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William E. Kennedy State Bar No. 158214 

CONSUMER LAW OFFICE OF WILLIAM E. KENNEDY 

2797 Park Avenue, Suite 201 

Santa Clara, California 95050 

Telephone: (408) 241-1000 

Facsimile: (408) 241-1500 

Email: wkennedy@kennedyconsumerlaw.com 

Attorneys for Plaintiff LUCIA RUIZ 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA – SAN JOSE DIVISION 

LUCIA RUIZ, 

 Plaintiff, 

 v. 

ALLY FINANCIAL INC. 

 Defendants. 

Case No. 

COMPLAINT 

1. Conversion; 

2. Violation of the Rosenthal Fair Debt 

Collection Practices Act, Civ. Code § 

1788, et seq.; 

3. Violation of California Consumer 

Credit Reporting Agencies Act, Civ. 

Code § 1785.1 et seq.; 

4. Violation of the Fair Credit Reporting 

Act, 15 U.S.C. § 1681 et seq.; 

5. Violation of Business and Professions 

Code § 17200 et seq.

DEMAND FOR JURY TRIAL

INTRODUCTION

1. This action was brought in response to Ally Financial Inc.'s wrongful refusal to 

allow plaintiff to reinstate her loan and reclaim her vehicle following repossession, its continued 

attempts to collect a deficiency balance that is not owed, and its continued reporting of 

inaccurate credit reporting information. 

PARTIES

2. Plaintiff Lucia Ruiz is an individual and at all relevant times herein was a resident 

of Monterey County, California. 

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3. Defendant Ally Financial Inc. (hereinafter "Ally") is an automobile financing 

company. Ally was at all relevant times and is qualified to do business in the state of California 

and regularly transacted business in Monterey County and Santa Clara County. 

JURISDICTION 

4. Jurisdiction is proper in the Federal District Court pursuant to 28 U.S.C. § 1331 

on the basis that Defendants by an act or omission violated federal law, specifically the Fair 

Credit Reporting Act, 15 U.S.C. § 1681 et seq. 

INTRADISTRICT ASSIGNMENT 

5. This action may be properly heard in this judicial district because (a) the 

Defendant conducts continuous, systematic and substantial business in Monterey County, and 

(b) the Plaintiff resides in Monterey County. 

FACTUAL BACKGROUND 

6. Plaintiff Lucia Ruiz purchased a new 2016 Jeep Compass from My Jeep Chrysler 

Dodge in Salinas, California on November 27, 2015. The purchase contract was assigned to 

defendant Ally by My Jeep Chrysler Dodge. 

7. Ms. Ruiz paid a $3,450 which consisted of trade in vehicle valued at $1,200 and a 

manufacturer’s rebate of $2,250.00. 

8. Ms. Ruiz’s employment at the Salinas Union High School District was not 

renewed in May 2016 and she fell behind on car payments. Ally repossessed the vehicle in 

October, 2016. 

9. Ally provided a Notice of Plan to Sell Property to Ms. Ruiz which was dated 

October 25, 2016. 

10. The Notice of Plan to Sell Property that Ally provided to Ms. Ruiz is attached as 

Exhibit 1. 

11. The Notice of Our Plan to Sell Property is a form required by California Civil 

Code section 2983.2. 

12. The Notice of Our Plan to Sell Property form set out the requirements for Ms. 

Luiz to redeem or to reinstate her contract and get her vehicle back. 

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13. The Notice of Our Plan to Sell Property form also provided an “Extension Form” 

which Ms. Luiz could use to obtain a ten-day extension of time to redeem or reinstate the 

contract. 

14. Notice of the ten-day extension is required by California Civil Code 

§2983.2(a)(3). 

15. The Extension Form stated that it was to be returned by certified or registered 

mail, return receipt requested to the post office box address shown in the letterhead, or 

personally served or delivered in person to Ally Financial care of CT Corporation System, 350 

North St. Paul, Suite 2900, Dallas, Texas 75201-4234. 

16. The Extension Form stated that “We must receive the signed form by the end of 

the day on November 14, 2016.” 

17. The Notice of Our Plan to Sell Property stated that Ms. Ruiz was required to pay 

a $15.00 fee to the San Jose Police Department before getting her vehicle back. Ms. Ruiz paid 

the fee. 

18. Ms. Ruiz went to the address where her vehicle was being held to retrieve her 

personal belongings. She was required to pay $50.00 to retrieve them. Several of her belongings 

were damaged or soiled. 

19. Seeing that the deadline to make redeem or reinstate the contract was on 

November 14, 2016, Ms. Ruiz took steps to obtain a ten-day extension. 

20. Ms. Ruiz called Ally to ask if she could fax in the extension form. 

21. The Ally representative that she spoke to said that she could not fax in the 

Extension Form. 

22. Ms. Ruiz asked whether, if she mailed the Extension Form with a postmark 

before the November 14, 2016 deadline, it would be considered timely. 

23. The Ally representative that Ms. Ruiz spoke to said that the Extension Form 

would be considered timely if postmarked before the deadline. 

24. Ms. Ruiz mailed the Extension form on November 14, 2016 to Ally Financial 

care of CT Corporation System, 350 North St. Paul, Suite 2900, Dallas, Texas 75201-4234. 

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25. To further ensure that her Extension Form would be received in time, Ms. Ruiz 

hired a courier in Dallas, Texas to hand deliver it to Ally Financial care of CT Corporation 

System, 350 North St. Paul, Suite 2900, Dallas, Texas 75201-4234. 

26. The courier attempted to hand deliver it on November 14, 2016, but was not able 

to because neither CT Corporation nor Ally were located at that address. 

27. The courier did some investigation, and learned that CT Corporation was located 

at another address in Dallas. However, by the time this information was acquired, it was too late 

to deliver the Extension Form on November 14, 2016. 

28. The courier delivered the signed Extension Form to CT Corporation’s new Dallas 

address on November 15, 2016. 

29. Ally nonetheless moved forward with sale of the repossessed vehicle 

30. On November 18, 2016, Ally sent a letter to Ms. Ruiz stating that her vehicle had 

been sold on November 16, 2016. 

31. Accordingly, Ally sold Ms. Ruiz’s vehicle after it had received the Extension 

Form. 

32. The letter November 18, 2016 stated that Ms. Ruiz owed a $9,165.57 deficiency 

to Ally. 

33. Had Ally allowed Ms. Ruiz to reinstate the contract, she would have done so. 

Rees-Levering Act Requirements 

34. California Civil Code section 2983.2(a)(3) requires that the notice of repossession 

set out the address where the request for a ten-day extension can be personally served or 

delivered. In addition, California Civil Code section 2983.2(a)(7) requires that the notice set out 

the address where an accounting can be requested. 

35. The address provided by Ally in the Notice of Our Plan to Sell Property for 

purposes of personal service or delivery of the Extension Form was the incorrect address. 

36. The address provided by Ally in the Notice of Our Plan to Sell Property for 

purposes of requesting an accounting was the incorrect address. 

37. California Civil Code section 2983.2(a) states that car buyers can only be held 

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liable for a “deficiency after disposition of the repossessed or surrendered motor vehicle” only if 

the notice meets all of the requirements, including those in section 2983.2(a)(3) and 

2983.2(a)(7). 

38. Pursuant to Civil Code section 2983.2(a), since Ally didn’t inform Ms. Ruiz of 

the correct address, she does not owe any deficiency to Ally. 

39. Ally nonetheless sent dunning letters to Ms. Ruiz demanding payment of $9,165. 

Ally also called Ms. Ruiz to collect the money. 

40. Ally reported that Ms. Ruiz owed a $9,165 balance to credit reporting agencies 

Equifax, Experian, and Trans Union beginning in November or December 2016, and rereporting this information each month thereafter. 

41. On December 21, 2016, Ms. Ruiz sent a letter to Ally which disputed that she 

owed the $9,165 balance due to non-compliance with the Rees-Levering Act. 

42. The December 21, 2016 letter which Ms. Ruiz sent to Ally is attached as Exhibit 

2. 

43. The December 21, 2016 letter was also sent to Experian, Equifax and Trans 

Union credit reporting agencies. 

44. The December 21, 2016 described in detail the events following the repossession, 

including the attempt to submit the Extension Form. The letter cited the Rees Levering Act 

provisions set forth in this Complaint and explained why pursuant to those provisions Ms. Ruiz 

did not owe a deficiency. 

45. Ms. Ruiz received no response for approximately one month. 

46. Ally sent the letter attached as Exhibit 3 on or about January 24, 2017 to Ms. 

Ruiz. 

47. The January 24, 2017 letter does not address the issue which Ms. Ruiz raised in 

her December 21, 2016 letter, which had to do Ally’s reporting of a deficiency balance. 

48. Ally’s January 24, 2017 letter incorrectly assumed that Ms. Ruiz was disputing 

the payment history on the loan, and respond only to that issue. 

49. Plaintiff is informed and believe that Ally did not give any consideration to 

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whether it had failed to comply with the Rees Levering Act and whether any noncompliance 

barred its attempt to collect a deficiency balance following the sale of the vehicle. 

50. Plaintiff is informed and believe that Equifax forwarded an Automated Consumer 

Dispute Verification form which had information about Ms. Ruiz’ December 21, 2016 letter to 

Ally. 

51. Plaintiff is informed and believe that Experian forwarded an Automated 

Consumer Dispute Verification form which had information about Ms. Ruiz’ December 21, 

2016 letter to Ally. 

52. Plaintiff is informed and believe that Trans Union forwarded an Automated 

Consumer Dispute Verification form which had information about Ms. Ruiz’ December 21, 

2016 letter to Ally. 

53. Plaintiff is informed and believe that Equifax forwarded the December 21, 2016 

letter to Ally. 

54. Plaintiff is informed and believe that Experian forwarded the December 21, 2016 

letter to Ally. 

55. Plaintiff is informed and believe that Trans Union forwarded the December 21, 

2016 letter to Ally. 

56. Plaintiff is informed and believes that Ally communicated to Experian that its 

reporting of a $9,165 deficiency balance was correct. 

57. Plaintiff is informed and believes that Ally communicated to Equifax that its 

reporting of a $9,165 deficiency balance was correct. 

58. Plaintiff is informed and believes that Ally communicated to Trans Union that its 

reporting of a $9,165 deficiency balance was correct. 

59. Mr. Ruiz received a response to the dispute from Experian indicating that it 

would continue to report that Ms. Ruiz owed $9,165, and that the account was past due and 

charged off. 

60. As the result of Ally’s refusal to allow plaintiff to reinstate her car loan, Ms. Ruiz 

has suffered the loss of the vehicle, including all payments made towards the vehicle. Ms. Ruiz 

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has incurred rental car expenses, and other losses and inconveniences caused by the loss of her 

car. Defendant’s collection attempts and negative credit reporting have caused Ms. Ruiz stress 

in the form of upset, nervousness, anger, distraction, and frustration. 

 

FIRST CAUSE OF ACTION 

Conversion 

61. Plaintiff incorporates all other paragraphs of this Complaint as though fully set 

forth herein. 

62. Ms. Ruiz had a right to reinstate the loan pursuant to the California ReesLevering Act and would have done so had she been given the opportunity. 

63. Ally’s failure to provide the information necessary for her to reinstate her vehicle 

amounts to conversion of the vehicle. Cerra v. Blackstone (1985) 172 Cal.App.3d 604. 

64. As a result of Ally’s conversion, Ms. Ruiz has been damaged through the loss of 

her motor vehicle, including the payments she made toward it. Ms. Ruiz has also expended time 

and money attempting to reacquire the vehicle. 

SECOND CAUSE OF ACTION 

Consumer Credit Reporting Act, Civil Code § 1785.1 et seq. 

65. Plaintiff incorporates all other paragraphs of this Complaint as though fully set 

forth herein. 

66. Ally has reported to credit reporting agencies that Ms. Ruiz owes a deficiency 

balance of $9,165 with respect to the vehicle. Ally continued to report this information even 

after being informed of the reason it was incorrect. This false information is expected to remain 

on Ms. Ruiz’s credit report for approximately seven years. 

67. California’s Civil Code § 1785.25(a) states that a “person shall not furnish 

information on a specific transaction or experience to any consumer credit reporting agency if 

the person knows or should know the information is incomplete or inaccurate." 

68. Ally negligently and willfully furnished information to the credit reporting 

agencies that it knew or should have known was incomplete, inaccurate, and misleading, but 

nevertheless has reported and continue to report the information. 

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69. In its willful reporting of inaccurate credit information, Ally was guilty of 

oppression, fraud, and malice as those terms are defined in Civil Code § 3294 (a). 

70. Based on these violations of Civil Code § 1785.25(a), Plaintiff is entitled to the 

remedies afforded him by Civil Code § 1785.31, including actual damages, pain and suffering, 

punitive damages, injunctive relief, and attorney’s fees. 

THIRD CAUSE OF ACTION 

Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq. 

71. Plaintiff incorporates all other paragraphs of this Complaint as though fully set 

forth herein. 

72. 15 U.S.C. §1681s-2b explains the responsibilities of furnishers of credit 

information after they have been notified by a credit reporting agency that the consumer disputes 

the credit information provided by the furnisher. Upon receiving notice of a dispute, the 

furnisher is to review all relevant information provided by the consumer reporting agency, 

conduct a reasonable investigation and report the results to the appropriate consumer reporting 

agencies. The consumer may bring a cause of action against the furnisher if it does not comply 

with the provisions of 15 U.S.C. §1681s-2b. 

73. Plaintiff communicated her dispute regarding the derogatory credit information to 

Equifax, Experian and Trans Union. Thereafter, plaintiff is informed and believes that each of 

these credit reporting agencies notified Ally of the dispute in accordance with 15 U.S.C. 

§1681i(a)(2). 

74. Thereafter, plaintiff is informed and believes that upon being notified of the 

dispute by a credit reporting agency, Ally failed to review all relevant information provided by 

the credit reporting agencies and available in its files, and/or conduct a reasonable investigation 

to ascertain whether the derogatory information it had reported was incomplete or inaccurate, in 

violation of 15 U.S.C. §1681s-2b. 

75. In addition, plaintiff is informed and believes that Ally notified the credit 

reporting agencies that the derogatory credit information reported with respect to the plaintiff 

was correct. 

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76. Plaintiff is informed and believes that the violation of 15 U.S.C. §1681s-2b by 

Ally was willful. In the alternative, plaintiff is informed and believes that the violation of 15 

U.S.C. §1681s-2b by Ally was negligent. 

77. Ally’s violations of 15 U.S.C. §1681s-2b caused damages in an amount to be 

proven at trial. 

FOURTH CAUSE OF ACTION 

Rosenthal Fair Debt Collection Practices Act, Cal. Civil Code §§ 1788, et seq. 

78. Plaintiff incorporates all other paragraphs of this Complaint as though fully set 

forth herein. 

79. Ally is a “debt collector” within the meaning of Civil Code §1788.2(c). 

80. The monies which Ally sought to collect from Plaintiff is a “debt” within the 

meaning of Civil Code §1788.2(d). 

81. Ally, as alleged above, represented to Plaintiff that she owed a deficiency balance 

of $9,165. 

82. This representation is false, and in violation of Civil Code § 1788.13(e), which 

prohibits false representations that the consumers’ debt may be increased by such charges. 

83. The debt collection practices of Ally violated other provisions of the Rosenthal 

Fair Debt Collection Practices Act, including to but not limited to Civil Code §1788.17, which 

incorporates by reference, and requires compliance with the provisions of the federal FDCPA, 

including: 

 A. 15 U.S.C. § 1692e, which prohibits any false, deceptive or misleading 

representation or means in connection with the collection of any debt; 

 B. 15 U.S.C. § 1692e(2)(A), which prohibits misrepresentation of the 

character, amount, or legal status of the debt; 

 C. 15 U.S.C. § 1692e(10), which prohibits the use of any false representation 

or deceptive means to collect or attempt to collect any debt; 

 D. 15 U.S.C. § 1692f(1), which prohibits the collection of any amount unless 

such amount is expressly authorized by the agreement creating the debt or permitted by 

law. 

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84. Ally's violations were willful and knowing. 

85. As a result of Ally’s violations of the Rosenthal FDCPA, Plaintiff suffered actual 

damages and emotional distress, in an amount to be proven at trial. 

FIFTH CAUSE OF ACTION 

California Business and Professions Code § 17200, et seq. 

86. Plaintiff incorporates all other paragraphs of this Complaint as though fully set 

forth herein. 

87. California Business and Professions Code sections 17200, et seq., also known as 

the California Unfair Competition Law (“UCL”), prohibits acts of “unfair competition,” 

including any unlawful, unfair, fraudulent or deceptive business act or practice. 

88. Defendant’s conduct alleged herein constitutes unfair, unlawful, or fraudulent 

acts or practices within the meaning of Business and Professions Code sections 17200, et seq. in 

that it constitutes a violation of the Rees-Levering Act by providing inaccurate and misleading 

information as to how to obtain a ten-day extension of time to reinstate or redeem a vehicle loan 

or obtain an accounting. 

89. As a direct result of Defendant’s unfair, unlawful, or fraudulent acts and 

practices, plaintiff lost money or property. 

90. Defendant’s unlawful, unfair and fraudulent business practices alleged herein 

present a continuing threat to Plaintiff and members of the public in that on information and 

belief Defendant persists and continues to engage in these practices, and will not cease doing so 

unless and until forced to do so by this Court. 

91. Pursuant to Business and Professions Code §§17200 and 17203, plaintiff seeks 

injunctive relief as prayed for below. 

PRAYER FOR RELIEF 

 WHEREFORE, Plaintiff prays for judgment against Defendant as follows: 

a) Actual damages, including emotional distress, pursuant to 15 U.S.C. § 1681n and 15 

U.S.C. § 1681o, California Civil Code § 1685.31(a), and California Civil Code § 

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1788.30(a) and 15 U.S.C. § 1692k(a)(2)(A) (incorporated into the Rosenthal FDCPA 

by Civil Code §1788.17); 

b) Time and money expended in pursuit of reacquisition of Ms. Ruiz’ vehicle; 

c) Punitive damages pursuant to 15 U.S.C. § 1681n(a)(2) and Civil Code § 

1785.31(a)(2)(B); 

d) Statutory damages pursuant to California Civil Code § 1788.30(b) and 15 U.S.C. § 

1692k(a)(2)(B) (incorporated into the Rosenthal Act by Civil Code § 1788.17); 

e) Injunctive relief to remove the derogatory credit from Plaintiff’s credit report 

pursuant to California Civil Code § 1785.31(b) and Business and Professions Code § 

17200 et seq.; 

f) Injunctive relief to require Ally to inform consumers generally of the correct address 

for submission of the Extension Form and to request an accounting. 

g) Costs and reasonable attorney’s fees pursuant to 15 U.S.C. § 1681n(c), California 

Civil Code § 1785.31(a)(1), California Civil Code § 1785.31(d), California Civil 

Code § 1788.30(c), and 15 U.S.C. § 1692k(a)(3) (incorporated into the Rosenthal Act 

by Civil Code §1788.17); and Code of Civil Procedure § 1021.5. 

h) For such other and further relief as the Court deems just and proper. 

DATED: February 7, 2017 CONSUMER LAW OFFICE OF WILLIAM E. 

 KENNEDY 

 By: /s/ William E. Kennedy 

Attorneys for Plaintiff Lucia Ruiz 

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DEMAND FOR JURY TRIAL 

Plaintiff demands a trial by jury of all the claims asserted in this Complaint so triable. 

DATED: February 7, 2017 CONSUMER LAW OFFICE OF WILLIAM E. 

 KENNEDY 

 By: /s/ William E. Kennedy 

Attorneys for Plaintiff Lucia Ruiz 

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