Sharon D. Cousineau 

Samwel, Cousineau & Shea, PC 

700 West Evergreen Blvd. 

Vancouver, WA 98660 

Tel. 360-750-3789 

Fax 360-750-3788 

scousineau@scslawoffice.com 

ALICIA LESURE

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON 

EUGENE DIVISION

ALICIA LESURE, ) 

) 

Plaintiff, )

)

v. ) Case No. 

) 

PORTFOLIO RECOVERY ASSOCIATES, ) 

LLC, ) 

) 

Defendant. ) 

PLAINTIFF’S COMPLAINT

Plaintiff, ALICIA LESURE (“Plaintiff”), through her attorneys, Samwel, Cousineau & 

Shea, PC, alleges the following against Defendant, PORTFOLIO RECOVERY ASSOCIATES, 

LLC (“Defendant”):

INTRODUCTION

1. Plaintiff’s Complaint is based on the Fair Debt Collection Practices Act 15 U.S.C. 1692,

et seq. (“FDCPA”).

JURISDICTION AND VENUE

2. This Court has jurisdiction under 28 U.S.C. §1331 and 15 U.S.C. §1692k (FDCPA).

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3. Jurisdiction of this court arises pursuant to 15 U.S.C. 1692k(d), which states that such 

actions may be brought and heard before “any appropriate United States district court 

without regard to the amount in controversy.”

4. Venue and personal jurisdiction in this District are proper because Defendant does or 

transacts business within this District, and a material portion of the events at issue occurred 

in this District.

PARTIES

5. Plaintiff is a natural person residing at Portland, Multnomah County, Oregon.

6. Plaintiff is a consumer as that term is defined by 15 U.S.C. 1692a(3).

7. Plaintiff allegedly owes a debt as that term is defined by 15 U.S.C. 1692a(5).

8. Defendant is a debt collector as that term is defined by 15 U.S.C. 1692a(6).

9. Within the last year, Defendant attempted to collect a consumer debt from Plaintiff.

10. Defendant is a national collection agency located in Norfolk, Virginia. 

11. Defendant is a business entity engaged in the collection of bus debt within the State of 

Oregon.

12. Defendant’s business includes, but is not limited to, collecting on unpaid, outstanding 

account balances.

13. When an unpaid, outstanding account is placed with Defendant it is assigned a reference 

number.

14. The principal purpose of Defendant’s business is the collection of debts allegedly owed to 

third parties. 

15. Defendant regularly collects, or attempts to collect, debts allegedly owed to third parties. 

16. During the course of its attempts to collect debts allegedly owed to third parties, Defendant 

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sends to alleged debtors bills, statements, and/or other correspondence, via the mail and/or 

electronic mail, and initiates contact with alleged debtors via various means of 

telecommunication, such as by telephone and facsimile. 

17. Defendant acted through its agents, employees, officers, members, directors, heirs, 

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

FACTUAL ALLEGATIONS

18. Defendant is attempting to collect an alleged consumer debt from Plaintiff. 

19. Plaintiff’s alleged debt owed arises from transactions for personal, family, and household 

purposes.

20. In July 2014, Defendant began placing collection calls to Plaintiff. 

21. Defendant calls Plaintiff on Plaintiff’s cellular telephone at 971-404-7523 in an attempt to 

collect the alleged debt.

22. Defendant calls Plaintiff from 757-663-7884, 731-577-4188, 757-512-5018, 757-251-

0504, and 620-860-1573.

23. 757-663-7884, 731-577-4188, 757-512-5018, 757-251-0504, and 620-860-1573 are 

Defendant’s telephone numbers. 

24. Within the last year, Plaintiff answered several of Defendant’s calls placed to Plaintiff’s 

cell phone.

25. Each time Plaintiff answers Defendant’s calls, Plaintiff disputes the alleged debt and 

requests for Defendant to cease contacting Plaintiff.

26. Despite Plaintiff’s disputes and repeated requests for Defendant to cease contacting 

Plaintiff, Defendant continues to place collection calls to Plaintiff. 

27. Defendant calls Plaintiff’s cell phone at an annoying and harassing rate, usually 4-5 times 

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per day.

COUNT I

DEFENDANT VIOLATED THE FAIR DEBT COLLECTION PRACTICES ACT

28. Defendant violated the FDCPA based on the following:

a. Defendant violated §1692d of the FDCPA by engaging in conduct that the natural 

consequences of which was to harass, oppress, and abuse Plaintiff in connection 

with the collection of an alleged debt when Defendant’s collectors continued to 

call Plaintiff’s cellular telephone after Plaintiff repeatedly disputed the alleged and 

requested that Defendant stop calling; and

b. Defendant violated §1692d(5) of the FDCPA by causing a telephone to ring 

repeatedly and continuously with the intent to annoy, abuse, and harass Plaintiff 

when Defendant continuously called Plaintiff, usually 4-5 times per day, after 

Plaintiff repeatedly told Defendant to stop calling her.

WHEREFORE, Plaintiff, ALICIA LESURE, respectfully requests judgment be entered 

against Defendant, PORTFOLIO RECOVERY ASSOCIATES, LLC, for the following:

29. Statutory damages of $1,000.00 pursuant to the Fair Debt Collection Practices Act, 15 

U.S.C. 1692k;

30. Costs and reasonable attorneys’ fees pursuant to the Fair Debt Collection Practices Act, 

15 U.S.C. 1692k; and

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

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DATED: October 15, 2014 RESPECTFULLY SUBMITTED, 

By: /s/ Sharon D. Cousineau_________

Sharon D. Cousineau

Samwel, Cousineau & Shea, PC

700 West Evergreen Blvd.

Vancouver, WA 98660

Tel. 360-750-3789

Fax 360-750-3788

scousineau@scslawoffice.com

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