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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

QUAVION DESHUN HOLLINS, Individually 

and on Behalf of All Others Similarly Situated,

Plaintiff,

vs.

CHRISTUS HEALTH, a Texas Nonprofit 

Corporation d/b/a TLRA DEBT RECOVERY,

Defendant.

Case No.: 2:23-cv-351

CLASS ACTION COMPLAINT

JURY TRIAL DEMANDED

Plaintiff QUAIVON DESHUN HOLLINS (hereinafter referred to as “Plaintiff”), 

individually and on behalf of all other similarly situated, by and through his attorneys of record 

The Bourassa Law Group, hereby brings this complaint against the above-named defendant, and 

in support thereof alleges the following:

PRELIMINARY STATEMENT

1. Plaintiff brings this action on his own behalf and on the behalf of all others similarly 

situated for actual and statutory damages arising from CHRISTUS HEALTH d/b/a TLRA DEBT 

RECOVERY’S (hereinafter referred to as “Defendant”) violations of the Fair Debt Collection 

Practices Act (hereinafter referred to as the “FDCPA”), 15 U.S.C. § 1692, et seq., and Texas law.

JURISDICTION AND VENUE

2. Jurisdiction of this Court is invoked under 15 U.S.C. § 1692k(d) and 28 U.S.C. §

1331, and supplemental jurisdiction exists for the state law claims under 28 U.S.C. § 1367.

3. Venue in this District is proper because Plaintiff and Defendant reside and/or do 

business in the State of Texas.

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4. Venue is also proper in this District because the acts and transactions that give rise 

to this action occurred, in substantial part, in the Eastern District of Texas where Plaintiff is 

located.

PARTIES

5. Plaintiff is a natural person who resides in Kilgore, Texas.

6. Plaintiff is a “consumer” as defined in the FDCPA at 15 U.S.C. § 1692a(3).

7. Plaintiff allegedly owes a (past due) consumer debt as defined by 15 U.S.C. §

1692a(5) and Texas Finance Code §392.001.

8. Defendant “is a fully licensed and comprehensive debt collection agency with 

nationwide collection capability”1and maintains a principal place of business located at 2707 

North Loop West, Suite 400, Houston, Texas 77008.

9. Plaintiff is informed and believes, and thereon alleges, that Defendant regularly 

collects or attempts to collect consumer debts owed or due or asserted to be owed or due another 

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

Code §392.001.

STATEMENT OF FACTS

10. Plaintiff incorporates by this reference each and every allegation previously made 

in this Complaint, as if fully set forth herein.

11. Defendant’s website states that “TLRA’s collection methodologies and practices 

are based on the mission of CHRISTUS Health of extending the healing ministry of Jesus Christ 

and the core values of Dignity, Integrity, Compassion, Excellence, and Stewardship.”2

12. Beginning in December 2020 and continuing through the present, Defendant has 

1 http://www.tlra.com/Services/BadDebtProgram (visited June 5, 2023).

2

http://www.tlra.com/TLRA/AboutTLRA (visited June 5, 2023).

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relentlessly harassed Plaintiff by telephone in an attempt to collect a hospital bill allegedly owed by 

Plaintiff.

13. Throughout the month of December 2020, Plaintiff received over 50 calls from 

Defendant.

14. Throughout the month of January 2021, Plaintiff received over 120 calls from 

Defendant.

15. Throughout the month of February 2021, Plaintiff received over 300 calls from 

Defendant.

16. Throughout the month of March 2021, Plaintiff received over 200 calls from 

Defendant.

17. Throughout the month of April 2021, Plaintiff received over 350 calls from 

Defendant.

18. On April 27, 2021, Plaintiff, by and through his counsel, sent a cease and desist 

letter certified mail, return receipt requested, to Defendant requesting all further communication 

be directed to Plaintiff’s attorney, validation of the debt, and copies of all written communications 

with Plaintiff as required by the FDCPA.

19. On May 1, 2021, Frank Amaya, a representative of Defendant, signed the receipt 

of the certified letter. 

20. Despite Defendant’s actual knowledge that Plaintiff was represented by an 

attorney, Defendant continued to attempt to communicate with Plaintiff. 

21. Throughout the month of May 2021, Plaintiff received over 300 calls from 

Defendant.

22. On August 10, 2021, Plaintiff received 10 missed calls from Defendant between 7:00 

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a.m. and 8:00 a.m.

23. On April 5, 2022, Plaintiff received 12 missed calls from Defendant in the morning. 

24. On April 25, 2022, Plaintiff received 6 missed calls from Defendant in the morning.

25. On July 25, 2022, Plaintiff received 7 missed calls from Defendant in the morning.

26. On September 2, 2022, Plaintiff received 11 missed calls from Defendant in the 

morning.

27. On March 30, 2023, Plaintiff received 10 missed calls from Defendant in the 

morning.

28. On April 25, 2023, Plaintiff received 8 missed calls from Defendant in the morning.

29. On April 27, 2023, Plaintiff received 5 missed calls from Defendant in the morning.

30. On June 5, 2023, Plaintiff received 10 missed calls from Defendant between 8:00 

a.m. and 10:00 a.m.

31. The calls from Defendant are at all times of the day and night, sometimes as late as 

midnight or as early as 2:00 a.m.

32. During these calls, Plaintiff was called a “sorry ass” and “sorry,” and told to “man up 

and pay [his] debt.”

33. Defendant often did not identify that the call was from a debt collector and would 

misrepresent Defendant as “criminal attorneys.”

34. In addition, Defendant threatened to have the police come to Plaintiff’s home and 

arrest him.

35. Plaintiff was also told by Defendant’s agents or employees that he would “go to jail 

today” and “go to jail for the rest of his life” if he did not pay off the alleged debt.

CLASS ALLEGATIONS

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36. Plaintiff incorporates by this reference each and every allegation previously made 

in this Complaint, as if fully set forth herein.

37. These claims for relief are brought by the Plaintiff individually and on behalf of the 

following class:

a. A class consisting of consumers with a Texas address who:

i. Within one year prior to the filing of this action;

ii. Received calls or other forms of communication from Defendant;

iii. In a form identical or substantially similar to the calls made to

the Plaintiff, described in the statement of facts.

38. Under Federal Rule of Civil Procedure Rule 23, a class action is appropriate and 

preferable in this case because:

a. The calls made at the heart of this litigation and the class is so numerous

that joinder of all members is impractical.

b. There are questions of law and fact common to the class that predominate

over any questions affecting individual class members. The principal 

question presented by this case is whether the calls described in the

Statement of Facts violated various provisions of the FDCPA, including

but not limited to 15 U.S.C. § 1692g.

c. The only issue related to the individuals of class is the identification of the 

individual consumers who received calls (i.e. the class members), a matter 

capable of ministerial determination from the Defendant’s records.

d. Plaintiff’s claims are typical of those of the class members. All are based on 

the same facts and legal theories.

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e. Plaintiff will fairly and adequately represent the class members’ interests

and have retained counsel experienced in handling class actions and 

collection abuse claims.

39. A class action is superior for the fair and efficient adjudication of the class 

members’ claims as Congress specifically envisioned class actions as a principal means of 

enforcing the FDCPA. See 15 U.S.C.§ 1692k. The members of the class are generally 

unsophisticated consumers, whose rights will not be vindicated in the absence of a class action. 

Prosecution of separate actions by individual members of the classes would also create the risk of

inconsistent or varying adjudications resulting in the establishment of inconsistent or varying 

standards and would not be in the best interest of judicial economy.

40. If facts are discovered to be appropriate, Plaintiff will seek to certify the class under 

Rule 23(b)(3) of the Federal Rules of Civil Procedure.

FIRST CLAIM FOR RELIEF

VIOLATIONS OF THE FDCPA, 15 U.S.C.§ 1692c(a)

41. Plaintiff incorporates by this reference each and every allegation previously made 

in this Complaint, as if fully set forth herein.

42. The FDCPA makes it unlawful for a debt collector to communicate with a

consumer in connection with collection of any debt:

(1) at any unusual time or place or a time or place known or

which should be known to be inconvenient to the consumer. 

In the absence of knowledge of circumstances to the 

contrary, a debt collector shall assume that the convenient

time for communicating with a consumer is after 8 o'clock

antemeridian and before 9 o'clock postmeridian, local time 

at the consumer's location; 

(2) if the debt collector knows the consumer is represented by 

an attorney with respect to such debt and has knowledge of, 

or can readily ascertain, such attorney’s name and address, 

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unless the attorney fails to respond within a reasonable 

period of time to a communication from the debt collector or 

unless the attorney consents to direct communication with 

the consumer . . .

15 U.S.C. § 1692c(a)(1) and (2).

43. Defendant called Plaintiff multiple times before 8:00 a.m. and after 9:00 p.m. in 

connection with its attempts to collect a consumer debt from Plaintiff in violation of 15 U.S.C. § 

1692c(a)(1).

44. Defendant called Plaintiff multiple times after having actual knowledge of 

Plaintiff’s representation by an attorney in violation of 15 U.S.C. § 1692c(a)(2).

45. As a result of these violations by Defendant, Plaintiff is entitled to statutory 

damages plus actual damages to be shown specifically at the time of trial.

46. It has been necessary for Plaintiff to obtain the services of an attorney to pursue this 

claim and therefore Plaintiff is entitled to recover reasonable attorneys’ fees therefor.

SECOND CLAIM FOR RELIEF

VIOLATIONS OF THE FDCPA 15 U.S.C.§ 1692d

47. Plaintiff incorporates by this reference each and every allegation previously made 

in this Complaint, as if fully set forth herein.

48. Section 1692d of the FDCPA states, in pertinent part:

A debt collector may not engage in any conduct the natural 

consequence of which is to harass, oppress, or abuse any person in 

connection with the collection of a debt. Without limiting the 

general application of the foregoing, the following conduct is a 

violation of this section:

(1) The use or threat of use of violence or other criminal means 

to harm the physical person, reputation, or property of any 

person.

(2) The use of obscene or profane language or language the

natural consequence of which is to abuse the hearer or 

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reader.

* * *

(5) Causing a telephone to ring or engaging any person in

telephone conversation repeatedly or continuously with 

intent to annoy, abuse, or harass any person at the called 

number.

49. Defendant, by and through its agents, engaged in conduct intended to harass 

Plaintiff.

50. Defendant, by and through its agents, also called Plaintiff a “sorry ass” and told 

him to “man up” and pay the alleged debt in violation of 29 U.S.C. § 1692d(2).

51. In addition, Defendant, by and through its agents, called Plaintiff hundreds of times,

at all hours of the day and night, in connection with its attempts to collect a consumer debt from 

Plaintiff in violation of 29 U.S.C. § 1692d(5).

52. As a result of these violations by Defendant, Plaintiff is entitled to statutory 

damages plus actual damages to be shown specifically at the time of trial.

53. It has been necessary for the Plaintiff to obtain the services of an attorney to pursue 

this claim and therefore the Plaintiff is entitled to recover reasonable attorneys’ fees therefor.

THIRD CLAIM FOR RELIEF

VIOLATIONS OF THE FDCPA 15 U.S.C. § 1692e

54. Plaintiff incorporates by this reference each and every allegation previously made 

in this Complaint, as if fully set forth herein.

55. Section 1692e of the FDCPA states in pertinent part:

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:

* * *

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(3) The false representation or implication that any individual is

an attorney or that any communication is from an attorney.

(4) The representation or implication that nonpayment of any 

debt will result in the arrest or imprisonment of any

person or the seizure, garnishment, attachment, or sale of 

any property or wages of any person unless such action is

lawful and the debt collector or creditor intends to take such 

action.

* * *

(7) The false representation or implication that the consumer 

committed any crime or other conduct in order to disgrace 

the consumer.

* * *

(11) The failure to disclose in the initial written communication

with the consumer and, in addition, if the initial

communication with the consumer is oral, in that initial oral 

communication, that the debt collector is attempting to 

collect a debt and that any information obtained will be used

for that purpose, and the failure to disclose in subsequent

communications that the communication is from a debt 

collector, except that this paragraph shall not apply to a 

formal pleading made in connection with a legal action.

56. Defendant’s agents and employees represented to Plaintiff that they are “criminal 

attorneys” in an attempt to collect a consumer debt from Plaintiff in violation of 15 U.S.C. § 

1692e(3).

57. Defendant, by and through its agents, threatened to have the police come to 

Plaintiff’s home and arrest him, and told Plaintiff he would “go to jail today” and “go to jail for 

the rest of his life” if he did not pay off the alleged debt in an attempt to frighten and disgrace 

Plaintiff in violation of 29 U.S.C. § 1692e(4) and (7).

58. Defendant also failed to disclose in all of its communications with Plaintiff that the 

communication was from a debt collector in violation of 29 U.S.C. § 1692e(11).

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59. As a result of these violations by Defendant, Plaintiff is entitled to statutory 

damages plus actual damages to be shown specifically at the time of trial.

60. It has been necessary for the Plaintiff to obtain the services of an attorney to pursue 

this claim and the Plaintiff is entitled to recover reasonable attorneys’ fees therefor.

FOURTH CLAIM FOR RELIEF

VIOLATION OF THE TEXAS. FINANCE CODE § 392.301(a)

61. Plaintiff incorporates by this reference each and every allegation previously made 

in this Complaint, as if fully set forth herein.

62. Section 392.301 of the Texas Finance Code states in pertinent part:

A debt collector may not use threats, coercion, or attempts to coerce 

that employ any of the following practices:

* * *

(5) threatening that the debtor will be arrested for nonpayment

of a consumer debt without proper court proceedings.

63. Defendant, by and through its agents, threatened to have the police come to

Plaintiff’s home and arrest him, and told Plaintiff he would “go to jail today” and “go to jail for 

the rest of his life” if he did not pay off the alleged debt in an attempt to frighten and disgrace 

Plaintiff in violation of Texas Finance Code § 392.301(a)(5).

64. As a result of the Texas Finance Code violations by Defendant, Plaintiff is entitled 

to actual damages to be shown specifically at the time of trial.

65. It has been necessary for the Plaintiff to obtain the services of an attorney to pursue 

this claim and the Plaintiff is entitled to recover reasonable attorneys’ fees therefor.

FIFTH CLAIM FOR RELIEF

VIOLATION OF THE TEXAS. FINANCE CODE § 392.302

66. Plaintiff incorporates by this reference each and every allegation previously made 

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in this Complaint, as if fully set forth herein.

67. Section 392.302 of the Texas Finance Code states in pertinent part:

A debt collector may not oppress, harass, or abuse a person by:

(1) using profane or obscene language or language intended to 

abuse unreasonably the hearer or reader;

* * *

(4) causing a telephone to ring repeatedly or continuously, or 

making repeated or continuous telephone calls, with the

intent to harass a person at the caller number.

68. Defendant, by and through its agents, called Plaintiff hundreds of times, at all hours 

of the day and night, in connection with its attempts to collect a consumer debt from Plaintiff in 

violation of Texas Finance Code 392.302.

69. Defendant, by and through its agents, also called Plaintiff a “sorry ass” and told 

him to “man up” and pay the alleged debt in violation of Texas Finance Code 392.302.

70. As a result of the Texas Finance Code violations by Defendant, Plaintiff is entitled 

to actual damages to be shown specifically at the time of trial.

71. It has been necessary for Plaintiff to obtain the services of an attorney to pursue 

this claim and Plaintiff is entitled to recover reasonable attorneys’ fees therefor.

DEMAND FOR JURY TRIAL

Please take notice that Plaintiff demands a trial by jury in this action.

PRAYER FOR RELIEF

WHEREFORE, the Plaintiff respectfully prays that this Court grant the following relief in 

Plaintiff’s favor, and on behalf of the class, and that judgment be entered against Defendant for 

the following:

(1) For actual damages incurred by Plaintiff pursuant to 15 U.S.C. § 1692k(a)(1) and

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Tex. Fin Code § 392.403.

(2) For statutory damages awarded to Plaintiff, not to exceed $1,000, pursuant to 15

U.S.C. § 1692k(a)(2)(A);

(3) For statutory damages awarded to the Class Members, pursuant to 15 U.S.C. § 

1692k(a)(2)(B), of the amount not to exceed the lesser of $500,000.000 or 1 per 

centum (1%) of the net worth of the Defendant.

(4) For injunctive relief pursuant to Tex. Fin. Code Ann. § 392.403(a)(1);

(5) A declaration that the calls made by the Defendant, described in the statement of 

facts, violated the FDCPA, pursuant to 15 U.S.C. § 1592k(a)(3);

(6) For disgorgement of all of Defendant’s profits obtained through use of phone calls 

at issue;

(7) For reasonable attorney fees for all services performed by counsel in connection 

with the prosecution of these claims;

(8) For reimbursement for all costs and expenses incurred in connection with the 

prosecution of these claims; and

(9) For any and all other relief this Court may deem appropriate.

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Dated: July 28, 2023

By: 

Respectfully submitted,

/s/ Jason D. Mazingo 

Jason D. Mazingo

Texas State Bar No. 24055925

Jason@MazingoFirm.com

THE MAZINGO FIRM, P.C.

118 West Houston Street

Tyler, Texas 75702

Phone: 903.630.7123

Fax: 903.218.7849

MARK J. BOURASSA, ESQ. (pro 

hace vice forthcoming)

VALERIE S. GRAY, ESQ. (pro hace 

vice forthcoming)

THE BOURASSA LAW GROUP

2350 W. Charleston 

Blvd., Suite 100

Las Vegas, Nevada 89102

Tel: (702) 851-2180

Fax: (702) 851-2189

Email: mbourassa@blgwins.com

vgray@blgwins.com

ATTORNEYS FOR PLAINTIFF

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