In the 

United States Court of Appeals 

For the Seventh Circuit ____________________ 

No. 19-1491 

SARAH M. STEFFEK, et al., 

Plaintiffs-Appellants, 

v.

CLIENT SERVICES, INC., et al., 

Defendants-Appellees. 

____________________ 

Appeal from the United States District Court for the 

Eastern District of Wisconsin. 

No. 1:18-cv-00160-WCG — William C. Griesbach, Judge. 

____________________ 

ARGUED DECEMBER 11, 2019 — DECIDED JANUARY 21, 2020 

____________________ 

Before FLAUM, HAMILTON, and BARRETT, Circuit Judges. 

HAMILTON, Circuit Judge. The Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq., requires the collector of a 

consumer debt to send the consumer-debtor a written notice 

containing, among other information, “the name of the creditor to whom the debt is owed.” § 1692g(a)(2). Plaintiffs Sarah 

Steffek and Jill Vandenwyngaard received form notices from 

defendant Client Services, Inc. subject to this requirement. On 

each, a header stated only “RE: CHASE BANK USA, N.A.” 
2 No. 19-1491 

with an account number, and the letters continued: “The 

above account has been placed with our organization for collections.” The letters did not say whether Chase Bank still 

owned the accounts in question or instead had sold the debts 

to another entity. Steffek and Vandenwyngaard sued Client 

Services for violating § 1692g(a)(2), arguing that these letters 

failed to identify clearly the current holder of the debt.

The district court certified a plaintiff class of Wisconsin 

debtors who received substantially identical notices from Client Services. The court then found that undisputed facts 

showed that Chase Bank was actually the current creditor and 

granted summary judgment to Client Services. Steffek v. Client 

Servs., Inc., No. 1:18-cv-00160-WCG, 2019 WL 1126079, at *5 

(E.D. Wis. Mar. 12, 2019). The actual identity of the current 

creditor, however, does not control the result. Regardless of 

who then owned the debts, the question under the statute is 

whether the letters identified the then-current creditor clearly 

enough that an unsophisticated consumer could identify it 

without guesswork. See Janetos v. Fulton Friedman & Gullace, 

LLP, 825 F.3d 317, 321 (7th Cir. 2016). Undisputed facts show 

that the notices here failed that test. We therefore reverse and 

remand for entry of summary judgment in the plaintiffs’ favor 

as to liability.

I. Factual and Procedural Background

The facts needed to decide this case are few and undisputed. Steffek and Vandenwyngaard received form dunning 

letters, also called debt validation notices, from Client Services. The parties agree that Client Services is a “debt collector,” that the named plaintiffs are “consumers,” and that the 

letters were “communications” in connection with attempts to 
No. 19-1491 3

collect “debts,” as each of those terms is defined in the Act. 

See 15 U.S.C. § 1692a(2)–(3), (5)–(6). 

The letter Steffek received was identical to the others except for differing account numbers and balances. It began 

with a header that read: 

RE: CHASE BANK USA, N.A. 

ACCOUNT NUMBER: XXXXXXXXXXXX3802 

BALANCE DUE: $8,936.43 

REFERENCE NUMBER: [redacted]3872 

The body of the letter then read: 

The above account has been placed with our organization for collections. 

Unless you notify our office within thirty (30) 

days after receiving this notice that you dispute 

the validity of this debt or any portion thereof, 

this office will assume this debt is valid. If you 

notify this office in writing within thirty (30) 

days from receiving this notice that you dispute 

the validity of this debt or any portion thereof, 

this office will obtain verification of the debt or 

obtain a copy of a judgment and mail you a copy 

of such judgment or verification. If you request 

of this office in writing within thirty (30) days 

after receiving this notice, this office will provide you with the name and address of the original creditor, if different from the current creditor. 

We look forward to working with you in resolving this matter. 
4 No. 19-1491 

The letter further specified that payment should be made to 

Client Services. The only addresses contained in the letter 

were the P.O. box and street addresses of Client Services in 

Missouri. Finally, a postscript stated: “THIS 

COMMUNICATION IS FROM A DEBT COLLECTOR. THIS 

IS AN ATTEMPT TO COLLECT A DEBT. ANY 

INFORMATION OBTAINED WILL BE USED FOR THAT 

PURPOSE.” A slightly redacted copy of the letter Steffek received is attached as an appendix to this opinion. 

The parties agreed on a stipulation to all facts necessary 

for cross-motions for summary judgment. Client Services reneged on its stipulation, however, by submitting some additional evidence, as we discuss in the concluding portion of 

this opinion. After addressing that procedural complication, 

the district court granted summary judgment to Client Services. Steffek, 2019 WL 1126079, at *5. Finding that the letters 

“contained” the name of Chase Bank and no other creditor, 

the court decided that the letters satisfied § 1692g(a)(2) as a 

matter of law. Id. at *4. The plaintiffs have appealed.1

II. Failure to Identify the Current Creditor

The Fair Debt Collection Practices Act protects consumers 

through a series of disclosure requirements, beginning with 

the initial notice subject to 15 U.S.C. § 1692g. The required information includes the amount of the debt; the name of the 

 

1 The district court also granted summary judgment on any claims 

arising under 15 U.S.C. § 1692e, the Act’s general prohibition on false, deceptive, or misleading representations. Steffek, 2019 WL 1126079, at *5. The 

complaint alleged violations of § 1692e, but plaintiffs did not make any 

argument opposing summary judgment on those claims. Any claims under § 1692e are forfeited. 
No. 19-1491 5

creditor; a statement that unless the debtor disputes the validity of the debt within 30 days, it will be assumed to be valid; 

a statement that if the debtor disputes the debt in writing, the 

collector will mail the consumer verification of the debt or a 

copy of the judgment; and a statement that, upon written request within 30 days, the debt collector will provide the name 

and address of the original creditor if different from the current creditor. § 1692g(a). 

We and other circuits have long interpreted § 1692g to require that the mandatory disclosures be made so that they 

would be clearly understood by unsophisticated debtors. 

“The statute does not say in so many words that the disclosures required by it must be made in a nonconfusing manner. 

But the courts, our own included, have held, plausibly 

enough, that it is implicit that the debt collector may not defeat the statute’s purpose by making the required disclosures 

in a form or within a context in which they are unlikely to be 

understood by the unsophisticated debtors who are the particular objects of the statute’s solicitude.” Bartlett v. Heibl, 128 

F.3d 497, 500 (7th Cir. 1997), citing Avila v. Rubin, 84 F.3d 222, 

226 (7th Cir. 1996) (to be valid, a debt validation notice “must 

be effective, and it cannot be cleverly couched in such a way 

as to eviscerate its message”); Terran v. Kaplan, 109 F.3d 1428, 

1432 (9th Cir. 1997) (debt validation notice may not include 

superfluous language that “overshadows” the required disclosures); Russell v. Equifax A.R.S., 74 F.3d 30, 35 (2d Cir. 1996) 

(“It is not enough for a debt collection agency simply to include the proper debt validation notice in a mailing to a consumer—Congress intended that such notice be clearly conveyed.”); Graziano v. Harrison, 950 F.2d 107, 111 (3d Cir. 1991) 

(§ 1692g was violated by contradictory message: “statutory 

notice must not only explicate a debtor’s rights; it must do so 
6 No. 19-1491 

effectively”); Miller v. Payco–General American Credits, Inc., 943 

F.2d 482, 484 (4th Cir. 1991) (“a debt collector does not comply 

with § 1692g merely by inclusion of the required debt validation notice; the notice Congress required must be conveyed 

effectively to the debtor” (quotation omitted)). 

This implied requirement of clarity extends to identification of the current creditor under § 1692g(a)(2). The mere 

presence of the correct name in the notice somewhere does 

not suffice. See Smith v. Simm Assocs., Inc., 926 F.3d 377, 381 

(7th Cir. 2019) (explaining that § 1692g(a)(2) “requires a debt 

collector to present information about the creditor and the 

debt in the manner the unsophisticated consumer can understand”); Janetos v. Fulton Friedman & Gullace, LLP, 825 F.3d 317, 

321 (7th Cir. 2016) (“When § 1692g(a) requires that a communication include certain information, compliance demands 

more than simply including that information in some unintelligible form.”). Across all the Act’s protections, we evaluate a 

communication “through the objective lens of an unsophisticated consumer who, while ‘uninformed, naïve, or trusting,’ 

possesses at least ‘reasonable intelligence, and is capable of 

making basic logical deductions and inferences.’” Smith, 926 

F.3d at 380 (claim under § 1692g(a)(2)), quoting Pettit v. Retrieval Masters Creditor Bureau, Inc., 211 F.3d 1057, 1060 (7th 

Cir. 2000) (claim under § 1692e). 

Turning to the notice at issue in this case, the problem for 

Client Services is that the form letter simply did not identify 

Chase Bank as the creditor to whom the debts were then 

owed. The heading said “RE: CHASE BANK,” followed by an 

account number, which communicated only that the letter 

somehow related to the listed Chase Bank account. The body 

of the letter then explained that this “account has been placed 
No. 19-1491 7

with our organization for collections,” referring to Client Services. Farther down, the letter said that the recipient could 

write to Client Services to find out if the original creditor was 

different from the current creditor. This latter sentence raised 

the possibility that the debt could have been resold, but the 

letter did not clarify who actually owned the debt. The letter 

did not communicate clearly on whose behalf Client Services 

was trying to collect the debt. The letter did say, however, that 

the recipient should pay Client Services rather than anyone 

else, which a recipient could reasonably understand as implying that Client Services itself was then the creditor. 

As it turns out, the evidence available on summary judgment indicated that Chase Bank still owned the accounts for 

the two lead plaintiffs, Steffek and Vandenwyngaard. But this 

fact—extrinsic to the letter itself—does not insulate Client Services from the claim that it violated § 1692g(a)(2), which required it to identify the current creditor clearly, without leaving the matter to guesswork. In Smith, the letter identified an 

entity as the “original creditor” and named no other potential 

creditor, which we concluded left no doubt as to who then 

owned the debt. 926 F.3d at 380–81. Similarly, our recent decision in Dennis approved a letter that expressly identified 

both the “original creditor” and the “current creditor” in 

those terms. See Dennis v. Niagara Credit Solutions, Inc., — F.3d 

—, No. 19-1654, 2019 WL 7288044 at *1 (7th Cir. Dec. 30, 2019).

This case is controlled by Janetos, however, not Smith or 

Dennis. The notice in Janetos said that the account had been 

“transferred from Asset Acceptance, LLC, to Fulton, Friedman & Gullace, LLP.” 825 F.3d at 321. The debt collector, Fulton, argued that this “transferred” phrase made clear that Asset Acceptance owned the debt and that Fulton was only 
8 No. 19-1491 

collecting it. Id. We disagreed: “standing alone the fact that 

the form letter included the words ‘Asset Acceptance, LLC’ 

did not establish compliance with § 1692g(a)(2).” Id. The letter 

left recipients “to guess who currently owned the debts in 

question.” Id. at 323. Because this facial lack of clarity left no 

factual dispute, we reversed summary judgment for the defendants and directed summary judgment for the plaintiffs. 

Id. at 326. 

Client Services’s arguments to distinguish Janetos are not 

persuasive. First, it urges that unsophisticated consumers 

would understand the difference between “transferred,” used 

by the collector in Janetos, and “placed,” used here. With respect, that supposed difference is not clear to the members of 

this panel, let alone to unsophisticated consumers. Client Services has not shown that “transferred” and “placed” have distinct meanings regarding ownership of a debt that are universally understood even in the debt-collection business itself. 

And even if consistent trade usage of those verbs had been 

shown, that would not show compliance with § 1692g(a)(2), 

which requires clear communication to unsophisticated consumers. 

Second, Client Services cites several district court decisions that have approved similar letters on the theory that 

they gave account numbers for the debts and thus identified 

the creditors. E.g., Howard v. Client Services, Inc., No. 0:17-cv62425-UU, 2018 U.S. Dist. LEXIS 142827, at *17 (S.D. Fla. Aug. 

21, 2018) (noting “the account information in the header” and 

granting summary judgment to Client Services). The district 

court here also mentioned that practice favorably. Steffek, 2019 

WL 1126079, at *4. We agree that listing an account number 

may help a consumer identify the origins of the debt in 
No. 19-1491 9

question (especially if it is an old account). The problem under 

§ 1692g(a)(2) is that an original account number, just like “RE: 

CHASE BANK,” says nothing about who owns the debt today.2

Third, Client Services points out that it identified itself on 

the letter as “A DEBT COLLECTOR.” This disclosure appears 

in the so-called “mini-Miranda” warning at the end of the letter as required by 15 U.S.C. § 1692e(11). Client Services argues 

that this mandatory postscript alerted consumers that it collects debts for others rather than buying them itself. By process of elimination, goes the argument, Chase Bank is the only 

creditor named in the notice, so that any recipient would 

 2 Client Services cites additional district court decisions that ruled for 

debt collectors even though the notices identified only accounts, not the 

current creditors. See Ocampo v. Client Services, Inc., No. 18-cv-4326 (BMC), 

2019 WL 2881422 (E.D.N.Y. July 3, 2019); Stehly v. Client Services, Inc., No. 

2:18-cv-5103 (DRH)(ARL), 2019 WL 2646664 (E.D.N.Y. June 27, 2019); 

Philips v. Central Fin. Control, No. 2:17-cv-02011-RDP, 2018 WL 3743221 

(N.D. Ala. Aug. 7, 2018); Taylor v. MRS BPO, LLC, No. 2:17-cv-01733 

(ARR)(RER), 2017 WL 2861785 (E.D.N.Y. July 5, 2017); Santibanez v. Nat’l 

Credit Sys., Inc., No. 6:16-cv-00081, 2017 WL 126111 (D. Or. Jan. 12, 2017); 

Demonte v. Client Services, Inc., No. 14-cv-14511, 2015 WL 12556159 (S.D. 

Fla. July 29, 2015); see also Campagna v. Client Services, Inc., No. 18-cv-3039, 

2019 WL 6498171 (Dec. 3, 2019) (claim under § 1692e). The plaintiffs, on 

the other hand, point to several decisions that have reached the opposite 

result. See Datiz v. Int’l Recovery Assocs., Inc., No. 2:15-cv-03549 

(ADS)(AKT), 2018 WL 3751920 (E.D.N.Y. July 27, 2018), report and recommendation adopted, 2018 WL 4561461 (E.D.N.Y. Sept. 24, 2018); McGinty 

v. Prof’l Claims Bureau, Inc., No. 15-cv-4356 (SJF)(ARL), 2016 WL 6069180 

(E.D.N.Y. Oct. 17, 2016); Lee v. Forster & Garbus LLP, 926 F. Supp. 2d 482 

(E.D.N.Y. 2013); Sparkman v. Zwicker & Assocs., P.C., 374 F. Supp. 2d 293 

(E.D.N.Y. 2005). We do not need to dissect and distinguish these rulings 

in detail; we respectfully disagree with any reasoning inconsistent with 

this opinion’s application of § 1692g(a)(2). 
10 No. 19-1491 

understand that Chase Bank must be the current owner of the 

debt. But we considered and rejected this exact syllogism in 

Janetos: 

[D]efendants argue that the letter made clear 

that Fulton is a law firm and a debt collector. 

True enough, but neither point leads to a “basic 

logical deduction” that Fulton must have been 

collecting the referenced debts on Asset Acceptance’s behalf or that Asset Acceptance remained the current owner of the debts. 

825 F.3d at 321–22, quoting Pettit, 211 F.3d at 1060. What Client Services invokes is not logic but guesswork. Again, Janetos

controls this case. 

Finally, the district court correctly observed that 

§ 1692g(a)(2) does not mandate the use of specific terms such 

as “creditor” or “owner of the debt.” Steffek, 2019 WL 1126079, 

at *4. We made the same point in Smith: “the FDCPA does not 

require use of any specific terminology to identify the creditor.” 926 F.3d at 381. That point does not help Client Services 

here. The Act does not prescribe specific words, but it does 

require the debt collector to identify clearly “the name of the 

creditor to whom the debt is owed.” 15 U.S.C. § 1692g(a)(2). 

Debt collectors are free to use words other than these chosen 

by Congress if the words will communicate the required information to unsophisticated consumers. The plaintiffs are 

entitled to summary judgment as to liability here because this 

letter did not clear that hurdle. 

III. Evidentiary Dispute

Because Client Services is liable for violations of 15 U.S.C. 

§ 1692g(a)(2) no matter who actually owned the debts, we 
No. 19-1491 11

need not decide whether the district court was correct to treat 

that issue as undisputed at summary judgment. See Steffek, 

2019 WL 1126079, at *2. Nevertheless, the evidentiary and 

procedural controversy over the parties’ factual stipulation in 

this case raises issues that recur in summary judgment practice, so it is prudent to address the controversy. 

At the first scheduling conference in the district court in 

March 2018, Client Services reported that it was not “100% 

sure” that Chase Bank still held the named plaintiffs’ debts. 

(That initial uncertainty in the litigation tends to confirm the 

point that the dunning letters violated § 1692g(a)(2).) The 

plaintiffs then sought details about the relationship between 

Client Services and the as-yet-unknown owner of the debts 

through requests for production. Client Services objected to 

the requests and responded with only five pages of internal 

account notes, two pages for Steffek and three for Vandenwyngaard.3

Discovery negotiations broke down, and on August 22, 

2018, the plaintiffs filed a motion to compel with the district 

court. Two days later, however, the parties seemed to resolve 

their disputes through a joint stipulation to what they agreed 

were “the only facts that shall be used by the Parties in support of, or in opposition to, a finding of liability by way of any 

dispositive motion filed by the Parties or at trial.” In other 

words, the parties stipulated to ten facts that they thought sufficient to decide the case and agreed to halt all discovery except on the issue of damages. The stipulation provided that 

 3 The plaintiffs did not use one of their permitted interrogatories under Federal Rule of Civil Procedure 33 to ask the identity of the current 

creditor. 
12 No. 19-1491 

Chase Bank “was the original creditor of the debts” but pointedly omitted the identity of the current creditor. The court approved this arrangement by order dated September 11, 2018. 

The parties filed cross-motions for summary judgment on 

October 5, 2018. The plaintiffs’ accompanying statement of 

facts, required by local rule, merely reiterated the ten stipulated facts. But Client Services reneged on the stipulation: its 

statement of facts went beyond the stipulation to claim that 

Chase Bank was not only the original but also the current creditor. In support of this assertion, Client Services attached an 

affidavit from Edward Little, its chief information officer, as 

well as the five pages of account notes disclosed earlier. In 

their opposition brief, the plaintiffs protested that the court 

should enforce the terms of the stipulation and disregard 

these new materials.4

The district court held a conference on March 11, 2019 to 

address the procedural dispute and to settle the identity of the 

current creditor. Client Services insisted that Chase Bank was 

“absolutely” the current creditor; the plaintiffs maintained 

that the court should restrict itself to the stipulated facts. The 

court concluded that the evidence showed that Chase Bank 

was the current creditor and granted summary judgment for 

Client Services the next day. Steffek, 2019 WL 1126079, at *2, 

*5. 

On appeal, the plaintiffs have raised several objections. 

They point out that affiant Little had not been identified as a 

 4 Client Services asserts on appeal that its clear violation of its courtapproved stipulation was not deliberate but resulted from an “internal 

miscommunication,” without any additional detail or explanation. See 

Appellee’s Br. at 12 n.1. 
No. 19-1491 13

knowledgeable witness in Client Services’ initial disclosures 

or supplements. Plaintiffs also contend that the Little affidavit 

did not properly authenticate the Steffek and Vandenwyngaard account notes. More generally, plaintiffs object to the 

district court’s decision to allow Client Services to breach 

without consequence the court-approved stipulation for the 

summary judgment motions. We address these points in turn.

First, a motion for summary judgment supported by an affidavit from a witness not previously disclosed in the case ordinarily will cause problems that Rule 26(a)(1)(A)(i) and (e)(1) 

and case management plans are intended to prevent. Rule 

26(a)(1)(A)(i) requires early identification of “each individual 

likely to have discoverable information—along with the subjects of that information—that the disclosing party may use to 

support its claims or defenses, unless the use would be solely 

for impeachment.” Rule 26(e)(1) imposes a duty on a disclosing party to supplement its disclosures if they turn out to be 

incomplete or incorrect, at least if the new information has not 

already been made known to other parties. Finally, Rule 

37(c)(1) directs judges to exclude evidence left out of required 

disclosures absent some extenuating circumstance. We are not 

suggesting that a party can never move for summary judgment based on an affidavit from a previously undisclosed witness. When that happens, though, judges need to be ready to 

address the problems the tactic creates for opposing parties so 

as to prevent surprise and unfair prejudice. E.g., Baemmert v. 

Credit One Bank, N.A., 271 F. Supp. 3d 1043, 1051 (W.D. Wis. 

2017) (declining to consider declaration submitted at summary judgment from a previously undisclosed witness). 

Second, because the plaintiffs objected to the notes, the 

district court should have considered them only if it 
14 No. 19-1491 

concluded that they would be admissible at trial. See Fed. R. 

Civ. P. 56(c)(2) (authorizing objections that material cited to 

support or oppose a motion for summary judgment “cannot 

be presented in a form that would be admissible in evidence”); Baines v. Walgreen Co., 863 F.3d 656, 662 (7th Cir. 2017) 

(“Evidence offered at summary judgment must be admissible 

to the same extent as at trial, at least if the opposing party objects, except that testimony can be presented in the form of 

affidavits or transcripts of sworn testimony rather than in person.”). Documents must be authenticated by an affidavit that 

lays a proper foundation for their admissibility, even at the 

summary judgment stage. See Castro v. DeVry Univ., Inc., 786 

F.3d 559, 578 (7th Cir. 2015) (affirming district court’s decision 

to disregard a document unaccompanied by an affidavit establishing that it met the business records hearsay exception). 

The Little affidavit presented a borderline case under this 

standard. It contained scant information concerning the provenance of the account notes to support their admissibility under Rule of Evidence 803(6). 

At the same time, we recognize the practicalities of the adversary system. Parties often submit documents on summary 

judgment without authenticating them with affidavits thorough enough to overcome all potential objections: 

When that happens—when one side fails to 

cross all evidentiary t’s and dot all procedural 

i’s—it is also not unusual for opposing lawyers 

to choose to overlook available evidentiary or 

other procedural objections. Lawyers should 

know their cases. Courts are entitled to rely on 

lawyers to decide which potential objections are 

worth raising and which are not. This is 
No. 19-1491 15

especially so when many such defects in summary judgment evidence could be cured 

quickly with a supplemental affidavit or two. 

Neither the rules of evidence nor the rules of 

civil procedure require lawyers or judges to 

raise all available evidentiary objections. 

Cehovic-Dixneuf v. Wong, 895 F.3d 927, 932 (7th Cir. 2018) (affirming summary judgment where objection to moving 

party’s evidence was raised first on appeal); see also Elghanmi 

v. Franklin College, No. IP 99-879-C H/G, 2000 WL 1707934, at 

*1 (S.D. Ind. Oct. 2, 2000) (noting that counsel often do not include full authentication or object to its absence where there 

is no real dispute about authenticity of document). When an 

objection is raised, nothing stops the trial court from allowing 

the offering party to supplement the record to cure the defect. 

But the court may not simply ignore an objection to evidence 

the court will rely upon for its decision. 

Third, and on the other hand, the district court retained 

discretion to consider facts beyond the parties’ stipulation. 

True, “once made, a stipulation is binding unless relief from 

the stipulation is necessary to prevent a ‘manifest injustice’ or 

the stipulation was entered into through inadvertence or 

based on an erroneous view of the facts or law.” Graefenhain 

v. Pabst Brewing Co., 870 F.2d 1198, 1206 (7th Cir. 1989); see 

also Christian Legal Soc’y v. Martinez, 561 U.S. 661, 677 (2010) 

(“[T]he parties will not be permitted to deny the truth of the 

facts stated, ... or to suggest, on appeal, that the facts were 

other than as stipulated or that any material fact was omitted.”), quoting 83 C.J.S., Stipulations § 93 (2000). At the same 

time, however, “the district court has ‘broad discretion’ to decide whether to hold a party to its stipulations.” Graefenhain, 
16 No. 19-1491 

870 F.2d at 1206; see also United States v. Nobles, 422 U.S. 225, 

235 n.9 (1975) (citing district court’s “inherent power to control evidentiary matters”). Although we disagree with the district court on the relevance of the disputed information and 

the ultimate merits, we are not convinced that the court 

abused its broad discretion here in deciding to relieve Client 

Services of its obligations under the stipulation, at least in the 

absence of unfair prejudice, which we do not see. 

The district court’s power to consider evidence it deemed 

relevant or even decisive did not leave the plaintiffs without 

options. When Client Services breached the stipulation by offering evidence that Chase Bank still owned the debts in question, plaintiffs could have sought appropriate relief from the 

district court to prevent unfair prejudice. One obvious remedy would have been a delay under Rule 56(d) to conduct additional discovery. See Smith v. OSF HealthCare System, 933 

F.3d 859, 865–71 (7th Cir. 2019) (reversing denial of Rule 56(d) 

motion). Plaintiffs’ failure to do so supports the district court’s 

conclusion that no actual dispute existed as to the ownership 

of the debt. Nevertheless, as explained above, the identity of 

the current creditor does not determine the outcome of this 

case. 

The defendants’ debt validation notices violated 15 U.S.C. 

§ 1692g(a)(2) as a matter of law by failing to disclose clearly 

the identity of the current creditor. The judgment of the district court is therefore REVERSED. The case is REMANDED 

for further proceedings consistent with this opinion. 
APPENDIX 
3451 Harry S Truman Blvd. 

Saint Charles, MO 63301·4047 

RE: CHASE BANK USA, N.A. 

ACCOUNT NUMBER: XXXXXXXXXXXX3802 

BALANCE DUE: $8,936-43 

REFERENCE 

Office Hours <Central Time). 

Monday-Thu(sday: 8am-8pm 

F1iday: 7am-5pm 

Saturday: 7am-11am 

Sunday: Closed 

PHONE: 877·288-9903 

DA TE: 2/2212017 

The above account has been placed with our organlzatlon for collections. 

Unless you notify our office within thirty (30} days after receiving this nolice that you dispute the validity or this debt or any 

portion thereof, this office will assume lhis debt is valid. If you notify this office in writing within thirty (30) days from receiving 

this notice that you dispute the validity of this debt or any portion thereof, tt1ls office will obtain verification or the debt or 

obtain a copy of a Judgment and mai1 you a copy of sucl1 Judgment or verification. If you request of this office in writing 

within thirty (30} days after receiving this notice, this office will provide you wllh the name and address or the original creoitor, 

ir different from the current credltor_ 

We look rorward to working with you in resolving this matter. 

Mike Crafts 

THIS COMMUNICATION IS FROM A DEBT COLLECTOR THIS IS AN ATIEMPT TO COLLECT A DEBT. 

ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 

FOR lMPORTANT RIGHTS AND PRlVILEGES WHICH MIGHT APPLY TO YOUR STATE OF RESIDENCE, 

PLEASE SEE BELOW OR REVERSE SIDE (IF FAXED THEN FOLLOWING PAGE). 

Send yoLff payment in the enclosed envelope using the 

remittance coupon below. 

llil Pay-by-Phone: 1-877-552-5905 

Do not send correspondence to this address. 

PO Box 1586 

Saint Peters, MO 63376 

a Onfine: www.csiconsumetcenter.com 0 j If you are unable lo pay Lhe balance in run, contacl our 

j°ffice at 877-288-9903 for payment options, which may Ala be available to you. 

lilHil'lli---8-7

_

2 

_____ _ 
CALIFORNIA 

The state Rosenthal Fair Debi Collection Practices Act and the federal Fair Debt Collection Practices Act require that, except 

under unusual circumstances, collectors may not contact you before 8:00 a.m. or after 9:00 p.m . They may not harass you 

by using threats of violence or arrest or by using obscene language. Collectors may not use false or misleading statements 

or call you al work if they know or have reason to know that you may not receive personal calls at work. For the most part. 

collectors may not tell another person. other than your auomey or spouse, about your debt. Collectors may contact another 

person to confinn your location or enforce a judgment. For more lnfonnation about debt collection activities, you may 

contact the Fe<!eral Trade Commission al 1-877-FTC·HELP or www.flc.gov. Non profit credit counseling services may be 

available in the area. 

COLORADO 

FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT. SEE 

WWW.COAG.GOV/CAR. A consumer has the rigl1t to request in writing that a debt collector or collection agency cease 

further communication with the consumer. A written request to cease communication will not prohibit the debt collector or 

collection agency from taking any other at tlon authorized by law to collect the debt. The address anel telephone number for 

Client Services, tnc.'s local Colorado office is: The Executive Building, Attn: Stokes & Wolf, P.C. as agent for Client 

Services, Inc., 1776 S. Jackson St., Suite 900 Denver, CO 80210 (TEL: (303) 753-0945). 

KANSAS 

An investigative consumer report, which includes Information as to your character. general reputation, personal 

characteristics and mode of living, has been requeste<I. You have the right to request additional Information, which includes 

the nature and soope of the investigation. 

MASSACHUSETTS NOTICE OF IMPORTANT RIGHTS: You have the right lo make a written or oral request that telephone calls regarding your 

debt not be made to you at your place or employment. Any such oral request will be valid for only ten days unless you 

provide written confirmation of the request postmarked or delivered within seven days of such request. You may terminate 

this request by writing lo the debt collector. 

MINNESOTA 

This colleclion agency is licensed by the Minnesota Depai1menl of Commeme. 

NEW YORK 

In accordance with the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq., debt collectors are prohibited from 

engaging In abusive, deceptive, and unfair debt collection efforts, Including but not limited to· the use or threat of violence, 

the use of obscene or profane language, and repealed phone calls made with the intent to annoy, abuse, or harass. If a 

creditor or debt collector receives a money judgment against you in court, state and federal laws may prevent the following 

types of income from being taken to pay the debt: supplemental secttlity income (SSI), social security, public assistance 

(welfare), spousal support including maintenance (alimony) or child support, unemployment benefits, disability benefits, 

workers' compensation benefils .. public or private pensions, veterans' benefits, federal student loans, fe<leral student grants, 

federal work study funds, and ninety percent of your wages or salary eame<I in the last sixty days. 

NEW YORK CITY 

New York City Department or Consumer Affairs License Number: 1306512 NORTH CAROLINA North Carolina Perm II \lumber: 100705 

TENNESSEE This collection agency Is licensed by the Collection service Board or the Department of Commerce and Insurance.