1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1

TRINETTE G. KENT (State Bar No. 025180)

KENT LAW OFFICES

3219 E. Camelback Rd #588

Phoenix, AZ 85018

Telephone: (480) 247-9644

Facsimile: (480) 717-4781

E-mail: tkent@kentlawpc.com

Of Counsel to:

Credit Repair Lawyers of America

22142 West Nine Mile Road

Southfield, MI 48033

Telephone: (248) 353-2882

Facsimile: (248) 353-4840

Attorneys for Plaintiff,

Shawn Roth

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

Shawn Roth,

Plaintiff,

vs.

Healthcare Collections-I, L.L.C.,

an Arizona limited liability company,

Defendant.

Case No.: 

COMPLAINT

JURY TRIAL DEMAND

Case 2:17-cv-03956-JJT Document 1 Filed 10/26/17 Page 1 of 6
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

2

NOW COMES THE PLAINTIFF, SHAWN ROTH, BY AND THROUGH 

COUNSEL, TRINETTE G. KENT, and for his Complaint against the Defendant, 

pleads as follows:

JURISDICTION

1. This court has jurisdiction under the Fair Debt Collection Practices Act 

(“FDCPA”), 15 U.S.C. §1692k(d) and 28 U.S.C. §§1331,1337.

VENUE

2. The transactions and occurrences which give rise to this action occurred in the 

City of Apache Junction, Maricopa County, Arizona.

3. Venue is proper in the District of Arizona, Phoenix Division. 

PARTIES

4. Plaintiff is a natural person residing in Apache Junction, Maricopa County, 

Arizona.

5. The Defendant to this lawsuit is Healthcare Collections-I, L.L.C., which is an 

Arizona limited liability company that maintains its registered agent in the City 

of Phoenix, in Maricopa County, Arizona. 

GENERAL ALLEGATIONS

6. Defendant is attempting to collect a consumer debt allegedly owed by Plaintiff 

to Banner Goldfield in the amount of $4,688.00 (“the alleged Debt”). 

Case 2:17-cv-03956-JJT Document 1 Filed 10/26/17 Page 2 of 6
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

3

7. On March 28, 2017, Mr. Roth obtained his Equifax credit file and noticed that 

Defendant reported the alleged Debt.

8. On or about April 7, 2017, Mr. Roth submitted a letter to Defendant, disputing 

the alleged Debt.

9. On or about October 17, 2017, Mr. Roth obtained his Equifax and Trans Union 

credit files and noticed that Defendant failed to flag the alleged Debt as 

disputed on both credit files, in violation of the FDCPA.

10.Mr. Roth suffered pecuniary and emotional damages as a result of Defendant’s 

actions.

COUNT I

VIOLATION OF THE FAIR DEBT COLLECTION PRACTICES ACT

11.Plaintiff reincorporates the preceding allegations by reference.

12.At all relevant times, Defendant, in the ordinary course of its business, regularly 

engaged in the practice of collecting debts on behalf of other individuals or 

entities.

13.Plaintiff is a "consumer" for purposes of the FDCPA, and the account at issue in 

this case is a consumer debt.

14.Defendant is a "debt collector" under the Fair Debt Collection Practices Act 

("FDCPA"), 15 U.S.C. §1692a(6).

Case 2:17-cv-03956-JJT Document 1 Filed 10/26/17 Page 3 of 6
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

4

15.Defendant's foregoing acts in attempting to collect this alleged debt violated the 

following provisions of the FDCPA:

a. 15 U.S.C. §1692e(8) by communicating or threatening to communicate to 

any person credit information which is known or which should be known 

to be false, including the failure to communicate that a disputed debt is 

disputed. Defendant did this when it failed to flag the alleged Debt as 

disputed on Mr. Roth’s Equifax and Trans Union credit files.

16.The Plaintiff has suffered economic, emotional, general, and statutory damages 

as a result of these violations of the FDCPA.

WHEREFORE, PLAINTIFF PRAYS that this court grant him a judgment 

against Defendant for actual damages, costs, interest, and attorneys’ fees. 

DEMAND FOR JUDGMENT RELIEF

Accordingly, Plaintiff requests that the Court grant him the following relief against 

the Defendant:

a. Actual damages;

b. Statutory damages; and

c. Statutory costs and attorneys’ fees.

Case 2:17-cv-03956-JJT Document 1 Filed 10/26/17 Page 4 of 6
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

5

JURY DEMAND

Plaintiffs hereby demand a trial by Jury. 

DATED: October 26, 2017 

KENT LAW OFFICES

By: /s/ Trinette G. Kent 

Trinette G. Kent 

Attorneys for Plaintiff,

Shawn Roth 

Case 2:17-cv-03956-JJT Document 1 Filed 10/26/17 Page 5 of 6
Case 2:17-cv-03956-JJT Document 1 Filed 10/26/17 Page 6 of 6