorized by the agreement creating the alleged Debt, nor were they 

otherwise permitted by law.

44. Moreover, upon information and good faith belief, the “collection fees” 

charged by Defendant are substantially more than any costs of collection borne by the 

original creditor. 

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.8 Page 8 of 17
9

45. Indeed, it does not appear that the original creditor bore any costs of 

collection at all. As Defendant advertises on its web site:

Our contingency based firm offers a full range of services related to your 

Association's collection needs. We are the ONLY one-stop-shop in the 

industry and guarantee positive results at NO RISK & NO COST to your 

Association!5

46. Upon information and good faith belief, Defendant’s February 26, 2015 

communication to Plaintiff was based on a template used by Defendant to collect debts 

from consumers throughout Michigan.

47. Upon information and good faith belief, Defendant routinely attempts to 

collect fees and costs, incident to the collection of consumer debt, that are not authorized 

by contract or by law.

CLASS ACTION ALLEGATIONS

48. Plaintiff brings this action as a class action pursuant to Federal Rules of Civil 

Procedure 23(a) and (b)(3) on behalf of two Classes consisting of:

Disclosure Class

(a) All persons with Michigan addresses, (b) to whom EquityExperts.org, 

LLC mailed an initial debt collection communication that stated: “Unless you 

dispute the validity of the debt, or any part of the debt, within 30 days from 

the date of this letter Equity Experts.org will obtain verification of the debt 

or a copy of judgment against you, if any, and mail a copy of the verification 

or judgment to you,” or “If you request the name of the original creditor, IN 

WRITING, within 30 days from the date of this letter, Equity Experts.org 

will provide the name and address of the original creditor, if different from 

the current creditor, (c) in the one year preceding the date of this complaint, 

(d) in connection with the collection of a consumer debt.

 

5

See http://equityexperts.org (last visited March 18, 2015).

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.9 Page 9 of 17
10

Fee Class

(a) All persons with Michigan addresses, (b) to whom EquityExperts.org, 

LLC sent a demand for payment for EquityExperts.org, LLC’s fees and 

expenses incurred in connection with its attempts to collect a debt from such 

person, (c) in the one year preceding the date of this complaint, (d) in 

connection with the collection of a consumer debt.

Excluded from the Classes are Defendant, its officers and directors, members of their 

immediate families and their legal representatives, heirs, successors, or assigns, and any 

entity in which Defendant has or had controlling interests.

49. The proposed Classes satisfy Fed. R. Civ. P. 23(a)(1) because they are so 

numerous that joinder of all members is impracticable. The exact number of Class 

members is unknown to Plaintiff at this time and can only be ascertained through 

appropriate discovery. The proposed Classes are ascertainable in that, upon information 

and belief, the names and addresses of all members of the proposed Classes can be 

identified in business records maintained by Defendant. 

50. The proposed Classes satisfy Fed. R. Civ. P. 23(a)(2) and (3) because 

Plaintiff’s claims are typical of the claims of the members of the Classes. To be sure, the 

claims of Plaintiff and all of the members of the Classes originate from the same conduct, 

practice and procedure on the part of Defendant and Plaintiff possesses the same interests 

and has suffered the same injuries as each member of the proposed Classes.

51. Plaintiff satisfies Fed. R. Civ. P. 23(a)(4) because he will fairly and 

adequately protect the interests of the members of the Classes and has retained counsel 

experienced and competent in class action litigation. Plaintiff has no interests that are 

contrary to or in conflict with the members of the Classes that he seeks to represent. Indeed, 

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.10 Page 10 of 17
11

Plaintiff was appointed as Class Representative by the Eastern District of Michigan in a 

previous class action against Defendant regarding Defendant’s illegal debt collection 

practices. 

52. A class action is superior to all other available methods for the fair and 

efficient adjudication of this controversy, since joinder of all members is impracticable. 

53. Furthermore, as the damages suffered by individual members of the Classes

may be relatively small, the expense and burden of individual litigation make it 

impracticable for the members of the Classes to individually redress the wrongs done to 

them. There will be no difficulty in the management of this action as a class action.

54. Issues of law and fact common to the members of the Classes predominate 

over any questions that may affect only individual members, in that Defendant has acted 

on grounds generally applicable to the Classes. Among the issues of law and fact common 

to the Classes are:

a. Defendant’s violations of the FDCPA as alleged herein;

b. Defendant’s failure to properly provide in its initial debt collection letter the 

disclosures required by 15 U.S.C. § 1692g(a);

c. Defendant’s demands for payment of collection fees and costs that are not 

authorized by contract or law;

d. the existence of Defendant’s identical conduct particular to the matters at 

issue;

e. the availability of statutory penalties; and

f. the availability of attorneys’ fees and costs.

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.11 Page 11 of 17
12

COUNT I

VIOLATION OF 15 U.S.C. § 1692e(2)(A)

On behalf of Plaintiff and the Fee Class

55. Plaintiff repeats and re-alleges each and every factual allegation contained in 

Paragraphs 1-54 above

56. 15 U.S.C. § 1692e(2)(A) provides: 

False or misleading representations

A debt collector may not use any false, deceptive, or 

misleading representation or means in connection with the 

collection of any debt. Without limiting the general 

application of the foregoing, the following conduct is a 

violation of this section:

(2) The false representation of—

(A) the character, amount, or legal status of any debt;

57. In its February 26, 2015 communication, Defendant falsely, deceptively, 

and/or misleadingly stated the amount of the Debt owed by Plaintiff by including 

“collection fees” of $270 in Plaintiff’s alleged balance.

58. Because Plaintiff did not owe any collection fees to Defendant, Defendant 

violated 15 U.S.C. § 1692e(2)(A) by falsely representing the character, amount, or legal 

status of the alleged Debt.

COUNT II

VIOLATION OF 15 U.S.C. § 1692f(1)

On behalf of Plaintiff and the Fee Class

59. Plaintiff repeats and re-alleges each and every factual allegation contained in 

Paragraphs 1-54 above.

60. 15 U.S.C. § 1692f(1) provides: 

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.12 Page 12 of 17
13

Unfair practices

A debt collector may not use unfair or unconscionable means 

to collect or attempt to collect any debt. Without limiting the 

general application of the foregoing, the following conduct is 

a violation of this section:

(1) The collection of any amount (including any interest, fee, 

charge or expense incidental to the principal obligation) unless 

such amount is expressly authorized by the agreement creating 

the debt or permitted by law. 

61. Defendant violated 15 U.S.C. § 1692f(1) by charging fees and costs of 

collection that were neither expressly authorized by the agreement creating the debt or by 

law.

62. Defendant also violated 15 U.S.C. § 1692f(1) by charging fees and costs of 

collection that were not borne by the original creditor.

COUNT III

VIOLATION OF 15 U.S.C. §1692g(a)

On behalf of Plaintiff and the Disclosure Class

63. Plaintiff repeats and re-alleges each and every factual allegation contained in 

Paragraphs 1-54 above.

64. 15 U.S.C. § 1692g provides: 

(a) Within five days after the initial communication with a consumer in 

connection with the collection of any debt, a debt collector shall, unless the 

following information is contained in the initial communication or the 

consumer has paid the debt, send the consumer a written notice containing –

(1) the amount of the debt;

(2) the name of the creditor to whom the debt is owed;

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.13 Page 13 of 17
14

(3) a statement that unless the consumer, within thirty days after receipt of 

the notice, disputes the validity of the debt, or any portion thereof, the debt 

will be assumed to be valid by the debt collector;

(4) a statement that if the consumer notifies the debt collector in writing

within the thirty-day period that the debt, or any portion thereof, is disputed, 

the debt collector will obtain verification of the debt or a copy of a judgment 

against the consumer and a copy of such verification or judgment will be 

mailed to the consumer by the debt collector; and

(5) a statement that, upon the consumer’s written request within the thirtyday period, the debt collector will provide the consumer with the name and 

address of the original creditor, if different from the current creditor.

(b) If the consumer notifies the debt collector in writing within the thirty-day 

period described in subsection (a) that the debt, or any portion thereof, is 

disputed, or that the consumer requests the name and address of the original 

creditor, the debt collector shall cease collection of the debt, or any disputed 

portion thereof, until the debt collector obtains verification of the debt or any 

copy of a judgment, or the name and address of the original creditor, and a 

copy of such verification or judgment, or name and address of the original 

creditor, is mailed to the consumer by the debt collector.

(c) The failure of a consumer to dispute the validity of a debt under this 

section may not be construed by any court as an admission of liability by the 

consumer.

(emphasis added).

65. Defendant’s February 26, 2015 communication was its initial 

communication to Plaintiff regarding the Debt.

66. The February 26, 2015 communication was in connection with an attempt to 

collect the Debt from Plaintiff.

67. At the time Defendant acquired Plaintiff’s Debt for collection, the Debt was 

considered to be in default by the original creditor.

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.14 Page 14 of 17
15

68. The February 26, 2015 communication did not contain the proper disclosures 

required by 15 U.S.C. §1692g, nor did Defendant provide such disclosures within five days 

thereafter.

69. Specifically, Defendant’s February 26, 2015 communication violated 15 

U.S.C. §1692g(a)(4) by failing to inform Plaintiff that Defendant need only mail 

verification of the debt to him, and a copy of any judgment, if he notified Defendant of his

request in writing.

70. “Every district court to consider the issue has held that a debt collector 

violates § 1692g(a) by failing to inform consumers that requests under subsections (a)(4) 

and (a)(5) must be made in writing.” Osborn v. Ekpsz, LLC, 821 F. Supp. 2d 859, 870 (S.D. 

Tex. 2011) (citing Bicking, 783 F. Supp. 2d at 844–46; Beasley v. Sessoms & Rogers, P.A.,

No. 5:09–CV–43–D, 2010 WL 1980083, at *6–7 (E.D.N.C. Mar. 1, 2010); Nero v. Law 

Office of Sam Streeter, 655 F. Supp. 2d 200, 206 (E.D.N.Y. 2009); McCabe v. Crawford 

& Co., 272 F. Supp. 2d 736, 742–44 (N.D. Ill. 2003); Carroll v. United Compucred 

Collections, Inc., No. 1–99–0152, 2002 WL 31936511, at *8–9 (M.D. Tenn. Nov. 15, 

2002); Grief v. Wilson, Elser, Moskowitz, Edelman & Dicker, LLP, 217 F. Supp. 2d 336, 

340–41 (E.D.N.Y. 2002)).

71. Separately, Defendant’s February 26, 2015 communication violated 15 

U.S.C. §1692g(a)(5) by incorrectly informing Plaintiff that any requests for the name and 

address of the original creditor must be made within 30 days of February 26, 2015, as 

opposed to within 30 days of Plaintiff’s receipt of the February 26, 2015 communication.

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.15 Page 15 of 17
16

72. The result of Defendant’s violation of 15 U.S.C. §1692g(a)(5) is to truncate, 

in violation of the FDCPA, the amount of time within which Plaintiff can request the name 

and address of the original creditor.

73. As a result, Defendant violated 15 U.S.C. §1692g(a).

TRIAL BY JURY

74. Plaintiff is entitled to and hereby demands a trial by jury.

WHEREFORE, Plaintiff prays for relief and judgment as follows:

a) Determining that this action is a proper class action under Fed. R. Civ. P. 23;

b) Certifying Plaintiff as class representative;

c) Appointing Plaintiff’s counsel as class counsel;

d) Adjudging and declaring that Defendant violated 15 U.S.C. § 1692e(2)(A), 

15 U.S.C. § 1692f(1), and 15 U.S.C. § 1692g(a);

e) Enjoining Defendant from future violations of 15 U.S.C. § 1692e(2)(A), 15 

U.S.C. § 1692f(1), and 15 U.S.C. § 1692g(a) with respect to Plaintiff and the proposed 

classes;

f) Awarding Plaintiff, and members of the proposed classes, statutory damages

as allowed under the FDCPA; 

g) Awarding Plaintiff, and members of the proposed classes, actual damages; 

h) Awarding Plaintiff, and members of the proposed classes, reasonable 

attorneys’ fees and expenses incurred in this action;

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.16 Page 16 of 17
17

i) Awarding Plaintiff, and members of the proposed classes, any pre-judgment 

and post-judgment interest as may be allowed under the law; and

j) Awarding other and further relief as this Court may deem just and proper.

Dated: March 26, 2015

Respectfully submitted,

/s/ Michael L. Greenwald

Michael L. Greenwald

Greenwald Davidson Radbil PLLC

5550 Glades Road, Suite 500

Boca Raton, FL 33431

561-826-5477

561-961-5684 (Fax)

mgreenwald@gdrlawfirm.com

Counsel for Plaintiff and the Proposed Classes

Ronald S. Weiss (P48762)

Law Offices of Ronald S. Weiss

7035 Orchard Lake Road, Suite 600

West Bloomfield, MI 48322

RWeiss@YourFairDebtCollectionRights.com

248-737-8000

248-737-8003 (Fax)

Counsel for Plaintiff and the Proposed Classes

Case 2:15-cv-11120-LJM-RSW ECF No. 1 filed 03/26/15 PageID.17 Page 17 of 17