VERIFIED COMPLAINT 1

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

GAINESVILLE DIVISION 

SHARON DAVIS, 

 Plaintiff, 

v. Case No. 

NORTHSTAR LOCATION SERVICES, LLC, 

 Defendant. 

_____________________________________/ 

PLAINTIFF’S COMPLAINT AND DEMAND FOR JURY TRIAL

SHARON DAVIS (“Plaintiff”), by her attorneys, KROHN & MOSS, LTD., alleges 

the following against NORTHSTAR LOCATION SERVICES, LLC, (“Defendant”): 

INTRODUCTION 

1. Count I of Plaintiff’s Complaint is based on the Fair Debt Collection Practices Act, 15 

U.S.C. 1692 et seq. (FDCPA). 

JURISDICTION AND VENUE 

2. 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,” and 28 U.S.C. 1367 grants this court 

supplemental jurisdiction over the state claims contained therein. 

3. Because Defendant conducts business in the state of Florida, personal jurisdiction is 

established. 

4. Venue is proper pursuant to 28 U.S.C. 1391(b)(2).

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VERIFIED COMPLAINT 2

PARTIES 

5. Plaintiff is a natural person who resides in Trenton, Gilchrist County, Florida. 

6. Pursuant to the definitions outlined in 15 U.S.C. 1692a(1-6),Defendant is a debt collector 

and sought to collect a consumer debt from Plaintiff which was allegedly due and owing 

from Plaintiff, and Plaintiff is a consumer debtor. 

7. Defendant has its headquarters in Buffalo, New York. 

8. Defendant uses instrumentalities of interstate commerce or the mails in any business the 

principal purpose of which is the collection of any debts, or who regularly collects or 

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

another and is a "debt collector" as that term is defined by 15 U.S.C. § 1692a(6). 

9. Defendant is a collection agency that in the ordinary course of business, regularly, on behalf 

of itself or others, engages in debt collection. 

FACTUAL ALLEGATIONS

10. On or about June 16, 2010, Defendant placed a collection call to Plaintiff stating it is a 

collection agency calling regarding a debt for Carl Hansbrough (“Hansbrough”) . 

11. Plaintiff informed Defendant that Hansbrough does not reside with her and that she has not 

spoken with him in 30 years. 

12. Plaintiff demanded that Defendant remove her telephone number from the account. 

13. On June 23, 2010, Defendant placed another collection call to Plaintiff regarding the debt 

for Hansbrough. 

14. Defendant informed Plaintiff that two or three years ago, Hansbrough listed Plaintiff as a 

contact and included her telephone number. 

15. Plaintiff just began using the telephone number that Defendant contacted in April 2010. 

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VERIFIED COMPLAINT 3

16. Plaintiff contacted Defendant at 866-856-3109, and spoke with Defendant’s representative 

"Heath" who identified himself as a supervisor or manager. 

17. Heath confirmed that Plaintiff’s phone number was removed from Hansbrough’s account. 

18. Heath then informed Plaintiff that she could be prosecuted for offering third party 

information regarding how to contact Hansbrough. 

COUNT I 

DEFENDANT VIOLATED THE FAIR DEBT COLLECTION PRACTICES ACT 

19. Defendant violated the FDCPA based on the following: 

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

consequence of which is to harass, oppress, or abuse Plaintiff in connection with the 

collection of a debt. 

b. Defendant violated §1692e of the FDCPA by using false, deceptive or misleading 

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

c. Defendant violated §1692e(10) of the FDCPA by using false representation or 

deceptive means to collect or attempt to collect any debt or to obtain information 

concerning Plaintiff. 

WHEREFORE, Plaintiff, SHARON DAVIS, respectfully requests judgment be entered 

against Defendant, NORTHSTAR LOCATION SERVICES, LLC, for the following: 

20. Statutory damages of $1000.00 pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. 

1692k, 

21. Costs and reasonable attorneys’ fees pursuant to the Fair Debt Collection Practices Act, 15 

U.S.C. 1692k 

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

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VERIFIED COMPLAINT 4

 RESPECTFULLY SUBMITTED, 

 By: /s/ Nicholas J. Bontrager 

 [ ] Nicholas J. Bontrager 

 Attorney for Plaintiff 

 Krohn & Moss, Ltd. 

 10474 Santa Monica Blvd., Suite 401 

 Los Angeles, CA 90025 

 Phone: (323) 988-2400 x 229 

 Fax: (323) 802-0021 

 nbontrager@consumerlawcenter.com 

DEMAND FOR JURY TRIAL

 PLEASE TAKE NOTICE that Plaintiff, SHARON DAVIS, hereby demands trial by jury in 

this action. 

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